1. Applicability

This Privacy Policy applies to the website of Utrust available at www.utrust.com, but does not apply to any third party websites that may be linked to our websites, which will be governed by their own privacy policies.

2. Controller

MODERNlTYPARTY OÜ, a company duly incorporated under the laws of Estonia, bearing company registration number 14831182, with registered address at Harju maakond, Tallinn, Kesklinna linnaosa, Maakri tn 25, 10145 (hereinafter “Utrust”, “Service Provider”, “us”, “we”, or “our”), is responsible for the collection of personal data via our site www.utrust.com (“our site”).

Our data privacy officer may be contacted at [email protected].

3. General information

The terms “We”, “Us”,” Our” mean Utrust. The terms “You” and “Your” refer to You, as a user or visitor of our website provided Services. The term “personal data” refers to all information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person 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 one or more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person, as set out the GDPR. In addition, personal data comprises data of legal persons.

4. Collection of data

You may give Us information about You by submitting information on Our site or by corresponding with Us by email or otherwise. This includes information You provide when You register to use Our Site, subscribe to Our Site services, participate in discussion boards or other social media functions on Our Site, and when You report a problem with Our Site. The information You give Us may include your name, address, email address, phone number, personal description or photograph. Any processing of your personal data is based on a legal basis which is indicated below.

We collect and use the following data from you:

Information you provide to us.

  1. Collection of information takes place whenever you:
  • Fill out forms and/or enquiries;
  • Contact us through our communication channels;
  • Register/open an account.
  1. The following will be collected:
  • Name, domicile address, country, tax information, date of birth;
  • Contact details (e.g. email address, phone number)
  • Username;
  • Responses to the enquiries;
  • Information and documents about your funds, sources of income and other financial information;
  • Your identification documents and all documents you have provided to us;
  • Your image in a photo or video selfie as part of your registration process;
  • Information about other people related to you or to any of the corresponding funds.

Information resulting from your use of our products and services.

The following is collected:

  • Technical and device information;
  • Information about your visit to our website or our products/services (e.g. response time, errors, page interaction);
  • Details on your transactions;
  • Location.

Information from other sources.

This might include:

  • Third parties, such as official registers, financial institutions, partners, and sanctions lists;
  • Financial records and information to help us verify your identity;
  • Social media or other publicly available information;
  • Online directories, and websites to do verification checks.


5. Purpose of processing and legal basis

Any processing of data requires a legal basis. If the processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures taken at the request of the data subject, the processing may be based on Art. 6, para. 1, b) of the GDPR.

If the processing is necessary to safeguard the legitimate interests of the data controller or a third party, provided that the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, do not prevail, it can be based on Art. 6, para. 1, d) of the GDPR.

We process your data for the following purposes:

  • to fulfil our obligation to make the services available to you in accordance with the service conditions concluded between you and us: the legal basis for data processing is Art. 6, para. 1, c) and f) of the GDPR;
  • to inform you about changes to our services: the legal basis for data processing is Art. 6, para. 1, e) of the GDPR.
  • to ensure that the content of our website is presented on your computer as efficiently as possible: the legal basis for data processing is Art. 6, para. 1, c) or d) or f) of the GDPR.
  • in order to enable you to participate in test and trial offers of our services: the legal basis for data processing is Art. 6, para. 1, f) of the GDPR.
  • to inform you about parts of the services which we believe to be of interest to you if you have given your consent: the legal basis for data processing is Art. 6, para. 1, a) of the GDPR;
  • as part of our efforts to offer you the greatest possible security when using our service ad website: the legal basis for data processing is Art. 6, para. 1, d) or f) of the GDPR;
  • to resolve operational issues and improve our services: the legal basis for data processing is Art. 6, para. 1, f) of the GDPR;

We also process data that cannot be assigned to any person. These are data that do not personally identify you, including anonymous information and aggregated data. This information helps us better understand how our visitors use the Services, analyze demographics, interests and behaviors of our visitors, improve the Services, provide customized services and information to visitors, and similar purposes.

6. Feedback

If You contact Us to provide feedback, register a complaint, or ask a question, We will record any Personal Information and other content that You provide in Your communication so that We can effectively respond to Your communication. We reserve the right to use this information in any manner permitted by law, to respond to Your communication. The processing of your personal data for feedback processing is based on Art. 6, para. 1, d) or f) of the GDPR.

7. Activity

When You use the Services, We receive and store certain information which may include Your Personal Information, regarding Your use of the Services. Examples include IP addresses, browser types, domain names, and other statistical data regarding Your use of the Services. We may use this data in a way that does not disclose any of Your personally identifiable information, including, but not limited to, for purposes of developing new product and service offerings.

8. Cookies and tracking technologies

We use cookies and similar tracking technologies to track the activity on our Service and to customize our Services and content; measure promotional effectiveness and promote safety. They enable the website and other services to remember your actions and preferences over a period of time, so you won’t have to re-enter them every time you access any of the services. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. Enabling these cookies is strictly necessary for the Website and other services to work, as it will provide you with a better browsing experience. You can delete or control these cookies; however, this will impair some of the features of our services.

We may use the following cookies:

  • Session Cookies. We use Session Cookies to operate our Service. We collect session data because it helps us administer our services, track correlative information and to collate statistics in relation to visitor traffic. We may use your IP address to help us diagnose problems with our server. Therefore, these cookies are necessary to enhance the performance and functionality of our Website.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Third-party persistent cookies by Google Analytics – Google Analytics uses cookies to collect statistical information. These help us to measure how users interact with our services by collecting information on clicks, time spent on a page, the frequency a User visits it, what browser a visitor to the Website is using, and so on. Statistics and analytical data are very useful tools for us to provide a better and more engaging product for our users and to make our business predictions more accurate. The cookie set by Google Analytics which will identify you as a unique user on the Website can only be used by Google. For further information please visit the Terms of Service and the Privacy Policy​. You have the option to stop Google Analytics from recognizing you when return to our Website by disabling cookies on your browser.
  • We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
  • We use Segment to monitor the performance of our services and to enhance your experience; to understand user behaviour in order to provide you with a more relevant experience;  to personalize and measure the effectiveness of advertising; to make our services to work as intended.

9. Disclosure of information

We may disclose Your Personal Information for the following reasons:

  • Legal obligation – In response to a request for information if we believe such disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation. The legal basis for processing to fulfil a legal obligation is Art. 6, para. 1, c) of the GDPR.
  • Violation of Terms of Services – If we believe your actions are in violation of Our Terms, or to protect the rights, property and safety of Us or others. In this case, the transfer is based on Art. 6, para. 1, c) or f) of the GDPR.

10. Retention period

We store your personal data for as long as is necessary for the purpose for which it was collected or for fulfilling our legal obligations, such as statutory retention periods. The data will be deleted at the latest within one month after the respective purpose no longer applies.

11. Your rights

The security of your data is very important to us. Utrust aims to take reasonable steps to protect your rights regarding the personal information that we collect and process about you.

If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances and without prejudice of complying with our legal obligations, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Utrust relied on your consent to process your personal information.
  • Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.

12. Links to other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

13. Security

We take commercially reasonable steps to protect Your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We use up to date TLS-encryption that your systems support when transmitting data via Our systems. However, We cannot guarantee that all Internet or email transmission is fully secure or error free and except for Our guarantee to use commercially reasonable and up to date measures to technically secure any data transmission, We cannot guarantee their absolute security and We therefore cannot be held liable for intercepted information sent via the Internet or for third parties using revoked, stolen, forged, or otherwise insecure certificates. You should therefore take special care in deciding what information You send to Us via email and keep this in mind when disclosing any Personal Information to Us or to any other party via the Internet.

14. Changes to this Privacy Policy

We are free to change this privacy policy at any time. The new version will always be posted on this website. These changes will be effective immediately for new users of our services and will become effective for existing users through continued use of the services after the effective date of the posted change. If you do not wish to approve the changes to our use of your personal information, you must notify us before such changes take effect that you wish to deactivate your account with us. Please note that you are always responsible for keeping your personal information up to date and providing us with your current contact information.

15. Commitment

We take the responsibility to protect the security and privacy of our users seriously. We have established effective policies that define our commitment to data security and the information technology we manage. We are continually reviewing policies and procedures to assure that they are appropriate and effective in meeting our commitments to our community, our users, customers and ourselves. Any suspicious attempt to breach our terms and policies, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. All suspicious computer mischief will be reported to the appropriate authorities.

16. Communication

If You have any questions relating to these Policy, Your rights and obligations arising from these Terms and/or Your use of the site and the services, or any other matter, please contact [email protected]