Privacy Notice
Last revised: 21, of April 2025
This is the Privacy Notice of Merv Capital Ltd, a BVI-based company (hereinafter – “Company”,
“we’, "us ","our"). This document together with our Terms of Use sets out the basis on which
any personal data we collect from you, or that you provide to us as a user of our services, will be
processed by us for provision of our services to you through our website and/or other applicable
software, including but not limited to Digital Securities Dashboard (hereinafter – the
“Dashboard”). The website can be accessed via the following link: http://merv.fi/ (hereinafter –
the “Website”).
Please read the following carefully to understand our views and practices regarding your
personal data and how we will treat it. By visiting our Website, you are accepting and consenting
to the practices described in this Privacy Notice.
We take the protection of our user's ("user/you/your") personal data very seriously and strictly
comply with applicable data protection laws and regulations. In this Privacy Notice below we
provide you with an overview of what data we collect for what purpose and how we ensure the
protection of such data.
1. Purpose and Legal Basis of Processing Data; Legitimate Interests
1.1. Legal basis for collection and processing of your personal data
We will only collect, use and/or pass on Personal Data if this is permitted by law or if the user
consents to the data processing.
Applicable legal provisions are in particular those of the regulation the General Data Protection
Regulation (EU) 2016/679.
1.2. Your data will be used for the following purposes:
1. to implement this Privacy Notice and carry out the contractual relationships between you and
us regarding our services available via the Website and/or our other software, including the
Dashboard;
2. to contact you in any matters regarding our services (also using emails and messaging), and to
ensure the technical functionality of our services and fulfillment of contractual or pre-contractual
obligations;
3. to prevent fraudulent behavior by any of our users;
4. to analyze your use of our services and improve our services;
5. with your express consent or instruction to carry out our business activities or send you
newsletters and other advertising materials;
6. to follow our internal policies and protect our legitimate interests;
7. to save your blockchain data on the distributed ledger;
8. to comply with our legal obligations before third parties involved in the process of provision
of our services;
9. to provide you with information about other goods and/or services we offer that are similar to
those that you have already purchased or enquired about;
10. to provide you, or permit selected third parties to provide you, with information about goods
or services we feel may interest you. If you are an existing customer, we will only contact you by
electronic means (e-mail) with information about goods and services similar to those which were
the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and
where we permit selected third parties to use your data, we (or they) will contact you by
electronic means only if you have consented to this. You have the right to request we not process
your data for direct marketing.
11. to notify you about changes to our services;
12. to ensure that content from our Website is presented most effectively for you and your
device;
13. for other purposes otherwise explained in this Privacy Notice or by any further
communication from us;
14. to comply with any applicable 'know your customer', anti-money laundering, or anti-terrorist
financing laws and regulations in any jurisdiction in which we operate;
15. for entering into contract and further performance of a contract with your party.
2. Your Consent
1. We can collect and process your data with your consent. By clicking the “I Agree” button on
any of our resources or using our Website, or other of our services you confirm that you fully
agree with this Privacy Notice and provide explicit and full consent to us for the collection,
processing, and transferring of your data.
2. We shall inform you upon your request for personal data of the purposes for which the
personal data is being or is to be collected and further processed, of any information available to
the data controller as to the source of that personal data, of the data subject’s right to request
access to and to request correction of the personal data and how to contact the data controller
with any inquiries or complaints in respect of the personal data, of the class of third parties to
whom the data controller discloses or may disclose the personal data, whether it is obligatory or
voluntary for the data subject to supply the personal data, and where it is obligatory for the data
subject to supply the personal data, the consequences for the data subject if he or she fails to
supply the personal data.
3. Where we process personal data with your consent, you may at any time withdraw your
consent. The withdrawal of consent shall not affect the lawfulness of processing based on
consent before its withdrawal.
3. Recipient(s) of Your Data
1. We, as well as our external service providers, receive your data for the provision of our
services. We may need to share your information with our external service providers, affiliates,
and/or agents.
2. We require that third-party organizations who handle or obtain personal information as service
providers acknowledge its confidentiality and undertake to respect an individual's right to
privacy and comply with data protection principles including this Privacy Notice.
4. Information We May Collect From You
4.1. We may collect and process the following data about you:
1. your name;
2. physical address;
3. e-mail address and phone number; Polygon Network wallet address, and other financial
information applicable for the provision of our services;
5. date of birth;
6. gender and nationality.
To obtain the above-mentioned information we may either ask you during your filling of any
forms (e.g. registration forms) to access our services. Or, we may ask you to provide us with
copies of respective documents by phone, e-mail, or otherwise. Such documents include but are
not limited to:
– passport;
– driver's license;
– transaction history;
– certificates.
4.2. Company may also gather data about you:
– When you engage with us on social media;
– When you enter prize draws or competitions;
– When you book any kind of appointment with us or book to attend an event;
– When you choose to complete any surveys we send you;
– When you comment on or review our products and services;
– When you've given a third-party permission to share with us the information they hold about
you;
– When Company suppliers and partners share information with us.
4.3. We may collect your data from publicly-available sources when you have given your
consent to share information or where the information is made public as a matter of law in
relation to KYC and AML regulations.
4.4. We may collect notes from our conversations with you, details of any complaints or
comments you make, details of investments you made, and how and when you contact us.
4.5. Concerning each of your visits to our Website we may automatically collect the following
information:
1. technical information, including the internet protocol (IP) address, used to connect your
computer to the internet;
2. browser type and version;
3. time zone setting;
4. browser plug-in types and versions;
5. operating system and platform;
6. information about your visit, including the full uniform resource locators (URL) clickstream
to, through, and from our Website (including date and time);
7. products you viewed or searched for;
8. page response times, download errors, length of visits to certain pages, page interaction
information (such as scrolling, clicks, and mouse-overs);
9. methods used to browse away from the page and any phone number used to call our customer
service number.
4.6. Information we receive from other sources.
We may receive information about you if you use any of the other websites we operate or the
other services we provide. We also work closely with third parties (including, for example,
business partners, sub-contractors in technical, payment, and delivery services, advertising
networks, analytics providers, search information providers, and credit reference agencies) and
may receive information about you from them.
5. Your Rights
5.1. You have the right to:
1. withdraw your consent relating to the use of your data at any time with effect for the future
when such data processing is based on your consent*;
2. object to the processing of your personal data, if your personal data is processed on the basis
of legitimate interests;
3. access the scope of data stored by us;
4. amend or rectify your data if such data is incorrect or outdated;
5. request the restriction of processing of your data;
6. request the erasure of your data**;
7. know the countries, other than the BVI which personal data will be transferred;
8. Know about the technical measures taken to protect data;
7. receive information about the stored data (in a structured, current, and machine-readable
format) at any time;
9. be informed (subject to applicable statutory limitations) of whether your data is being
processed by us or on our behalf and, if so, be informed of a description of:
(a) the personal data relating to you which is being or will be processed;
(b) the purposes for which the personal data is being or will be processed;
(c) the recipients or classes of recipients to whom personal data is or may be disclosed;
and
(d) any information available to us as to the source of the data.
* Please note that if you become our investor as described in the Dashboard Terms of Use and at
any point will decide not to use our services and/or products we are legally obliged to
nevertheless store your data related to you as our investor for maintenance of shareholder list.
** Please note, that your blockchain data stored on a distributed ledger is pseudonymized and in
any case, cannot be deleted by us due to the consequences for the integrity of the entire chain,
specifically, due to deletion of such chain containing transactions validation history of other
users.
5.2. To enforce your above-mentioned rights, you may reach us through the email address
included at the end of this document.
6. Deletion of Your Data
The data that we collect from you will be stored and processed for the period of time necessary
to provide you with our services and will be deleted, subject to any retention requirements
contained in any applicable law after there will be no need for its storage and processing. Please
note that when using our Website and/or any of our available services certain information and
data about the user will be stored on the blockchain in pseudonymized form and may not be
deleted. Deletion of your data can be agreed with the state authorities.
7. Disclosure of Your Data
7.1. We may share your personal data with any member of our group, which means our
subsidiaries, our ultimate holding company, and its subsidiaries as well as the above-mentioned
third-party service providers. We provide only the information they need to perform their
specific services. They may only use your data for the exact purposes we specify in our contract
with them. We work closely with them to ensure that your privacy is respected and protected at
all times. If we stop using their services, any of your data held by them will either be deleted or
rendered anonymous.
7.2. We may share your data with selected third parties including:
– business partners, suppliers, and sub-contractors for the performance of any contract we enter
into with them to render you our services;
– advertisers and advertising networks that require the data to select and serve relevant adverts to
you;
– analytics and search engine providers that assist us in the improvement and optimization of our
Website;
– credit reference agencies for the purpose of assessing your credit score where this is a condition
for us entering into any agreement with you regarding our services;
– in the event that we sell or buy any business or assets, in which case we may disclose your
personal data to the prospective seller or buyer of such business or assets;
– if Company or substantially all of its assets are acquired by a third party, in which case personal
data held by us about our customers/investors will be one of the transferred assets;
– if we are under a duty to disclose or share your personal data in order to comply with any legal
obligation, in order to enforce or apply any agreements between you and us, or to protect our or
your rights, property, or safety. This includes exchanging information with other companies and
organizations for fraud protection and credit risk reduction;
– we may, from time to time, expand, reduce or sell the Company, which may involve the
transfer of divisions or the whole business to new owners. If this happens, your personal data
will, where relevant, be transferred to the new owner or controlling party, under the terms of this
Privacy Notice.
8. Use of the Blockchain
When using our services, including Dashboard, certain information and data about the user will
be stored on the blockchain in pseudonymized form and may not be deleted because it is not
possible without deleting the entire chain.
Such data stored on the blockchain will only be in pseudonymized form, including the address
(public key) of the user of the relevant services, a flag that the user is verified, a flag stating that
the user is a sophisticated investor, a flag that the user has verified their bank account. In this
event and if such data is considered to be personal data, the data processing by us will be based
on our legitimate interest in using and providing this technology for our services in a functioning
way.
9. Sharing Your Data With Authorities
We will only do this in very specific circumstances, for example:
– for fraud management, we may share information about fraudulent or potentially fraudulent
activity in our premises or systems. This may include sharing data about individuals with law
enforcement bodies.
– we may also be required to disclose your personal data to the police or other enforcement,
regulatory or Government body, in your country of origin or elsewhere, upon a valid request to
do so. These requests are assessed on a case-by-case basis and take the privacy of our customers
into consideration.
10. Cookies
10.1. A cookie is a small file of letters and numbers that we store on your browser or the hard
drive of your device if you agree to accept them. Cookies contain information that is transferred
to your device's hard drive.
Our Website uses cookies to distinguish you from other users of our Website. This helps us to
provide you with a good experience when you browse our Website and also allows us to improve
our Website. By continuing to browse the Website and/or Dashboard you accept the utilization
of cookies.
10.2. We use the following cookies:
– strictly necessary cookies – which are required for the operation of our Website, including,
cookies that enable you to log into secure areas of our Website;
– analytical/performance cookies – allow us to recognize and count the number of visitors and see
how visitors move around our Website when they are using it. This helps us to improve the way
our Website works, for example, by ensuring that users are finding what they are looking for in
the possible easiest way;
– functionality cookies – are used to recognize you when you return to our Website, enabling us
to personalize our content for you, greet you by name, and remember your preferences (for
example, your choice of language or region);
– targeting cookies – record your visit to our Website, the pages you have visited, and the links
you have followed. We use this information to make our Website more relevant to your interests.
We may also share this information with third parties for this purpose.
10.3. Please note that third parties (including, for example, advertising networks and providers of
external services like web traffic analysis services) may also use cookies, over which we have no
control. These cookies are likely to be analytical/performance cookies or targeting cookies.
10.4. You can block cookies by activating the setting on your browser that allows you to refuse
the setting of all or some cookies. However, if you use your browser settings to block all cookies
(including essential cookies) you may not be able to access all or parts of our site.
11. Access to Information on Your Data
11.1. You have the right to information held about you, which can be accessed by emailing us to
the next email address contact@merv.fi
12. Changes to Our Privacy Notice
12.1. Any changes we may make to our Privacy Notice in the future will be posted on this page.
Please check back frequently to see any updates or changes to our Privacy Notice.
13. Contacts
13.1. Questions, comments, and requests regarding this Privacy Notice are welcomed and should
be addressed to the contact@merv.fi