I.  Privacy Policy

Within the scope of this Privacy Policy, and for the comfort of the reader, the following words should be interpreted as follows:

Rycatea® = means    J&C Victorius Partners Limited

Rycatea® is committed to the principles of personal data protection laid down in European law and recognizes the importance of safeguarding its customers’ information. We are constantly improving our data processing activities and our privacy notices in order to provide you with as much transparency over the way we handle your data as we can. This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of Rycatea® Online store.

If you have concerns about how we use your personal information, you can contact us using the Contact Us form on our Online store or even by email at info@victoriuspartners.com

If you are unsure about the meaning of any term used in this Privacy Policy (such as “Rycatea® Account”), you may check the definition in the other legal documents regulating the Rycatea® Online store Terms of Service & Conditions & Refund Policy to all of which this Privacy Policy is inseparable part.

This Privacy Policy also applies to the information that is collected and used in relation to Rycatea® Online Store pursuant to the Terms of Service & Conditions & Refund Policy of Use of Rycatea® Online Store.

1.1.  About us.

When this policy mentions “we,” “us,” or “our,” it refers to Rycatea®, who is responsible for your information under this Privacy Policy. The specific responsible entity for your personal data may vary for the different services provided though the Rycatea® Online Store. The responsible entity in each case is referred to as the “Data Controller”.

1.2.  The Rycatea® Online Store.

For the purposes of this document Rycatea® Online Store consist of products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us or mobile apps, online platform, official social media platforms, or other online services.

Rycatea® Online Store is designed for business purposes and may be used by individuals or entities. In case you are registering for and/or using Rycatea® Online Store on behalf of an entity we will treat you as authorized person and you may be obliged to disclose to us personal data of the legal representatives, the employees, the agents, the beneficial owners or any other third-party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person beside yourself you have received prior consent from that other person to provide their personal information to us.

Тhe present Privacy Policy grants rights which only natural persons, related in any way to a Rycatea® client, may benefit from. Whenever we use “you”, “your” or similar, the persons which we refer to are the natural persons which are involved in any way with the information of the Rycatea® Client, which may be the representatives, the beneficial owners, the authorized persons or other similar and in case the Rycatea® Client is a sole trader or similar.

II.  Process of your personal information

2.1. Information processed about you

You are informed that there are two general categories of information that is collected from you differentiated on grounds as defined by the Regulation 2016/679 and other applicable data protection national laws.

1. Information which we collect when you use our Online Store
   
2. Information that we collect for other purposes, such as operating our Rycatea® Online Store or providing you with any of our linked services.

III.  Information that we process when you use our Online Store.

IV.  Specific data sharing.

In any case, we may share any of your information for specific reasons, outlined below:

1. With other members of the Rycatea® corporate family and partners: We may share your Personal Data with members of the Rycatea® Group of companies or within the extended family of companies that are related by common ownership or control, so that we may provide you with goods or services you have requested or authorized.
2. With our distributors: We may share information related to you or your company with our distributors/fulfillment centers, which help us to provide you with the best Rycatea® experience. Our distributors/fulfillment centers may help us in onboarding you or your company, with your transactions, Rycatea® terminal orders and other similar activities, for which they may process some of your personal information.
3. Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. With our legal counsels for the purposes of protecting our legal rights. We may share any information which is necessary to protect our legal rights to legal counsels or similar parties.
5. Monitoring. We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes. When visiting our offices, CCTV, access control systems and/or other monitoring systems may be in operation.
6. Business Transfers. If any of the companies that provides Rycatea® goods and services is involved in any merger, acquisition, reorganization, sale of assets, transfer of portfolio, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred to a different legal person and/or becomes subject to a different privacy policy.

V.  Decisions based solely on automated processing.

Sometimes, our systems may take decisions based solely on automated processing. This does not mean that we will always use automated decision making for these processing activities. In case you believe that you have been unfairly treated by our automated decision-making systems you may ask that a person reviews the decision at all times by contacting us via our Contact Us form. Such decisions may be done for processing activities that include:

VI.    Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information to provide Rycatea® Online Store to you, you can request that we erase your personal information and close your Rycatea® Account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevent us by law to close your account or terminate the Service. In case the Data Controller is a regulated financial institution, such as credit institution, E- money institution or similar, such Data Controller might be obliged by law to keep your personal information and all transactions history for a period of 5 years after the termination of the relation with you (or where the laws of the United Kingdom of Great Britain and Northern Ireland are applicable – for a period of 6 years). Please note that if you request the erasure of your personal information:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing security. For example, if we suspend a Rycatea® Account for fraud or safety reasons, we may retain certain information from that Rycatea® Account to prevent that client from opening a new Rycatea® Account in the future. We are also obliged to retain personal data which we have collected for the purposes of complying with the relevant anti- money laundering and anti-terrorism financing for a period as defined under the applicable law.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Rycatea® may keep some of your information for tax, legal reporting and auditing obligations.

Because we maintain our records in a manner protecting from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

VII.    Your rights.

You may exercise any of your rights within the scope of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)