Anahit Website Privacy Policy

Anahit is committed to respecting and protecting your privacy. This Privacy Policy governs the manner in which we collect, use, maintain, and disclose Personal Information collected when you visit this website at: https://www.anahit.com/  (or any successor website), and any desktop, subpages, and mobile versions, including all content, materials, features, applications, functionality, products, and services, made available on this website or other platforms (“the Site”).

This Privacy Policy also applies when you interact with us offline. For example, this Privacy Policy applies if you provide your contact information to us and our ongoing dealings with you as a client, investor, borrower, vendor, lender, or sponsor.

PERSONAL INFORMATION

“Personal Information” – or “personal data” in other jurisdictions like the European Union (“EU”) – means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household. We do not consider Personal Information to include information that has been aggregated or de-identified so that it does not allow a third party to reasonably identify a specific individual.

ACCEPTANCE

Please read this Privacy Policy carefully so that you understand our privacy practices. By providing Personal Information to us or by using the Site, you acknowledge that you agree to be bound and abide by Privacy Policy and the Terms of Service, and you are consenting to the collection, use, and disclosure of that information in accordance with this Privacy Policy.

PART OF THE TERMS OF SERVICE

This Privacy Policy forms part of our Terms of Service at:  https://www.anahit.com/terms-conditions/. 

Any capitalized, but undefined terms in this Privacy Policy have the meaning given to them in the Terms of Service.

CHANGES IN OUR PRIVACY POLICY

We may change this Privacy Policy from time to time, and we may provide you with additional notice through one or more of our channels. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices.  Any changes will become effective when the revised Privacy Policy is posted on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy.

1.  PERSONAL INFORMATION WE COLLECT

The information we collect falls into two categories: (1) information you voluntarily provide us when you visit our Site, or otherwise interact with us both online and offline, and submit your information, including via email, telephone, a Site contact form, as part of the transaction, and through other documents and correspondence; and (2) tracking information gathered as you visit our Site.

PERSONAL INFORMATION YOU PROVIDE

The types of Personal Data we collect and share depends on the product or service you have with us and the nature of our relationship with you. We may collect your Personal Information in various ways including by telephone, the Site, from documents or correspondence, and by email. Wherever practicable, we will collect information about you from you personally.

In order to provide our products and services, including establishing and administering any investment or loan, providing general financial advice and providing information about our products and services, and to comply with relevant legislation, in the past twelve months we may have collected Personal Information concerning you in the categories below we may have collected the following information:

1. Identifiers (e.g., real name, alias, postal address, email address, social security number, driver’s license number, passport number, other government ID, signature, telephone number, spouse’s name, financial information including tax-related information/codes and account details, information used for monitoring and background checks to comply with laws and regulations, including ‘know your client’, anti-money laundering, and sanctions checks, and other contact information);
2. Sensitive/protected characteristic information (e.g., age/date of birth, nationality, citizenship, country of residence, gender, race, and other information used to comply with laws and regulations);
3. Commercial information (e.g., assets, income, transaction and investment history, accounts at other institutions, information concerning the source of funds and any applicable restrictions on your investment such as political exposure or sanctions);
4. Professional or employment-related information (e.g., current or past job history, education, personal references);
5. Inferences drawn from other Personal Information (e.g., profiles reflecting preferences, characteristics, predispositions, behavior, aptitude, and trends, based on information such as assets, investment experience, risk tolerance, investment activity, and transaction history).

It may be necessary at times to collect some of the Personal Information listed above about you from other external sources, such as:

1. A financial adviser, lawyer, broker;
2. Authorized representatives, such as executors or administrators;
3. Credit check providers;
4. Publicly available registries; and
5. Identification verification service providers

We may combine Personal Information that you provide to us with Personal Information that we collect from, or about you from other sources, in some circumstances. This will include Personal Information collected in an online or offline context.

You may use the Site as a guest and are not required to register or create an account in order to use it to explore our content.  However, not all functionality may be available to you as a user or account holder on the Site.

PASSIVE INFORMATION COLLECTION

We may use analytics tools, including third-party services such as Google Analytics, to help us measure traffic, usage, and sales trends by your use of our Site. These tools use various technologies, including cookies or similar technologies, to collect certain information sent by your devices to the Site, including:

1. Your browser name,
2. The pages you visit on the Site,
3. Whether you have previously accessed the Site,
4. The IP (Internet Protocol) address for your computer
5. The type of computer and technical information about your means of connection to our Site, such as the operating system and the Internet service providers utilized, and
6. Navigational Data, also known as log files, server logs or clickstream data.

We conduct the passive collection of the above information in a variety of ways, including:

1. Through your browser or device. Certain information is collected by most browsers or automatically through your devices, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer, and model, language, and Internet browser type and version. We use this information to ensure that the Site and its services function properly.
2. Through your use of the Site. When you visit the Site, we may track and collect the usage data, including but not limited to the date and time your device accessed the Site.
3. Using cookies. Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and other traffic data of the Site. We use the information for security purposes, to facilitate navigation and display information more effectively. We can recognize your computer to assist your use of the Site.
4. If you do not want information collected through the use of cookies, you may choose to set your web browser to refuse cookies or to alert you when cookies are being sent.  However, if you do not accept these cookies, you may experience some inconveniences in your use of the Site and some parts of the Site may not function properly.
5. Using tracking technologies. We may use tracking technologies to track you across third-party websites. We do not currently respond to “do not track” signals or other mechanisms that might enable users to opt-out of tracking on the Site.
6. Using pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Site to, among other things, track the actions of users of the Site to improve the Site and its associated services.
7. Using your IP Address. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever you access the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We may use IP Addresses for purposes such as calculating usage levels of the Site, helping diagnose server problems, and administering the Site and its associated services. We may block certain IP addresses if they attempt to access the administrative portions of the site without authorization.
8. If you connect to us from a social network, such as LinkedIn or Facebook, we will collect personal data from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list, job title, and any other information you have agreed it can share or that the social network provides to us.

2.  HOW WE USE INFORMATION

We use information about you for various purposes, including:

1. To provide the services you request, including managing your investments or loans, administering investment- and lending-related activities, conducting transactions, and sending you related information, including any confirmations and receipts;
2. To manage and administer customer services, including but not limited to the administration of your customer account.
3. To communicate with you about Anahit, including our events, news, and information we think will be of interest to you.
4. To protect the security of and manage access to our premises, IT and communication systems, online platforms, websites, and other systems, preventing and detecting security threats, fraud, or other criminal or malicious activities
5. For insurance purposes, as necessary
6. For our recruitment, when you apply for a position with us
7. To comply with our legal and regulatory obligations such as to enforce our Terms of Use, for financial and credit checks, audit requirements, fraud, and crime prevention and detection, and record keeping. This may include automated checks of Personal Information you or your organization provide about your identity against relevant databases, and contacting you to confirm your identity, or making records of our communications with you for compliance purposes
8. Fulfill any other purposes related and/or ancillary to any of the above, or any other purposes for which your Personal Information was provided to us, consistent with the commitments made in this Privacy Policy

From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

3.  HOW WE SHARE INFORMATION

We do not sell, trade, or rent your Personal Information to others.

We may share the categories of Personal Information described above with service providers and third parties that we partner with to assist us in various functions, including providing technical support and performing security and anti-fraud services, providing you with our services and products, and providing you with communications and marketing information on our behalf. These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your Personal Information for any other purpose.

These service providers and third parties can be classified in the following categories:

1. Financial service providers, which we rely on in part to manage your investment or loan, administer investment- and loan-related activities.
2. Marketing service providers, which we use to send you promotional communications, for instance;
3. Tax authorities, in order to comply with applicable laws and regulations and where required or as requested by tax authorities in the territory in which you are located;
4. Event planners, which we use to organize and manage events and event-related services, including registering your attendance and the processing of your credit card data with respect to event-related expenses.
5. Financing counterparties, in order to assess such counterparties with regulatory checks and sourcing credit for fund-related entities in the course of our transactions and fund life cycles;
6. IT service providers, such as our data hosting provider and companies we employ to deliver and facilitate the services needed to support our business relationship with you, manage our Site, to provide Site-related services and/or to assist us in analyzing how our Site is used; or
7. Other service providers that we may engage to provide services to us or on our behalf.

Your Personal Information may be disclosed to a third party if we are required to do so because of applicable law, court order, or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding. Your Personal Information may be disclosed to a third party if the disclosure is reasonably related to the potential or actual sale or other disposition of all or part of our business or assets.

We may share aggregated or de-identified information with third-party partners, affiliates, or service providers for the purposes outlined above.

We may use third-party services such as Google Analytics to collect, monitor, and analyse the information as described above. These third-party service providers have their own privacy policies addressing how they use such information. To opt-out of Google Analytics on the Site go to https://tools.google.com/dlpage/gaoptout.

4.  INFORMATION RETENTION

Your Personal Information will be retained in accordance with our data retention policy, which identifies the types of records held by Anahit, and specifies the appropriate retention period for each record type. Those periods are determined by the purpose for which the information is collected and used, taking into account applicable data protection laws, legal, and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, and Anahit’ business requirements.

5.  HOW WE PROTECT YOUR INFORMATION

We take the protection of our users’ Personal Information very seriously We seek to use commercially reasonable data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your Personal Information under our control, in accordance with this Privacy Policy. However, the Internet is not 100% secure or error-free. We cannot guarantee that your use of our Site will be completely safe, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.  We encourage you to use caution when using the Internet.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an email to you. You may have a legal right to receive this notice in writing. If you have any questions or concerns, please notify us.

The safety and security of your information also depend on you. Where you have chosen an account password for access to certain features of the Site, you are responsible for keeping this password confidential. We ask that you not share your password with anyone and encourage you not to use the same password on the Site as you use on other websites.

6.  CHILDREN AND PRIVACY

We do not knowingly permit children under age 13 (in the United States) without adult supervision as described in our Terms of Service or age 16 (in the European Economic Area (EEA) to register and/or to create an account for any content, product, or service.  We will not knowingly collect, use, or disclose personally identifiable information about people under age 13 (in the United States) or age 16 (in the EEA), except as permitted by law. If we learn that we have collected any Personal Information from anyone under age 13 (in the United States) or age 16 (in the EEA), we will promptly take steps to delete such information.

If you believe that we might have any information collected from an individual under age 13 (in the United States) or age 16 (in the EEA), please contact us.

7.  CONTACT US

If you have questions about this policy, you can contact us using the contact form.