Privacy Policy

Last updated: 23 November 2023

We at Bakksy Finance OÜ, a company, registered under the laws of the Republic of Estonia with registration number 16575205 and registered address at Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 3 // 5 // 7, 10145 ("Bakksy", "we", "our"), are committed to protecting the privacy of our users of our forthcoming product.

This Privacy Policy applies to all personal data we collect when you sign up for our waitlist and giveaway and shall be considered an essential part of our Terms & Conditions.

References to "you" or "user" under the Privacy Policy refer to the individual who has joined the waitlist and giveaway for our forthcoming product launch, and provided personal information such as email and phone number and for whom the Privacy Policy applies. This includes, but is not limited to, individuals who have joined the waitlist and giveaway, become a part of the Bakksy community, received a Bakksy community card, or received a referral link to share with others.

Data Collection
1. The data we collect from you when you join our waitlist and giveaway may include: browsing history, general geographic location information, media files uploaded or accessed through our mobile application, information related to user interaction with products or services offered through our mobile application, technical information about the user’s device, operating system, and mobile application performance, additional data related to user’s interaction and usage of our mobile application, user-generated content such as comments, reviews, or messages, payment info, data related to credit card transactions and fraud prevention measures, additional financial information necessary for processing payments or providing financial services, information about user’s past purchases through our mobile application, user’s physical address, specific geographic location information with the user’s consent, email address, additional contact information provided by the user for communication, advertising data, phone number, contacts (address book), performance data, crash data, customer support, emails or text messages, device ID, any other data types necessary for the operation and improvement of our mobile application, user ID, information about user’s search queries within the application, name and nickname.
2. The purpose of collecting this information is to keep you informed about the development and launch of our product and to provide you with a campaign designed for early adopters, to provide and improve the services and features of the application, to personalize user experience and tailor content to user preferences, to process payments and transactions, to communicate with users and provide customer support, to analyze and report on application usage and performance, to send promotional or marketing communications with user consent, and to comply with legal obligations or respond to legal requests.
3. When you grant our app permission to access the contacts on your mobile device, we do not store or retain any of the contact information or data. We only utilize this permission to enable certain app features that require contacting people from your contact list, such as sending messages to selected contacts via our in-app interface. At no point do we save or cache contact details accessed from your device. We do not create any internal records or copies of your contacts. The contact data is only accessed temporarily and for the sole purpose of completing the specific action that requires contact access, such as composing a message. Once that action is finished, we immediately delete any contact information obtained from your device from our servers and systems.
4. Any profile picture uploaded by a user to their account will be uploaded and stored on our servers. In the event that the associated user account is deleted, we will delete any stored profile pictures of that user account from our servers as well.
5. Certain functionalities available in our app allow users to download digital stickers and the member cards onto their mobile devices. To enable these download features, users will be asked to grant us access to their device's photos, thereby allowing them to locally save the aforementioned files. We do not access any other photos or data on user devices beyond what is needed to facilitate the downloads.
6. By providing us with your email address, name and phone number, you are giving us permission to send you updates and promotions related to our product.
Participation in Customer Development Interviews
1. As part of the giveaway contest, one of the tasks may involve participating in Bakksy Customer Development (CustDev). During this task, you will have the opportunity to meet with the team of Bakksy and participate in an interview concerning various topics, such as app user experience, your interest in our forthcoming brokerage investment application service, your financial goals in terms of investing, your previous investing experience, and other reasonable questions that are relevant to customer development for our upcoming investing brokerage application.
2. To facilitate these interviews, we may utilize communication services such as Google Meet, Zoom, or others. As part of this task, you will be requested to provide your name and email through the Calendly service for the purpose of scheduling the meeting.
3. The interviews will be kept strictly confidential. Only subject to your consent we may record the interview for internal use only. Your answers and information provided will be used solely for the purpose of customer development for our upcoming brokerage application, and will not be shared with any third parties. During the interview you will be free to decline to answer any questions or end the interview at any time. Your participation in the interview is voluntary. Following completion of the interview, you will receive coins that contribute to your standing on the leaderboard for the contest or giveaway. Higher coins increase your chances of winning a prize.
Data Processing
1. Your personal data will be processed in accordance with the General Data Protection Regulation (GDPR) as well as applicable Estonian data protection laws, such as the Personal Data Protection Act (Isikuandmete kaitse seadus) and the Electronic Communications Act (Elektroonilise side seadus).
2. The purpose of processing your personal data is to fulfill the specific purpose of providing you with updates and promotions related to our product. We will only process your personal data for the specific purposes for which it was collected and in accordance with this Privacy Policy.
3. The processing of your personal data will be based on your consent, which you provide by joining our waitlist. We take the responsibility of processing your personal data seriously and will only use it in ways that are compatible with the purposes for which it was collected.
Data Retention
1. We will retain your personal data for as long as necessary to fulfill the purpose for which it was collected, as outlined in this Privacy Policy. This means that we will retain your personal data for the duration of our relationship and for a reasonable time thereafter in case of any legal claims.
2. When we no longer need your personal data, we will securely delete it or anonymize it so that it can no longer be associated with you. If you would like your personal data to be deleted earlier, you may request this by contacting us at [email protected]. We will consider your request and respond to you in accordance with applicable law.
3. Please note that there may be certain legal requirements that prevent us from immediately deleting your personal data. In these cases, we will securely store your personal data and restrict its processing until the relevant retention period has expired.
Data Security
1. We take the security of your personal data seriously and have implemented appropriate technical and organizational measures to protect it against unauthorized or unlawful processing, accidental loss, destruction or damage.
2. Your personal data will be stored on servers located in Warsaw, Poland, which are protected by industry-standard security measures. We will also implement appropriate measures to ensure that any third-party service providers we work with also implement appropriate security measures to protect your personal data. We have implemented strict measures to ensure the secure handling and storage of all user data collected through our web platform and mobile applications for waitlist, including email addresses, names, and phone numbers.
3. Access to user data is restricted to authorized personnel on a need-to-know basis who are bound by strict confidentiality agreements. We also require any third-party vendors or service providers that may handle user data on our behalf to adhere to our stringent security protocols and privacy standards.
4. In the unlikely event of a data breach, we will notify you and the relevant supervisory authority without undue delay and take steps to mitigate the consequences of the breach.
Your Rights
1. Under the GDPR, you have several rights in relation to your personal data that we process. These rights include:
  1. the right to access your personal data that we hold about you, including the purposes for which it is processed and the categories of personal data concerned.
  2. the right to have any inaccurate or incomplete personal data we hold about you rectified.
  3. the right to have your personal data erased in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected or when you withdraw your consent.
  4. the right to restrict the processing of your personal data in certain circumstances, such as where you dispute the accuracy of the data.
  5. the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller.
  6. the right to object to the processing of your personal data for certain purposes, such as direct marketing.
  7. the right to lodge a complaint with a supervisory authority if you believe that we have violated any of your rights under the GDPR.
  8. If you would like to exercise any of these rights, please contact us at [email protected]. We will respond to your request in a timely manner and in accordance with applicable law.
Data Sharing
1. We will not share your personal data with any third parties except as required by law or as necessary to fulfill the purposes for which it was collected. If we need to share your personal data with a third party, we will ensure that appropriate technical and organizational measures are in place to protect your personal data.
2. The circumstances of sharing your data with third parties to fulfill the purposes for which it was collected including sharing your data:
  1. with third-party service providers who perform services on our behalf, such as hosting and maintaining our servers, sending promotional materials, and providing customer support; these service providers are contractually obligated to protect the confidentiality and security of your personal data and are only permitted to use it for the purposes for which it was shared;
  2. with our affiliates for the purposes of providing you with information and promotions related to our product; our affiliates are required to comply with this Privacy Policy and applicable data protection laws;
  3. under the disclosure obligation we may have in relation to your personal data if we are required to do so by law or if we believe in good faith that such disclosure is necessary to comply with legal proceedings, to respond to claims, or to protect the rights, property, or safety of us, our customers, or the public;
  4. in the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, we may transfer your personal data to the acquiring entity; the acquiring entity will be required to comply with this Privacy Policy and applicable data protection laws.
  5. We will not sell, rent, or otherwise make your personal data commercially available to third parties without your prior consent, except as set out in this Privacy Policy.
  6. If we transfer your personal data to a third party in a country outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place to protect your personal data in accordance with applicable law.
Contact Information and Complaints
1. If you have any questions or concerns about this Privacy Policy or the processing of your personal data, please contact us at [email protected]. We will make every effort to address your concerns in a timely and satisfactory manner.
2. If you believe that your rights under the GDPR have been violated, you have the right to file a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).
Changes
1. We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. We will notify you of any material changes by posting the updated Privacy Policy on our website and, if required by law, by obtaining your consent.
Governing Law
1. This Privacy Policy and the processing of personal data shall be governed by and construed in accordance with the General Data Protection Regulation (GDPR) of the European Union and applicable data protection laws of the Republic of Estonia.
Dispute Resolution
1. Any disputes arising in connection with this Privacy Policy or the processing of personal data, if not settled via negotiations, shall be subject to the exclusive jurisdiction of the Arbitration Court of the Estonian Chamber of Commerce and Industry (ECCI) in accordance with its rules. The arbitral tribunal shall be composed of a sole arbitrator. The seat of arbitration shall be Tallinn, Estonia. The language of the arbitral proceedings shall be English.
2. In the event of a dispute arising from or relating to this Privacy Policy, the prevailing party shall be entitled to recover its reasonable attorneys' fees and arbitration proceedings costs, as well as all other expenses incurred in connection with the dispute, from the non-prevailing party.
Acceptance
1. By joining our waitlist and giveaway, you acknowledge that you have read and understand this Privacy Policy and that you agree to the collection, processing, retention, and sharing of your personal data as described in this Privacy Policy.
Account deletion
1. If you wish to delete your account and all the associated data, you can do so by utilizing the designated "Delete Account" button within our application. By clicking this button, you confirm your intention to permanently delete your account and understand that all user data and personal information linked to the account will be permanently removed, except as otherwise required by applicable law or as outlined in this Policy.
2. In the event of the complete deletion of an account, we shall retain the user's email address internally for our records, ensuring that they are not regarded as a new user in the event of being re-invited under the referral program and points are not credited to the referrer again. The email address of a user who has deleted their account will not be used for any marketing activities, will not be shared with any third parties, and will only be retained internally until the completion of the current promotion/giveaway program. Once the promotion/giveaway program ends, the email address will be permanently deleted from our systems with no copy or record retained. The email address will solely be used for our internal records for the purpose of accurate administration of the referral program and preventing duplicate referrals.