1. This Privacy Policy is intended to inform you, the natural person, the data subject, of the applicable personal data protection for your personal data processed by MB Išmanus Investavimas (iFuture Investments) (hereinafter referred to as the iFuture). This Policy provides information on the purposes for which personal data are processed, the applicable legal basis, the scope of processing, the protection and the time limit for processing during the collection of data and the processing of personal data of the data subject, etc.

2. The iFuture processes your data in accordance with provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27-04-2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation) (hereinafter – the Regulation), the Personal Data Protection Law of the Republic of Latvia, the Law on Electronic Communications of the Republic of Latvia and other directly applicable legislation regulating the protection of personal data, as well as instructions of competent authorities.

I. DATA CONTROLLER AND ITS CONTACT DETAILS

3. The data controller is MB Išmanus investavimas, company code No. 304975611. Contact phone +370 680 84992, email info@ifuture.lt You can find the contacts of a specific office by city at https://ifuture.lv/kontakti

II. PROCESSED PERSONAL DATA, PURPOSES, BASES AND STORAGE DURATION

4. The iFuture processes personal data according to the following categories of data subjects: employees, candidates for employees, consultants (partners, intermediaries), candidates for consultants, clients and their representatives (this includes: policyholders, insured persons, pension fund participants and their employers (natural persons), third parties paying pension contributions (part of them).

5. The term “personal data” as used in this Privacy Policy means information or fragments of information relating to you or information that could directly or indirectly identify you. iFuture may collect and process: 1) when you provide certain your personal data for processing one or more of the specific purposes specified in this Policy; 2) when you provide your personal data in order to fulfil an order or contract to which you are a party or to take action at your request before concluding a contract; 3) when you apply for a visit via the iFuture website by filling out forms or requesting services via the contacts listed on the website, contacting the iFuture staff or partners, and in all other ways; 4) when you report a problem or contact the iFuture staff for services; 5) when you interact with the iFuture staff in other ways and for other reasons.

6. The iFuture will only process and store personal data that is identified in the internal documents of the company and it is necessary to achieve specific purposes. If the purposes can be achieved without certain personal data, they will not be processed and stored, unless the processing and storage of such personal data is required by the law. The iFuture may demand additional personal information as necessary to achieve the purposes listed in this Privacy Policy. The iFuture makes every effort not to store any outdated or unnecessary information and to ensure that personal and other information is kept up to date and correct.

7. The iFuture processes the personal data of clients and their representatives in order to fulfil its contractual obligations (to provide a service, etc.) under contract (including verbal), to establish and maintain contractual relations, for communication, to protect the legitimate interests of the company and for other legitimate purposes: name, surname, personal identification number, address, e-mail , phone number, bank account number, e-mails (other correspondence information), personal health, selected types of insurance coverage. These personal data are processed during the term of the contractual relationship and for 10 years after the end of the contractual relationship for evidence following the contractual commitments. Emails and other communication information are stored for 3 years but can be extended up to 10 years when necessary for evidence following the contractual commitments. The basis for the data processing is a contract or for the purpose of taking action at the request of the data subject before the conclusion of the contract or a legitimate interest, or legal obligation.

8. The iFuture processes the following data of consultants (partners, intermediaries), candidates for consultants: name, surname, personal identification number, address, e-mail, phone number, e-mails (other correspondence information). The data is processed in order to establish and maintain cooperation, to fulfil mutual obligations. These personal data are processed during the term of the contractual relationship and for 10 years after the end of the contractual relationship. Emails and other communication information are stored for 3 years, but can be extended up to 10 years for evidence following the contractual commitments. The basis for the data processing is a contract or for the purpose of taking action at the request of the data subject before the conclusion of the contract or a legitimate interest, or legal obligation.

9. The iFuture processes the data of the employees and candidate and agrees on the procedure individually.

10. The iFuture may process personal data to protect the rights and legitimate interests of the Company, to process and manage incoming inquiries, requests and complaints, to recover debts, and so on.

11. The iFuture may process personal data for which it has your explicit consent (e.g. for direct marketing). The consent obtained for direct marketing or other purposes is valid for 5 years.

12. The iFuture may store your personal data for a period of time from the end of the contractual relationship in order to protect its legal interests in the event of a dispute or it is required by the law. The iFuture stores your personal data for no longer than it is reasonably necessary, depending on the purposes for which the data is collected.

13. In the internal rules of the iFuture there are provided the deadlines for storage of individual data and the deadlines set by legislation. The storage of your personal data for longer than specifically indicated in this Policy may be carried out only when: 1) it is necessary for the company to be able to defend itself against demands, claims or lawsuits and to exercise its rights; 2) there are reasonable suspicions of an illegal act which is the subject of an investigation; 3) your data is necessary for proper resolution of a dispute or complaint; 4) in case of other bases provided for in the legislation.

14. At the end of the term of processing and storage of personal data, the iFuture permanently destroys the data. When certain of your data is processed on the basis of the consent, when your consent expires, is revoked or deleted, the iFuture destroys the data processed with your consent. In any case, your consent and proof of it may be stored for a longer period.

III. TRANSFERING OF YOUR DATA

15. In accordance with the Regulation and the Law on the Legal Protection of Personal Data , the iFuture may transfer your personal data to third parties for processing purposes to the extent necessary to fulfil the order and provide the service, ensuring that relevant third parties maintain the confidentiality of personal data and ensure adequate protection.

16. Categories of THE iFuture data recipients: insurance companies, pension funds, legal and financial advisers; third parties handling the registries and the software.

17. If necessary for the aforementioned purposes, the iFuture has the right to transfer your personal data to its suppliers, strategic partners and others who assist in the execution of your orders, commercial activities in order to implement the cooperation. The iFuture requires data recipients to undertake to use the information received only for the purposes for which the data was transferred and in accordance with legal requirements. Data controllers involved by the iFuture have the right to process personal data only in accordance with its instructions and only to the extent necessary for the proper performance of their contractual obligations. Involving data controllers, the iFuture seeks to ensure that data controllers also implement appropriate organisational and technical security measures and maintain the confidentiality of personal data.

18. Your personal data may be processed by data controllers providing the iFuture accounting, data centre and / or server rental, IT maintenance and other services.

19. Data may also be provided to competent authorities or law enforcement agencies, such as the police or supervisory authorities, but only upon their request and only when required by applicable law or in the cases and procedures provided for by the law to enforce the iFuture rights, employee and resource security, to make, provide and defend legal requirements.

20. The iFuture does not transfer data outside the EU to a third country or international organisation.

IV. PROTECTION OF YOUR PERSONAL DATA AND YOUR RIGHTS

21. The iFuture takes the necessary administrative, organisational, technical and physical security measures to protect the personal data you provide from accidental, unlawful or unauthorised destruction, loss, rectification, access, disclosure or use, and other unlawful uses.

22. If you believe that the iFuture is processing your data in breach of data protection law, please at first contact the iFuture, as by good faith efforts it may be resolved all your doubts, granted the requests and corrected any made errors, if any.

23. If you are not satisfied with the proposed solution or if, in your opinion, the necessary action is not taken at your request, you have the right to submit a complaint to the supervisory authority of the State Data Protection Inspectorate in the Republic of Latvia (website address https: //www.dvi.gov.lv/).

24. You have the right to:

1) turn to the iFuture for information about the processing of your personal data;

2) turn to the iFuture for a correction of your personal data and / or to suspend the processing of such personal data, except for storage, in case if after acknowledgement you find out that the data is incorrect, incomplete or inaccurate;

3) apply to the iFuture with a request to destroy personal data or suspend the processing of such personal data, except for storage – in case you become aware of the processing of your personal data, and you established that the personal data is processed illegally or fraudulently;

4) not to give the consent to the processing of your personal data when such data is processed or is intended to be processed for the purposes of direct marketing or for a legitimate interest pursued by the iFuture or a third party to which the personal data is provided;

5) request data portability, which means that a) you have the right to request access to all personal data relating to which you have provided to us in a structured, commonly used and computer-readable format, or b) to transfer that data to another controller (if this is technically possible); this right can only be exercised with regard to personal data that are processed by electronic means and are obtained from you with your own consent or on the basis of a contract;

6) restrict the processing of your personal data;

7) demand the deletion of your personal data;

8) revoke the given consents regarding data processing, when the data is processed with your consent;

25. You have a right to know which personal data is processed, for what purposes, whom it is transferred to by writing to iFuture. To provide this information, we must ascertain your identity. To protect the personal data of the data subject, we will not process anonymous and unidentified requests that have not been identified with appropriate identification documents.

26. The iFuture will resolve your request within one month of receiving your request. This term may be extended for two months in certain cases about which you will be notified.

27. If your request is made electronically, the iFuture will also provide you with an answer electronically, unless this is not possible (e.g. due to the volume of information) or if you ask you to reply in another way. The iFuture may refuse to satisfy your request with a reasoned response once the circumstances set out in the law have been established.

28. Please contact the iFuture immediately if you have any questions, comments or concerns about this Privacy Policy. You have the right to notify the iFuture if you do not wish to be contacted in the future; you want to exercise your other rights as a data subject, which are specified in the Regulation, the Law on the Legal Protection of Personal Data; you want to report any violations of this Privacy Policy.

V. RESPONSIBILITY

29. You must provide complete and correct personal data and inform of any relevant change in personal data. The iFuture shall not be liable for any damages incurred by you and / or third parties if you have provided incorrect and / or incomplete personal information or failed to notify of personal data changes in a proper and timely manner.

VI. COOKIES ON THE WEBSITE

30. In order to improve traffic to the iFuture website, it may used cookies, small pieces of textual information that are automatically created while browsing the website and stored on the website visitor’s computer or other terminal device. The information collected by cookies allows you to browse the iFuture website more conveniently and to learn more about the behaviour of website visitors, analyse trends and improve both the website and the services provided by the iFuture or the information provided on the website. The website uses cookies to process depersonalised personal data. If a website visitor does not give a consent to the storage of Google cookies on his/her computer or other terminal device, he/she may change his/her web browser settings and disable all cookies, delete them all or enable / disable them one by one. For more information about the cookies used by Google on this website, please visit AllAboutCookies.org or www.google.com/privacy_ads.html

VII. WORDING AND AMENDMENT OF THE PRIVACY POLICY

31. The wording of this Privacy Policy is approved by the head of the company and its electronic version or its relevant text is placed on the website of the company, which is available at the following address https://ifuture.ll

32. The version of this Privacy Policy is effective as of 23/03/2020. 33. The iFuture may change this Privacy Policy and publish a new version at any time. Supplements and amendments of the Privacy Policy take effect from the date of their publication, i. e. from the date they are posted on the website.