Privacy and Cookies Policy
This Privacy and Cookie Policy (“Policy”) governs the access to and use of all parts of the website and services branded as Horys (“Horys”, “we”, “our”, “us”) and referring to the domain http://horystech.com/ (“Platform”) and all documents, data, materials or other information made available on the Platform.
This Policy applies to all visitors and/or users of the Platform (“User”, “you”, “your”) who act in their own personal capacity. Please read this Policy along with our Terms and Conditions carefully, and note that by using our Platform, you are consenting to the collection, storage, processing and transfer of your personal information in accordance with this Policy.
Last Updated: July 2024
1. DEFINITIONS
1.1. “Account” refers to the account created to access our Platform.
1.2. “Document(s)” includes any medium in which data is recorded, whether printed, or on tape, or film or by electronic means, or otherwise; map, diagram, photograph, film, microfilm, video-tape, sound recording, or machine-readable record; any record which is capable of being produced from a machine-readable record by means of equipment or a programme, or a combination of both, or any equipment or a programme, or a combination of both, and is used for that purpose by the public body or private body which holds the record.
1.3. “Personal Data” any information that relates directly or indirectly to a natural person whether living or deceased, who is identified or identifiable from that information, or from that and other information in the possession of a data User.
1.4. “User(s)” refers to any natural or legal person accessing and creating an Account on our Platform according to applicable terms and conditions, using any kind of technological devices that allows reading, listening, and/or watching information on the Platform or interacting with this information in an active or passive way.
This Policy may be made available in several languages for educational purposes only. In case of any inconsistency between the English version and a translated version, the English version prevails.
2. PURPOSE OF THIS POLICY
2.1. We understand how important it is for you to understand how we collect, store, process, share, and use your Personal Data. We respect and protect the privacy of our Users’ Personal Data on our Platform.
2.2. The purpose of this Policy is to describe how we collect, process, and manage Users’ Personal Data through the Platform, which is developed to offer our services.
3. ACCEPTANCE
By accessing and using our Platform or our services you are consenting to and accepting the terms of this Policy and all supplementary agreements, including the Terms and Conditions and any other subsequent and supplementary agreement related to the present document and our operations. If you do not agree or consent with the details we require with any aspect of this Policy, you have the right to withdraw your consent, and in doing so you are required to discontinue access or usage of our services.
4. PERSONAL INFORMATION THAT WE COLLECT FROM USERS
4.1. We collect and retain User’s Personal Data to facilitate, advance, and improve our array of products and services. This encompasses the development of technical infrastructure, reinforcement of security measures, adherence to compliance standards, prevention of fraud, and provision of robust customer support. Additionally, it is imperative to acknowledge that your Personal Data will also be collected in line with the prerequisites of our Third-Party Partner Websites. We are committed to exercising due diligence when dealing with every User and in the course of conducting business, and we comply with all the applicable laws and regulations.
4.2. The Personal Data we collect from our Users is as follows:
4.2.1. Users:
Full name;
Date of Birth;
Email address;
Gender;
Residence address;
Nationality;
Zip Code;
Passport or National ID number;
Telephone number;
Credit card details;
Source of wealth;
Occupation;
Bank account details, including institution name, branch, account name, bank identifier;
Bank account number or IBAN;
Browser Information;
IP address;
Login information;
Browser type and version;
Time zone setting;
Platform;
Operating system;
Transaction history;
Pages accessed and links clicked.
4.3. We obtain this information in a number of ways through your use of our Platform or other dealings with us, including through any of our websites, account opening applications, contact forms, telephone, internet chat systems, our account sign up forms, webinar sign up forms, and information provided in the course of ongoing client service correspondence. We may also collect information about you from third parties either through customer due diligence providers, sanctions screening providers, credit reference agencies, publicly available sources or screened third party data lists.
4.4. We will use your information to provide you with information about our products and services, and continuously review your ongoing needs once you open an Account with us or subscribe to information resources on our sites or applications.
4.5. We also collect, use and share statistical or demographic data for many purposes (“Aggregated Data”). Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. Where we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with the law and this Policy.
5. USE OF PERSONAL DATA
5.1 We may use your Personal data to:
To communicate with the User;
To provide our services;
To comply with legal and regulatory compliance;
To detect and prevent fraud and credit risks;
To provide, troubleshoot, and improve our Platform;
To enforce our terms in our Terms of Use;
To provide customer services;
To ensure quality control;
To ensure network and information security;
To enhance and personalize User experience;
To engage in marketing activities;
For transaction services; and
Purposes for which we seek User’s consent.
6. DATA TRANSFER
6.1. Except as described in this Policy, we will not disclose any of your information and we shall only share information in the following circumstances:
6.1.1. We may share your Personal Data if required by law or good faith that such actions are necessary to comply with the applicable laws and regulations state laws, or in a need of a litigation process, judicial or other government warrant or to cooperate with applicable law enforcements or regulatory authorities.
6.1.2. We may share your Personal Data with affiliates, selected third parties, including business suppliers, distributors and subcontractors, and/or outsourced service providers when it is necessary for the delivery of our services. These third parties may have access to or process information about you as part of providing services for us. Please note that the aforementioned third parties only collect, use and disclose your information in the ways indicated by us in order to provide adequate services. We are not liable or responsible for the Privacy and Cookies Policies of these third parties. We recommend that you review the Privacy and Cookies Policy of any third-party services you interact with to understand their use of cookies and data collection practices.
6.1.3. We may share your Personal data with our service providers under contracts to operate the business. For instances:
Cloud storage;
Payment process;
Transaction Monitoring;
Network Infrastructure;
Security;
Customer Support;
Marketing;
KYC/AML service providers;
Data analytics.
6.1.4. We may share your Personal data with any financial institutions which we partner to process payments you have authorized.
6.1.5. We transfer only the minimum amount of data necessary for a particular outsourced service provider(s) (if applicable) and we only cooperate with the outsourced service providers who can provide and ensure an adequate level of Personal Data protection.
6.1.6. We ensure that the service providers and affiliates/business partners who process personal information acknowledge the confidentiality of this information and protect the User’s right to privacy by complying with all applicable privacy and data protection laws.
7. PROTECTION AND STORAGE OF PERSONAL DATA
7.1. Personal data is stored on our secure servers, following internal privacy and security protocols.
7.2. We maintain physical, technical, administrative, and procedural safeguards in connection with the collection, storage, processing, use, transfer and disclosure of the User’s Personal Data. We use firewall barriers, encryption techniques, and authentication procedures to maintain the security of User’s online sessions. We take all measures to protect your personal data, considering the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure. For more information, you can contact us using the Contact Information provided below.
7.3. We take appropriate steps to ensure data privacy and security including through various hardware and software methodologies. However, we cannot guarantee the security of any information that is disclosed online.
7.4. Personal Data collected may be stored and processed in your region, and in any other country where we or our affiliates, subsidiaries and service providers have operating facilities. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem.
7.5. We cannot ensure the security or privacy of data transmitted via email, phone, or SMS, till such data reaches the domain of our network since we have no access to the involved data.
8. DATA RETENTION
8.1. We may retain your data through third parties subject to their privacy policies, as long as you continue to use our Services, have an account with us, or for as long as is necessary to fulfil the purposes outlined in this Privacy and Cookies Policy. We retain Personal Data for as long as it is needed for the purposes for which we collected it. We retain data for as long as you have an active Horys Account. Some information can be deleted from the Platform on request, however, unless prohibited by law, we may retain either the original or an accurate copy of all data and information received from its Users in an easily accessible format for a period of seven (7) years subsequent to the termination of your association with our Platform.
8.2. We do not store, sell, share, rent, or lease any Credit/Debit Card details or Personally Identifiable Information to any third party. We do not pass any debit/credit card details to third parties.
8.3. You can ask to close your account by contacting us, and we will delete your data on request. Once deleted, we will not have any information available to us through/by the third parties.
8.4. We may, however, retain your data for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.
8.5. We take reasonable measures to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for the purpose of providing its services on our Platform for which it was processed and in certain circumstances, if required by law and/or law enforcement agencies, we may not destroy any personal records or Personal Data even though the prescribed period for retention shall have elapsed.
8.6. Furthermore, information or data collected via technical means such as cookies, web page counters, and other analytics tools is kept for a period of up to one (1) year from the expiry of the termination of our association with the User.
9. DATA PROTECTION LAW AND THE EUROPEAN DATA PROTECTION RIGHTS
9.1. We are obliged and bound by the European General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 or "GDPR"), which regulates and protects the data of European Union citizens.
9.2. According to the GDPR, we provide privacy notices:
(i) in a concise, transparent, intelligible, and easily accessible form;
(ii) written in clear and plain language;
(iii) delivered in a timely manner; and
(iv) provided free of charge.
9.3. If Users you are located in the European Economic Area (EEA), they will have the rights as described below:
9.3.1. You may request access to and receive information about the personal data we maintain about you, update and correct inaccuracies in your personal data, restrict or object to the processing of your personal data, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your personal data to another company.
9.3.2. You may withdraw any consent you previously provided to us regarding the processing of your personal data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdraw your consent.
9.3.3. If you are located in the EEA, we will comply with applicable GDPR law when transferring your personal data outside of the EEA.
10. USER RIGHTS PROTECTED UNDER THE GDPR
10.1. Under certain circumstances, according to applicable laws and regulations, you have rights under data protection laws in relation to your Personal Data as detailed below:
10.1.1. Request Access: this enables you to receive copies of your Personal Data we hold about you and to check that we are lawfully processing it. This is also known as a "data subject access request". This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data provided to us.
10.1.2. Request Erasure: this enables you to request us to delete or remove your Personal Data where there is no good reason for us to continue to process it. Nonetheless, there may be circumstances where we may be legally entitled to retain your Personal Data in accordance with the terms of this Policy.
10.1.3. Request to Restrict Processing: this enables you to restrict the processing of your Personal Data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defence of legal claims. Be aware that by restricting your data processing it can lead to limited access to our Platform.
10.1.4. Request to Object Processing: you have the right to object to the processing of your Personal Data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
10.1.5. Request to Transfer: under previous request in written form we can transmit your Personal Data in a structured, commonly used, machine-readable format to another controller. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
10.1.6. Right to Data Rectification: this gives you the authority to request the correction of your Personal Data that we process or hold. This right ensures that personal data is accurate, up-to-date, and complete. If you discover that your Personal Data is incorrect, incomplete, or outdated, you can exercise this right by submitting a formal request to us. We are then obliged to rectify the erroneous data without undue delay, considering the purposes of the processing. This right supports the accuracy and fairness of data processing and contributes to the overall integrity and reliability of the Personal Data collected and processed by us.
11. COOKIES POLICY
11.1. Cookies are small text files that are placed on a device like computer, mobile or any other device by a website, containing details of your browsing history (“Cookies”). Whenever you visit our Platform, the website sends Cookies to the device used to access our Platform. The device automatically stores the Cookies in a file located within your website browser allowing us to recognize your device upon future access.
11.2. We use the following Cookies to operate our Platform, such as:
11.2.1. Session Cookies: are temporary and expire once you close your browser. It stores information for the time, or session when you are on our Platform;
11.2.2. Persistent Cookies: encompass all Cookies that remain on your hard drive until you erase, or your browser does it. It depends on the Cookie’s expiration date. All persistent Cookies have an expiration date written into their code, but their duration can vary;
11.2.3. First-Party Cookies: are put on your device directly by our Platform you are visiting;
11.2.4. Third-Party Cookies: are placed on your device, not by our Platform, but by a third party like an advertiser or an analytic system. Generally, the Third-Party Cookies consist of tracking Cookies used to identify online behaviour, understand interests, and then customize advertising for the User on other websites. Any information obtained from Third-Party Cookies is processed by the respective Collaborative Partners;
11.2.5. Google Analytics Cookies: to measure our User’s interactions with the content on our Platform. These Cookies collect information about your interactions with our Platform, such as unique visits, repeat visits, session duration and website activity;
11.2.6. Facebook Pixel: to process information about a User’s activity on our Platform, such as the website visited, Facebook identity, browser data, and more. The information processed from Facebook pixel is used to serve ads based on your interests through Facebook, as well as to measure cross-device conversions and User interactions on our Platform;
11.2.7. Essential Cookies: are known as strictly necessary Cookies for you to browse our Platform and use the features of it, such as accessing secure areas of our Platform. These Cookies are generally First-Party Session Cookies. These Cookies do not require consent from you. Essential Cookies helps to make our Platform easy to use by providing basic functions such as page navigation, language selections, authorization and filling in forms. Our Platform will not function without these Cookies, and they cannot be disabled. These Cookies do not reveal the User’s identity or collect information. They are stored on the User’s device until the browser is closed;
11.2.8. Functionality Cookies: allow our Platform to remember choices you have made in the past like what language you prefer, what region you would like or what username and password are so you can automatically log in. We use Cookies for navigation and to facilitate your access to and use of this site. These Cookies are necessary for transmission of communications on the network or to supply services whatever requested by you. Further they help us to know which pages are the most and least popular and see how visitors move around the website;
11.2.9. Performance Cookies: collect information about how you use our Platform, like which page you visited, and which link you clicked on. None of this type of information can be used to identify you. The sole purpose of performance cookies is to improve our Platform functions. Analytics may collect information through log data, such as; (i) IP address, (ii) Type of browser and device, (iii) Operating system, (iv) Name of the Internet Service Provider, (v) Country information, (vi) Date and time of visit, (vii) Web page origin and exit; and/or
11.2.10. Marketing Cookies: track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an advertisement. These Cookies can share information with other organizations or advertisers. These Cookies may be set through the website by our advertising partners. If you do not allow these Cookies, you will experience less targeted advertising. These Cookies are set on your device for up to two (2) years or deleted, if you erase your browser Cookie data.
11.3. You reserve the right to decide whether to accept or reject Cookies from our Platform. You can exercise your Cookie rights by setting your preferences in the Cookie Consent Manager. However, you will not be able to reject the Essential Cookies and still access the Platform, as they are strictly necessary to provide you with our products and services. In the event you choose to reject certain Cookies, you may still use our Platform though your access to some functionality and areas of our Platform may be restricted. You may also set or amend your web browser controls to accept or refuse Cookies.
11.4. We ensure to take certain physical and technical safeguards to protect your Personal data that we collect and maintain. However, please note and be aware that there are no security measures which are accurate and perfect or impenetrable.
11.5. Under certain circumstances we do not guarantee that Personal data of yours will not be accessed, disclosed, or amended or destroyed by breach of any of our physical and technical safeguards. If you choose to use our Platform from different jurisdictions/regions of the world with laws governing data collection, then please note that you are transferring your Personal data outside of those jurisdictions/regions for storage and processing purposes.
12. PRIVACY TERMS IN USING DIGITAL ASSETS AND BLOCKCHAIN
The digital assets and/or digital tokens are recorded on a public blockchain. It is a ledger which means a chain of blocks where each block contains the recording of any data transmission. Blockchains are decentralized or third-party networks that are not controlled or operated by any third-party partner service provider, affiliates or business partners of Horys, and Horys has no access or authority to erase, modify, or alter any personal data that could be available in such networks.
13. MODIFICATIONS
13.1. We reserve the right, at our sole discretion, to modify, amend, supplement or replace this Policy at any time and such update details shall be indicated at the top of this page.
13.2. The Platform Policies and Terms & Conditions may be revised or updated periodically to meet the necessary requirements and standards. We encourage Users to regularly visit the Platform to stay informed about any changes. Modifications will be effective on the day they are posted.
13.3. Continued access to the Platform means that Users agree to the updated content and to abide by the updated Policy.
14. CONTACT INFORMATION
In the event of any comments, questions, inquiries or complaints regarding this Policy, the User has the right to submit questions and/or concerns at
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