Privacy policy (As of October 2022 )

1. Information

shield crypto fund respects your privacy and is committed to protecting your personal data. This privacy policy (or policy) is issued on behalf of shield crypto fund, a company incorporated in portugal with its registered office address at alameda linhas torres 57, 3c, 1750-140 lisboa-portugal, portugal.
It is important that you read this policy together with any other policies we may issue regarding the collection and processing of personal data, so that you are fully aware of how and why we are using your data.
Our compliance and legal department (cld) is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact cld by using the details set out in section 9 below.

2. Purpose

the purpose of this policy is to inform you as to how we handle your personal data when you use our services, visit and use the functionality contained within our website (regardless of where you visit it from), to inform you about your privacy rights and how the law protects you. This website is not intended for children and we do not knowingly collect data relating to children.

3. Collection of your personal data

What information do we collect about you?
We may collect, use, store and transfer different kinds of personal data about you. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We have grouped together the personal data we may collect as follows:
identity data includes first name, middle names, last name, username or similar identifier, date of birth and gender.
Contact data includes physical address, email address and telephone numbers.
Financial data includes bank account information.
Transaction data includes details about payments to you and transactions you perform to your selected beneficiaries. This information includes the wallet address, amount, currency, type of transaction, source of funds, exchange rate, recipient name and bank details.
Technical data includes internet protocol (ip) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website.
Profile data includes your interests, preferences, feedback and survey responses.
Data imported by the user includes reputation or trade history.
Usage data includes information about how you use the website.
Aggregated data such as statistical or demographic data that is derived from your personal data but is not
considered personal data in law as this data will not directly or indirectly reveal your identity. We may aggregate your usage data (e. G. , information about how you use our website and related features) to calculate the percentage of users accessing a specific website feature. However, if 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 this policy.
Through the course of our business relationship, we may ask for additional evidence in order for us to comply with our legal obligations. These can include, but are not limited to, documents required to verify any information provided to us, or evidence of source of funds.
We do not collect any details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
How do we collect yourpersonal data?
We use different methods to collect data from and about you including through:
direct interactions you may give us your personal information by completing our onboarding process and providing supporting information and documentation for the purposes of helping us adhere to our compliance obligations, filling in forms or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you:
• Apply for our products or services;
• Request marketing to be sent to you;
• Give us some feedback.

Automated technologies or interactions where technical data about your equipment, browsing actions and patterns that we may automatically collect as you interact with our website, by using cookies and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources where we may receive personal data about you or technical data about you from parties such as google analytics based outside the eu.
Do you have to provide us with your personal data?
We require certain personal data to allow you to use our services and the website and where we need to collect personal data by law.
How do we use your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Register you as a new customer;
• to verify your identity;
• to provide you with our services;
• to make suggestions and recommendations to you
• about the goods or services that may be of interest to you;
• asking you to participate in a survey or provide
• feedback relating to the website or our services;
• sending out circulars, reminders, and any important notifications;
• sending marketing communications if you have
• requested information from us (or purchased is services from us);
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal or regulatory obligation;
• to improve our website.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Do you have to inform of us of any changes to your personal data?
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
When do we disclose your personal data?
Your personal data will be shared with the websites hosting provider, only as necessary to fulfill the website-related services. We partner with and are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfill the services they provide to us, such as website, software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and order fulfillment and delivery. When using our services, your personal data will be shared with our payment providers and banking partners for the purposes of performing the relevant transaction. When you transact with shield crypto fund, we may need to share your information with payment providers or banking providers, such as intermediary or beneficiary banks. For transparency, verification, and legal requirements, we are required to include certain information on the payment which could include:
• Your name;
• your date of birth;
• your address;
• beneficiary details;
• your identity document.

In the course of using our services, we may need to pass necessary information on to governmental departments, regulatory bodies, the police/law enforcement agencies or other third parties where we are legally compelled to do so.
Our employees and contractors are required to follow our data privacy and security policies when handling personal information.
We may partner with other organizations and as part of these arrangements, you may be a customer of our business partners in addition to shield crypto fund. You should review the privacy statements of our partners if you would like to know more about the information they collect.
Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will share personal information when we believe it is required, such as to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities.
When do we disclose your personal data?
Your personal data will be shared with the websites hosting provider, only as necessary to fulfill the website-related services. We partner with and are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfill the services they provide to us, such as website, software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and order fulfillment and delivery. When using our services, your personal data will be shared with our payment providers and banking partners for the purposes of performing the relevant transaction. When you transact with shield crypto fund, we may need to share your information with payment providers or banking providers, such as intermediary or beneficiary banks. For transparency, verification, and legal requirements, we are required to include certain information on the payment which could include:
• Your name;
• your date of birth;
• your address;
• beneficiary details;
• your identity document.

In the course of using our services, we may need to pass necessary information on to governmental departments, regulatory bodies, the police/law enforcement agencies or other third parties where we are legally compelled to do so.
Our employees and contractors are required to follow our data privacy and security policies when handling personal information.
We may partner with other organizations and as part of these arrangements, you may be a customer of our business partners in addition to shield crypto fund. You should review the privacy statements of our partners if you would like to know more about the information they collect.
Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will share personal information when we believe it is required, such as to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities.

4. Data Security

When do we disclose your personal data?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees and third parties who have a business need to know such information. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We store all data electronically in a secure manner to protect its confidentiality, integrity and availability. Data is stored on servers which are protected by actively maintained firewalls. We make use of up-to-date anti-virus software and our servers have restricted access.
We cannot guarantee the security of information collected or transmitted electronically however; we take reasonable care to safeguard your personal information. However, we have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5. Data retention

When do we disclose your personal data?
The personal data collected and processed by shield crypto fund will be kept for the entire period in which the registration of your user is on our website. You may, at any time, ask shield crypto fund to erase the personal data that you have transmitted. In
order to comply with certain legal obligations, shield crypto fund processes personal data for a longer period, such as the legal limitation period associated with the prevention of money laundering and terrorist financing, which is 7 years.

Your legal rights

Request access to your personal data (commonly known as a data subject access request)
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data we hold about you
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 you provide to us.
Request erasure of your personal data
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, subject to our legal and contractual obligations.
You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data
You can object to processing where we are relying on a legitimate interest (or that of a third party), but you feel such processing impacts your fundamental rights and freedoms. However, you can not object to the processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party.
Request restriction of processing of your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• if you want us to establish the datas accuracy;
• where our use of the data is unlawful, but you do not
• want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data, but we
• need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party
We will provide your personal data to you, or a third party you have chosen, in a structured, commonly used, machine-readable format.
Withdraw consent at any time where we are relying on consent to process your personal data
This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact cld.
What will you need from me if you wish to make a subject access request?
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Do i need to pay to access my personal data?
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
How long will it take to respond to my subject access request?
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

7. Reviews and amends to the policy

Our privacy policy is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment. Any personal information we hold will be governed by our most recent privacy policy. Shield crypto fund is entitled to the right to amend this policy whenever should be necessary. Everything an amendment takes place, the updated policy will be duly published in our public website.

8. Complaints

If you have a complaint about this policy or any element of how we use your personal data, then please contact us first. If you are not satisfied and are located in a eea country, then please contact your local data protection authority.
If you are based in, or the issue you would to complain about took place in the eea, please visit this website (https://edpb.europa.eu/aboutedpb/board/members_en) for a list of local data protection authorities in other eea countries.

9. Contact details

We have appointed a representative who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact our representative (as required pursuant to article 27 of the general data protection regulation 2016/679 of the european parliament) by using the following e-mail address: futures@shieldcryptofund.com

CLD:
legal@shieldcryptofund.com

Shield crypto fund representative:
futures@shieldcryptofund. Com