PRIVACY POLICY

This privacy policy applies between you, the User of this Website and Mikro Kapital HK Limited, the owner and provider of this Website. Mikro Kapital HK Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: https://plantago.capital/terms-and-conditions.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data

collectively all information that you submit to via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Cookies

a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Data Protection Laws

any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in Luxembourg;

GDPR

the General Data Protection Regulation (EU) 2016/679;

Mikro Kapital HK Limited, we or us

Mikro Kapital HK Limited, a company incorporated in Hong Kong with registered number 2596600 whose registered office is at Hong Kong, Room 20 Suite 2802 Admiralty Centre Tower 1, 18 Harcourt Road HK;

UK and EU Cookie Law

the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you

any third party that accesses the Website and is not either (i) employed by and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to and accessing the Website in connection with the provision of such services; and

Website

the website that you are currently using, https://plantago.capital, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:

Scope of this privacy policy

3. This privacy policy applies only to the actions of and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Mikro Kapital HK Limited is the "data controller". This means that Mikro Kapital HK Limited determines the purposes for which, and the manner in which, your Data is processed.

Children Under the Age of 18

4. Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, submit any financing applications or materials through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at support@plantago.capital.

Data collected

5. We may require you to provide us with your (1) last name, first name, other names or patronymic (if specified in the ID-card), (2) date, month and year of birth, (3) place of birth, (4) individual identification number if applicable, (5) the issuing authority, the date of issue and validity period, the series and number of the ID-card (or its substitute), (6) information about the registration address at the place of residence, (7) driver's license data (issuing authority, issuance date and validity period, series and number of the driver's license, category driver's license, (8) contact details, including but not limited to mobile phone number, e-mail address, (9) photography, (10) data on the place of work and position held, (11) geolocation data (14) IP address (automatically collected) (15) web browser type and version (automatically collected) (16) a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected) (17) any other personal data related or which may be created in connection with the conclusion and performance of a contract to which you are party. The information that we request will be retained by us and used as described in this Privacy Policy.

How we collect Data

6. We collect Data in the following ways:

Data that is given to us by you

7. Mikro Kapital HK Limited will collect your Data in a number of ways, for example:

in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you access the Website, we will collect your Data automatically, for example:

Our use of Data

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

10. We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you.

11. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

12. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:

13. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

14. We may use your Data to show you adverts and other content on other websites. If you do not want us to use your data to show you adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).

Who we share Data with

15. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

16. We may disclose personal information that we collect or you provide as described in this privacy policy:

Keeping Data secure

17. We will use technical and organisational measures to safeguard your Data, for example:

18. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: support@plantago.capital.

19. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

20. We store and process your personal data only as long as needed for the respective purpose. Moreover, data is stored and processed only if required for another purpose, such as to comply with legal requirements (such as retention obligations under tax or commercial laws). In this case, we limit further data processing to this purpose and the legal basis of further processing. Legal basis for the processing of data is performed on the following legal bases: Data processing for contract fulfillment: Article 6 Section1 b) GDPR. Data processing based on your consent: Article 6 Section1 a) GDPR. Data processing for the pursuit of legitimate interests: Article 6 Section1 f) GDPR. Data processing for compliance with legal requirements: Article 6 Section1 c) GDPR Storage by providers in third-party countries "Appropriate safeguards" as defined by Art. 46 GDPR when using service providers as set forth in the section "Recipients of personal data" are provided by standard data protection clauses as approved or adopted by the European Commission, binding corporate rules, or similar instruments. Rights of data subjects: As a data subject affected by data processing, you have the right to information (Art. 15 GDPR), rectification (Art. 16 GDPR), data erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and data portability (Art. 20 GDPR). Right to object For reasons relating to your particular situation, you have the right to file an objection at any time to processing of your personal data based on Art. 6 Section 1 e) GDPR (data processing in the public interest) or Art. 6 Section 1 f) GDPR (data processing based on a consideration of interests). If you file an objection, we will continue to process your personal data only if we can document mandatory, legitimate reasons that outweigh your interests, rights and freedoms, or if processing is for the assertion, exercise or defense of legal claims. To exercise your right of objection send us an email to support@plantago.capital.

Your rights

21. You have the following rights in relation to your Data:

22. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: support@plantago.capital.

23. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority.

24. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Transfers outside the European Economic Area

25. Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

26. We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, eg by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.

27. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to other websites

28. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

29. Mikro Kapital HK Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of . Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

30. We may also disclose Data to a prospective purchaser of our business or any part of it.

31. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Fraud prevention and identification check

32. Mikro Kapital HK Limited checks your personal customer data against sanction lists and compliance lists within the framework of legal requirements and within its own legitimate interests. For fraud prevention purposes, Mikro Kapital HK Limited carries out an identity check which is done by our service provider Sum and Substance Limited, incorporated and registered in England with company number 09688671, whose registered office is at 80 Wood Ln Central Working White City London W12 0BZ, as part of a manual reconciliation process. If you decide to validate your ID card via our Website, the images you have taken of your driving license/ID card and the portrait picture you have taken yourself will be collected and processed for the purposes of validating your driving license/ID card. The driving license data/ID card are read out electronically from the pictures of your driving license/ID card you have taken, and the pictures of your face are compared with the driving license/ID card pictures (face match). These images are stored as permanent proof of driving license/ID card control. These image files are verified by our service provider Sum and Substance Limited, incorporated and registered in England with company number 09688671, whose registered office is at 80 Wood Ln Central Working White City London W12 0BZ, as part of a manual reconciliation process.

More information of third parties involvement

33. Mikro Kapital HK Limited uses external IT service providers who provide server infrastructure, IT maintenance tasks or extensive IT solutions (such as cloud services) and software solutions on behalf of Mikro Kapital HK Limited. Mikro Kapital HK Limited uses external service providers for invoice archiving purposes. Governmental authorities, courts, external advisors, and similar third parties that are public bodies or other authorized third parties, provided that the facts described above are present (e.g. administrative offences or a legal obligation to provide information or account suspension due to unauthorized use). For the organization of marketing activities and promotions, personal customer data are partly transferred to service providers used for these purposes. Mikro Kapital HK Limited uses external service providers for market research purposes. Mikro Kapital HK Limited transfers your personal data to shipping companies if processing is required for communication by post. Mikro Kapital HK Limited uses external service providers to provide our customer service. For this purpose, personal customer data is transferred to these service providers. Mikro Kapital HK Limited processes your data in countries where the EU Commission has established an adequate level of data protection. In the following cases, processing takes place in countries where the EU Commission has not established an adequate level of data protection. We have ensured an adequate level of data protection by providing for appropriate safeguards, in particular, by entering into agreements with the recipients of personal data based on so called EU standard contractual clauses issued by the European Commission pursuant to Art. 46 para. 2 GDPR.

Cookies

34. This Website may place and access certain Cookies on your computer. Mikro Kapital HK Limited uses Cookies to improve your experience of using the Website and to improve our range of services. Mikro Kapital HK Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

35. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

36. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

37. The technologies we use for this automatic data collection may include:

We do not collect personal Information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

38. As you navigate through and interact with our Website, we may automatically collect certain information about your equipment, browsing actions and patterns, including:

38. The information we collect automatically is statistical data, and does not identify any individual. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

39. This Website may place the following Cookies:

40. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

41. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

42. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

43. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

44 Third-party Advertiser Use of Cookies and Other Tracking Technologies

Some advertisements on the Website are served by third-party advertisers, ad networks and ad servers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about our users. This may include information about users’ behavior on this and other websites to serve them interested-based (behavioral) advertising. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.

General

45. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

46. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

47. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

48. This Agreement will be governed by and interpreted according to the law of Luxembourg. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Luxembourg courts.

Changes to this privacy policy

49. Mikro Kapital HK Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact by email at support@plantago.capital.

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