Privacy Policy

This Privacy Policy (“Privacy Policy”) provides for the security measures MANAVA CORPORATION (a company incorporated under the laws of the Republic of Seychelles as an International Business Company, registration No. 236130 on 20 December 2022) ("MANAVA", "we", "us", or "our") has implemented to protect and manage Personal data of Users of MANAVA Platform, Website and/or App, in accordance with applicable data privacy regulations and this Privacy Policy.

Your privacy is extremely important to us, and we make every effort to protect it. Privacy Policy explains how we use your Personal data.

All capitalized terms not otherwise defined elsewhere in Privacy Policy shall have the same meanings assigned to them in the Terms and Conditions

1. Definitions

The following terms has the meaning as defined below:

“App” means the Android / IOS mobile application software (with all updates, upgrades, versions etc.) developed, owned by us which allow you to access our Services, Products.

“MANAVA platform” means a Website-based and App-based digital platform established by MANAVA that provides numerous tools, features and enables users to engage, act within the platform functionality, and have access to Partners’ services. MANAVA platform is integrated with platforms of Partners’ services allowing users to enjoy Partners’ services.

“Partners’ services” means services of banking accounts opening, maintenance and closing, cards issue, processing the payments to and from the card account, other services provided by the banks, financial institutions; cryptocurrency / cryptocurrency, fiat exchange services; cryptocurrency custody services, cryptocurrency transfer services etc.

“Personal data” means data consisting of information which relates to a living individual who can be identified or identifiable from that information (or from that and other information in the possession of the data user), including any expression of opinion about the individual but not any indication of the intentions of the data user in respect of that individual. An identifiable individual is one who can be identified directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“User” means any person using our Website and/or App, Services or Products.
“Website” means https://manava.in.

“You”, “your” means you, if you are our User, or if a legal entity is our User, you acting as a representative, an owner, an ultimate beneficial owner, etc. of such legal entity, or you contacting us via digital methods of communication.

2. General Provisions

We offer MANAVA's services and products (“Services”, “Products”) as detailed in our Terms and Conditions

We only use Personal data for the purposes specified in Privacy Policy and to provide you or a legal entity - our User (where you act as a representative, an owner, an ultimate beneficial owner, etc.) with our Services, Products. We only transfer your Personal data to third parties if it is needed for Services, Products providing or required by law.

3. Personal data regime. Purpose of Personal data processing

We highly respect your privacy. Privacy Policy contains important information regarding processing, namely, collection, recording, organisation, structuring, storage, adaptation or amending, augmenting, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, deleting, re-arranging etc. of your Personal Data collected on Website, App or otherwise. We have developed Privacy Policy to assist you make an informed decision about whether or not to use Website, App.

We reserve our right to update Privacy Policy at any time. In the event of such an update, its new version will be allocated at Website, App. We shall not serve you with a relevant notification of such update and your or a legal entity - our User (where you act as a representative, or an owner, an ultimate beneficial owner, etc.) continued use of Website, App will be interpreted as your acceptance of the new version.

We process Personal data in scope being enough for the following purposes:

• Contractual Purpose. Enter into service, sale agreement, its performance and providing Services, Products to you or a legal entity - our User (where you act as a representative, an owner, an ultimate beneficial owner, etc.) (which may require disclosure to relevant third parties as defined by us), for proper access to and quality improvement of features of our Website, App;
• Analytical, operating, administration and advertising Purpose. To collect general and particular statistics of Website, App use, for sending communications, notices, advertisements, updates, surveys, other marketing purpose, for customer service support and ancillary purposes;
• Compliance purpose. If required by law and within the scope required by the law, to verify your Personal data for the purpose of managing customer relationships and performing Know your client rules, to comply with regulatory obligations related to Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and other laws.

We process Personal data only for purposes stipulated in Privacy Policy or those prescribed by the applicable law.

Legal basis for processing is:

• a consent which is given, as set forth in our Privacy Policy;
• performance of the agreement based on our Terms and Conditions to which you or a legal entity - our User (where you act as a representative, an owner or an ultimate beneficial owner, etc.) is party or taking steps as required prior to entering into the agreement based on our Terms and Conditions
• if required by law and within the scope required by the law, compliance with a legal obligation to which we are subject, including, but not limited to, AML and CFT requirements;
• protection of your or another person vital interests;
• another basis prescribed by the law.

By using our Services, Products or our Website, App by you or a legal entity - our User (where you act as a representative, an owner, an ultimate beneficial owner, etc.), you expressly agree with Privacy Policy and expressly consent to and agree with your Personal data processing as stipulated herein and by the applicable law.

4. Types of Personal data

We classify our Personal data into the following three types:

4.1. Directly collected Personal data

This refers to the information, which User directly provides us (e.g., by filling in Website forms).

4.2. Indirectly collected Personal data

This kind of information relates to User but he/she/it does not provide it directly (e.g., an IP address).

4.3. Automatically collected / generated Personal data

Our system collects this type of information automatically. Though such information isn't provided by User, it relates to you and is considered to be Personal Data. It has 2 subtypes:

• Static. This information doesn't usually change once it's created. For instance, an internal user id;
• Dynamic. This subtype changes based on the activities performed by you.

5. What Personal data do we collect ?

Your following Personal data could be collected for the purpose of Personal data processing as set forth above:

• Name and surname, date of birth, residing address, postal address, E-mail address, phone number, citizenship, Personal data collected from open source, information that you are or not politically exposed person;
• ID card, passport details or other identification document, your occupation, employment industry, financial standing, biometric identifiers and biometric information;
• Verification data (if required by law and within the scope required by the law): your photo, video made during verification, data which we collect for the purpose of conducting User due diligence under applicable AML and CFT law and regulations; confirmation that you are a representative, an owner, an ultimate beneficial owner etc. of a legal entity - our User, information on the ownership and control structure of User;
• Computer and connection information such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform, domain, host, IP address, the date and time you access our Website or App, the address of the website from which you linked to our Website when you visit us;
• Data from mobile devices (for example, location), unique IDs of your devices when you use Android and/or IOS mobile apps;
• Your behaviour, preferences, interests, favourites;
• Customer support data: communication between us and you (inquiries submitted via the website, email, social media or chat);
• Financial information: bank details, wallet details, bank card numbers other credentials of a card, information about completed transactions, transfers, transactions activity log, billing, payment details and other financial and settlement details obtained by us when you or a legal entity - our User (where you act as a representative, an owner, an ultimate beneficial owner, etc.) use our Services, Products.

This information is not exhaustive, and is laid out to give you an idea about use of fundamental collected information. We will record all information collected and purposes for which we process that Personal data.

6. Lawfulness of Processing and Disclosure

By using our Website, App, our Services, Products, you expressly agree with this Privacy Policy and expressly consent to and agree with your Personal data processing as stipulated herein. If your Personal data is provided by a legal entity - our User (where you act as a representative, an owner, an ultimate beneficial owner etc.), such User shall be responsible and be sure that it has received your consent for your Personal data transfer to us.

We take all reasonable means to ensure that your Personal data is treated securely and in compliance with this Privacy Policy, when we process your Personal data for one of the legal purposes specified in this Privacy Policy. We protect your Personal data under internationally recognized standards, employing physical, technological, and administrative security measures to minimise the risks of loss, misuse, unauthorized access, disclosure, and alteration. Firewalls and data encryption are among the measures we employ, as well as physical access controls to our data centers, and information access authorization controls.

We also limit access to Personal data only for those employees or contractors who require it to fulfil their job or service duties. Our employees, contractors are trained on procedures of Personal data processing, including limitations on the release of information. Access to Personal data is limited to those of our employees and contractors whose work needs it. We perform periodic evaluations to ensure that proper information processing policies and procedures are understood and followed. All of our physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations.

When you provide your Personal data over our Website, App, it is securely sent across the Internet using industry standard encryption. Your Personal data will be held encrypted on secure servers

7. Third Parties

We have taken steps to ensure that third parties engaged by us in processing your Personal data, have suitable technical and organizational measures in place to protect this Personal data, and we will also ensure that they are compliant with the law. We have taken steps to ensure that third parties engaged by us, protect the confidentiality and security of Personal data, and ensure that Personal data is processed only for purposes set forth above and in compliance with applicable law.

We may transfer your Personal data to third parties such as:

• legal and regulatory authorities to whom we are obligated to disclose your Personal Data under the law; agencies that deal with law enforcement; entities in cases of fraud or collusion prevention, identity verification, payment processing, credit reference, if required by law; courts;
• identification and verification service providers engaged by us for Users, your verification, performance of AML and CFT requirements, if required by law;
• server hosts, which store our data, communication service providers, which help us stay in touch with you;
• marketing, advertisement service providers;
• banking, financial service providers, helping us in Service, Products to you or legal entity - our User (where you act as a representative, an owner, an ultimate beneficial owner, etc.);
• providers and contractors/subcontractors, employees/contractors that may need information for provision of services to us;
• other third parties which services, facilities we use, in order to provide our Services, Products and deal with certain processes necessary for the operation of the Website, App, perform internal procedures and law requirements.

Each third party processing Personal data shall ensure that:

• engaged people processing the data are subject to a duty of confidentiality;
• it took appropriate measures to ensure the processing security;
• it shall provide reasonable assistance in providing access to a data subject;
• allowing data subjects to exercise their rights under Personal data protection laws;
• it deletes or returns all Personal data as requested;
• it submits to audits and inspections whatever information needed to ensure that it meets Personal data protection laws;
• it shall not process (or cause to be processed) any Personal data in a country that has not been recognized as providing an adequate level of data protection unless it has put in place such measures as are necessary to ensure such transfer is in compliance with Personal data protection laws, except where otherwise required by applicable law
• it shall notify as soon as possible if it becomes aware of any unauthorised or unlawful processing, loss of, damage to or destruction of Personal data;
• it takes appropriate technical and organisational measures against unauthorised or unlawful processing of Personal data or its accidental loss, destruction or damage etc.

We are obliged to disclose your Personal data in following cases:

• in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements;
• to protect, establish, or exercise our legal rights or defend against legal claims, including to collect a debt; to comply with a subpoena, court order, legal process, or other legal requirement;
• when we believe in good faith that such disclosure is required to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of Terms and Conditions;
• to third parties in case of: merger, restructuring, joint venture, assignment, sale part of the business or the whole business.

8. Privacy when using cryptocurrencies and blockchain

Your cryptocurrencies may be recorded on a public blockchain. Public blockchains are distributed ledgers, designed to record transactions over wide networks of computer systems in an immutable manner. Many blockchains are open to forensic analysis, which can result in deanonymization and the unintended disclosure of private financial information, particularly when blockchain data is paired with other data.

We are not able to erase, modify, or alter Personal data from such networks, because blockchains are decentralised or third-party networks which are not controlled or operated by us.

9. Where do we store Personal data?

Personal data collected about our Users, you, will be stored on the server in the country that has not been recognized as providing an adequate level of data protection unless it has put in place such measures as are necessary to ensure such transfer is in compliance with Personal data protection laws, except where otherwise required by applicable law. To ensure the security and privacy of your Personal data, we take measures designed to protect that information from loss, misuse, unauthorized access, disclosure, alteration or destruction.

10. How long do we store Personal data?

We store Personal data within the term of its processing by us, third parties engaged by us for Services, Products providing, and additionally 5 years after cession of Service, Products providing, unless longer term is required by the applicable law.

11. Notifications

In case of Personal data breach, we shall notify the supervisory competent authority without undue delay after becoming aware of it, unless Personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

If we become aware of a security breach, we may seek to notify you electronically so that you can take appropriate preventive measures. If a security breach occurs, we may make a notice on Website, in App.

When Personal data breach is anticipated to result in a high risk to Users’, your rights and freedoms, we will inform you.

If we are acquired or merged with a third-party entity, we reserve the right to transfer or assign the data we have collected from our Users as part of such merger, acquisition, sale, or other change of control. If we become involved in a merger, acquisition, or any form of sale of some or all our assets, we will notify Users, you before Personal data is transferred and become subject to a different privacy policy.

We may not be able to control how your Personal data is treated, transferred, or used in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights in general.

12. Your Rights

12.1. Obtain confirmation

You have the right to request confirmation that Personal data pertaining to you is being processed.

12.2. Access Personal data

You have the right to access such data, or ask us to provide a copy of your Personal Data processed by us.

12.3. Request of information

You have the right to request the following additional information concerning your Personal data:

• the purposes of the processing;
• the categories of Personal data concerned;
• the recipient(s) or category(ies) of recipient to whom/which Personal data have been or will be disclosed;
• the criteria determining the period for which Personal data will be stored etc.

12.4. Request rectification

You have the right to rectify Personal data in case the data is incorrect or incomplete.

12.5. The right to be forgotten

You have the right to revoke previously provided consent and have the Personal data erased from our system. In this case, third parties will no longer have access to your Personal data.

However, it does not mean that your data will be erased immediately; it will still be stored at our facility in order to comply with numerous statutory obligations, specifically a provision of the regulations, under which we could store any collected information for a period of 5 years from relations termination. Your Personal data will be erased from our records after this period has elapsed.

12.6. Restrict processing

If the accuracy of Personal data is contested by you, you have the right to acquire processing limitations for a period enabling us to verify the accuracy of Personal Data.

12.7. Receive Personal data

You have the right to receive Personal data concerning you provided to us, in a structured, commonly used and machine-readable format. We are obliged and have provided all the information which you have right to receive. This Privacy Policy concludes all the information and is available to you on our Website at any point of time.

12.8. Have Personal data transmitted

You have the right to have Personal data transmitted directly from one controller to another, where technically feasible.

12.9. Object

You have the right to object, on grounds relating to your particular situation, where there is a reason to believe that we have no lawful grounds for processing Personal data, at any time to processing of Personal data concerning her or him.

12.10. Complaint

You have the right to file complaints regarding processing of your Personal data. You have the right to lodge a complaint with the respective supervisory authority.

13. Communications

Throughout our cooperation, you will receive information messages from us, and could send messages to us via Telegram bot @manava_support.

14. Implementation of changes

Our Privacy Policy is reviewed on a regular basis to ensure that any new obligations and technologies, as well as any changes to our business operations and practices, are taken into account, as well as that it remains abreast of the changing regulatory environment. Any Personal data we store will be subject to our most recent Privacy Policy.

If we decide to update our Privacy Policy, we will post those changes here and other places we deem necessary.

15. Conclusion

Please acknowledge, by implementing some rights given by law (erasure, stop processing), you will be deprived of some features of the Website, App, and in some cases, where applicable, we may be forced to close your account at the Website, App. Despite the rights exercised by you, we anyway could proceed with your Personal data processing, if required by law.

We are committed to protecting the privacy of Personal data and make every effort to disclose the processing details clear and simple to understand.

Should you have any questions concerning the information above, please, don't hesitate to contact us as set forth above.

Should we lawfully receive your Personal data from a third party, you will have the same rights regarding information in question as related to information you provided to us directly or we have collected during cooperation with you.

If you have a reasonable belief that we are violating our obligations to protect your privacy, you have a right to lodge a complaint with a relevant supervisory authority.