This privacy policy (“Policy”) specifies the main conditions of the processing of the personal data of the visitors, newsletter subscribers, clients, their representatives, beneficiaries of the internet website www.assethill.com of Asset Hill, UAB (“Asset Hill” or “we”, as well as the persons having submitted enforcement measures and candidates to the work positions offered by Asset Hill ("You").
The controller of your personal data is:
Legal entity code
306748270
Registered office address
Sporto g. 12-114, Vilnius, LT-09238, Lithuania
In processing your data, Asset Hill is also guided by, inter alia, the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, other applicable legislation and instructions and recommendations of supervisory authorities.
Any updates to this Policy, if any, shall always be published on the Asset Hill website.
If you have any questions regarding the protection of your personal data or this Policy, please contact us at info@assethill.com.
1. Processing of personal data for the purpose of providing the services of the management company
1.1 Asset Hill processes the data of its clients, their representatives and website visitors for the purpose of providing the services of a management company. In providing management company services, Asset Hill is governed by the Law on Collective Investment Undertakings for Informed Investors of the Republic of Lithuania and other applicable legislation, as well as by the agreements concluded with clients (or persons guaranteeing obligations).
1.2 Please also note that in order to properly provide the services of a management company, Asset Hill also processes your personal data for the following related purposes:
1.2.1. to comply with anti-money laundering and anti-terrorist financing requirements (as set out in applicable legislation and Asset Hill's internal policies);
1.2.2. to comply with other requirements applicable to Asset Hill's activities (as provided for in applicable law).
1.3 Asset Hill processes the following personal data of clients (their representatives) for the following purposes:
1.3.1. data confirming personal identity (name, surname, personal identification number, image, nationality, etc.);
1.3.2. contact data (residential address, email address, telephone number, etc.);
1.3.3. data about the relationship of the data subject with legal entities (position in the undertaking, data about the participation of the person in the control of legal entities, etc.);
1.3.4. data used by the Client to login in the account in the website of the Asset Hill (the user ID of the client, password, etc.);
1.3.5. financial data (personal credit rating, financial liabilities, income, property, loans, information about transactions made on the Asset Hill platform, their extent, etc.);
1.3.6. details of the client's investment knowledge and experience;
1.3.7. other data which is necessary for providing the services of Asset Hill.
1.4 Asset Hill receives the above-mentioned personal data necessary for providing the management company's services directly from you (when you provide it) or from other resources (e.g. state database, such as administered systems by the state enterprise Centre of Registers, etc.).
1.5 The above-mentioned personal data is stored for 10 years from the completion of the transaction, submitting a certain application or the completion of the operation, except for the cases when legislation specifies longer terms of storing such data.
2. Processing of personal data for the purpose of administering your enquiries
2.1.If you contact Asset Hill (by email, telephone, social media accounts or any other means), the personal data you have provided will be processed for the purpose of administering the relevant enquiries in order to, inter alia, ensure the quality of the services provided and, where necessary, to comply with various legal requirements and to protect the interests of Asset Hill.
2.2 The processing of the data referred to is normally based on Asset Hill's legitimate interest. In some cases, the administration of queries or complaints submitted by you may be based on compliance with legal requirements.
2.3 When making enquiries, please observe at least the minimum requirements for the protection of personal information - do not provide superfluous personal data that are not necessary for the purpose of the enquiry, complaint, letter or request.
2.4 The personal data you provide will normally be retained for up to 3 years, unless a different retention period is necessary for reasons such as the protection of the rights and legitimate interests of Asset Hill or others, the investigation of a complaint or the resolution of a dispute. The retention period may also vary according to legal requirements and therefore your personal data may be retained for a longer period.
3. Processing of personal data for direct marketing purposes
3.1 The Asset Hill website provides you with the opportunity to subscribe to email newsletters about the latest projects published on the website, as well as news related to Asset Hill's activities. We may also contact you via social platforms, telephone, letter or other alternative means to inform you about our services and investment opportunities.
3.2 In the above-indicated cases, Asset Hill processes your personal data for the purpose of direct marketing on the basis of your consent.
3.3 The period of storing of this personal data is 3 years from the day of receiving your consent, unless such consent is cancelled until the end of the indicated term of storing.
3.4 InRento, in accordance with the provisions of the Law on Electronic Communications of the Republic of Lithuania, may also process the data of existing clients (email address) for the purpose of direct marketing on the basis of the legitimate interest of the company.
3.5 You have the right to unsubscribe from Asset Hill's newsletters at any time by clicking on the link at the bottom of the newsletter or by contacting us in writing (by email to info@assethill.com.
3.6 Asset Hill may also carry out profiling of your personal data for marketing purposes in order to provide you with more tailored, specific and relevant offers or solutions. You may withdraw or object to the processing of your personal data by automated means, including profiling, at any time. You can object to the processing by automated means, including profiling, or to the use of purely automated processing, including profiling (without giving reasons for objecting) by contacting us at info@assethill.com.
4. Processing of personal data of staff candidates
4.1 Asset Hill processes your personal data (CV, cover letter, etc.) when you provide the relevant information when applying for a position offered by Asset Hill. The processing of your relevant personal data is based on your consent, which is expressed by providing the relevant data.
4.2 The period of retention of the data you provide will depend on the duration of the selection process conducted by Asset Hill for a particular position. Asset Hill will only process your personal data after the end of the respective selection process if you express your separate consent to this.
4.3 If you submit your CV, cover letter or other personal data to Asset Hill on your own initiative, where we have not advertised any competition, your relevant data may be stored and used for the purposes of subsequent recruitment exercises for up to 1 year. InRento also has the right to receive your CV data from recruitment service providers and job search portals if you have provided such data to them.
4.4 When sending your personal data to Asset Hill for the purpose of ongoing or future selections, please observe at least the minimum data protection requirements and do not provide superfluous information that is not relevant to your candidature.
5. Cookies used on the website
5.1 When you visit our website www.inrento.lt, we may use cookies and/or other similar technological solutions to process your IP address and other network data that you provide.
5.2 Cookies are small files (data files) that are sent to the web browser you use and stored on your device (computer, phone, etc.). They allow our website to "remember" your actions, preferences, transactions and other actions performed on our website. Cookies are transferred to your computer during your first visit to our website.
5.3 Our website uses the following cookies:
5.4 You can find more useful information about cookies, how to control them and how to delete them on the website www.allaboutcookies.org.
6. Recipients of personal data
6.1 In the course of its activities, Asset Hill may use certain data processors (service providers, such as data storage service providers, software development and support companies, online analytics companies, communication service providers, etc.) to which your personal data may be transferred. Your personal data will only be transferred to the relevant service providers when and to the extent necessary for the provision of their respective services.
6.2.When providing management company services, Asset Hill may transfer certain of your personal data to other data recipients, such as the Bank of Lithuania, accounting firms, auditors, depositories, etc.
6.3 In the course of providing its services, Asset Hill may transfer certain personal data of its clients (their representatives and/or beneficiaries) to companies controlled by collective investment undertakings managed by Asset Hill (special purpose vehicles), provided that it is reasonably necessary for the purposes set out in this Policy (e.g. for the purposes of opening bank accounts, etc.).
6.4 Asset Hill shall ensure that the processors (special purpose entities) of the personal data that you have provided to them follow (where applicable under the law) the instructions and instructions for the processing of your personal data and implement appropriate organisational and technical measures to protect personal data against accidental or unlawful destruction, alteration or any other unlawful processing.
6.5 For the purpose of prevention of money laundering and terrorist financing, in accordance with the procedures, cases and on the grounds set out in the Law, the personal data of Asset Hill's clients, their representatives and (or) beneficiaries may be passed on to the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania, to other law enforcement organisations and to financial institutions operating in the EEA and outside the EU, In any case, Asset Hill shall make reasonable efforts to ensure that, in order to comply with the Law, the personal data of its clients, their representatives and/or beneficiaries are not lost or used unlawfully.
6.6.The consents given by you for the processing of your personal data shall be stored by Asset Hill for the minimum storage period set by the Chief Archivist of Lithuania (1 year after the expiry of the storage period of the personal data for the processing of which the consent was given).
7. Your rights as a data subject
7.1 You, as data subjects, have the following rights with regard to your personal data:
7.1.1. To get acquainted with your personal data and the way it is processed;
7.1.2. require to correct incorrect, inexact or non-detailed data;
7.1.3. To require to delete your personal data;
7.1.4. to require to restrict the processing of your personal data;
7.1.5. to require to transfer your personal data to another processor or submit directly at your convenience;
7.1.6. not agree with processing your personal data, if it is processed on the grounds of legal interest;
7.1.7. to cancel given consent for processing your personal data.
7.2 To exercise your rights as a data subject, please contact us in writing (by email to info@assethill.com): please specify the specific right, the scope of the exercise of the right and your contact details (e.g. name, surname, email address - where you have registered on our platform, telephone number). If we lack sufficient information to be able to properly analyse your request, we will contact you immediately. Please note that we exercise your rights as a data subject in accordance with the General Data Protection Regulation and other legislation on the protection of personal data, as well as the guidelines of competent authorities.
7.3 If you believe that Asset Hill is processing your personal data unlawfully or in violation of your rights related to the processing of personal data, you have the right to contact the State Data Protection Inspectorate. However, before contacting the State Data Protection Inspectorate, we encourage you to first contact us immediately (by email to info@assethill.com). In this way, we will be able to work together to find the most expeditious and optimal solution to the problem for both parties.
