Last revised: 26.03.2024

This Privacy Notice together with our Terms of Use sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us for the purposes of provision of our services to you through our website and/or other applicable software, including but not limited to: LFT Advisors’s website. The website can be accessed via the following link: https://lftadvisor.com/ (hereinafter – the “Website”).

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our Website, you are accepting and consenting to the practices described in this Privacy Notice.

We take the protection of our user’s (“user/you/your”) personal data very seriously and strictly comply with applicable data protection laws and regulations. In this Privacy Notice below we provide you with an overview of what data we collect for what purpose and how we ensure the protection of such data.

1.1. Legal basis for collection and processing of your data

Applicable legal provisions are in particular those of the regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016, repealing the directive 95/46/EC, on the protection of individuals concerning the processing of Personal Data, on the free movement of such data (“General Data Protection Regulation”, GDPR), the Aсt on the Protection of Personal Data, 2018 Republic of Poland. We will only collect, use and/or pass on Personal Data if this is permitted by law or if the user consents to the data processing.

1.2. Your data will be used for the following purposes:

  1. to implement this Privacy Notice and carry out the contractual relationships between you and us regarding our services available via the Website (Art. 6 (1) b. of GDPR);
  2. to provide our services on the Website, to contact you in any matters regarding our services (also using emails and messaging), and to ensure the technical functionality of our services and fulfillment of contractual or pre-contractual obligations (Art. 6 (1) b. of GDPR);
  3. to prevent fraudulent behavior by any of our users (Art. 6 (1) b. and f. of GDPR);
  4. to analyze your use of our services and improve our services (Art. 6 (1) b. and f. of GDPR);
  5. with your express consent or instruction to carry out our business activities or send you newsletters and other advertising materials (Art. 6 Para. (1) a. of GDPR);
  6. to follow our internal policies and protect our legitimate interests (Art. 6 (1) a., b. or f. GDPR or Art. 7 (2) a. of GDPR);
  7. to comply with our legal obligations before third parties involved in the process of performance of our services (Art. 6 (1) c. GDPR);
  8. to notify you about changes to our services;
  9. to ensure that content from our Website is presented most effectively for you and your device;
  10. for other purposes otherwise explained in this Privacy Notice or by any further communication from us; and
  11. to comply with any applicable ‘know your customer’, anti-money laundering, or anti-terrorist financing laws and regulations in any jurisdiction in which we operate, including, without limitation, the Republic of Poland.

2. Your Consent

We can collect and process your data with your consent. By clicking the “I Agree” button on any of our resources or using our Website, or other of our services you confirm that you fully agree with this Privacy Notice and provide explicit and full consent to us for the collection, processing, and transferring of your data, inter alia, outside the Republic of Poland.

3. Recipient(s) of Your Data

We, as well as our external service providers, receive your data for the provision of our services. We may need to share your information with our external service providers.
We require that third-party organizations who handle or obtain personal information as service providers acknowledge its confidentiality and undertake to respect an individual’s right to privacy and comply with data protection principles including this Privacy Notice.

4. Information We May Collect From You

4.1. We may collect and process the following data about you:

  1. 1. your name;
  2. 2. physical address;
  3. 3. e-mail address and phone number;
  4. 4. date of birth;
  5. 5. gender and nationality.

To obtain the above-mentioned information we may either ask you during your filling of any forms (e.g. registration forms) to access our services. Or, we may ask you to provide us with copies of respective documents by phone, e-mail, or otherwise. Such documents include but are not limited to:

  • passport;
  • driver’s license.

4.2. LFT Advisors may also gather data about you:

  • When you review our services;
  • When you have given third party permission to share with us the information they hold about you;
  • When LFT Advisors‘s suppliers and partners share information with us.

4.3. We may collect your data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law concerning KYC and AML regulation.

4.4. We may collect notes from our conversations with you, details of any complaints or comments you make, details of investments you made, and how and when you contact us.

4.5. Concerning each of your visits to our Website we may automatically collect the following information:

  1. technical information, including the internet protocol (IP) address used to connect your computer to the internet;
  2. browser type and version;
  3. time zone setting;
  4. browser plug-in types and versions;
  5. operating system and platform.
  6. information about your visit, including the full uniform resource locators (URL) clickstream to, through, and from our Website (including date and time);
  7. services you viewed or searched for;
  8. page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
  9. methods used to browse away from the page and any phone number used to call our customer service number.

4.6. Information we receive from other sources.

We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties.

5. Your Rights

5.1. You have the right to:

    1. withdraw your consent relating to the use of your data at any time with effect for the future when such data processing is based on your consent*;
    2. object to the processing of your data, if your data is processed based on legitimate interests (based on Art. 6 (1) f. GDPR);
    3. access the scope of data stored by us;
    4. amend or rectify your data if such data is incorrect or outdated;
    5. request the restriction of processing of your data;
    6. request the erasure of your data;
    7. receive information about the stored data (in a structured, current, and machine-readable format) at any time;
    8. be informed (subject to applicable statutory limitations) of whether your data is being processed by us or on our behalf and, if so, be informed of a description of:

(a) the personal data relating to you which is being or will be processed;
(b) the purposes for which the personal data is being or will be processed;
(c) the recipients or classes of recipients to whom personal data is or may be disclosed; and
(d) any information available to us as to the source of the data.

5.2. To enforce your above-mentioned rights, you may reach us through the email address included at the end of this document.

6. Deletion of Your Data

The data that we collect from you will be stored and processed for the period of time necessary to provide you our services and will be deleted, subject to any retention requirements contained in any applicable law, after there will be no need in its storage and processing.

7. Disclosure of Your Data

7.1. We may share your personal information with third party services providers. We provide only the information they need to perform their specific services. They may only use your data for the exact purposes we specify in our contract with them. We work closely with them to ensure that your privacy is respected and protected at all times. If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

7.2. We may share your data with selected third parties including:

  • business partners, suppliers and subcontractors for the performance of any contract we enter into with them to render you our services.

8. Sharing Your Data With Authorities

We will only do this in very specific circumstances, for example:

  • for fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies
  • we may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

10. Access to Information on Your Data

10.1. GDPR and the Aсt on the Protection of Personal Data, 2018 Republic of Poland give you the right to information held about you and information can be accessed in accordance with GDPR and the Aсt on the Protection of Personal Data, 2018 Republic of Poland by emailing office@lftadvisor.com.

11. Changes to Our Privacy Notice

11.1. Any changes we may make to our Privacy Notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Notice.

12. Contacts

12.1. Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to LFT Advisors via email – office@lftadvisor.com.