Privacy & Data Policy Prop.com

The Privacy & Data Policy outlines how PC Holding UAB (hereafter referred to as Prop.com) handles and uses personal data across its digital platforms.

We take your privacy and data security seriously at Prop.com. This policy outlines our approach to collecting, using, and protecting any personal information that we may collect from you through our website, https://www.prop.com, applications, forms and other sites or systems that we own and operate. If you have any questions about this policy or your rights, please contact us.

Your right to data portability allows you to obtain and reuse your personal data upon request. We only collect personal information that is necessary to provide our services to you. We always collect data by fair and lawful means, with your knowledge and consent, and we explain why we’re collecting it and how it will be used.

We respect your right to be informed and only retain collected information for as long as necessary. We protect the data we store using commercially acceptable means to comply with data security regulations. Communication on our website, customer digital environment, and payment platforms are encrypted with SSL/TLS Certificates approved by the ISRG Policy Management Authority.

You have the right to request that we erase your data, which we will do unless we have a compelling reason to keep it. Our website may link to external sites that are not operated by us. We have no control over the content and practices of these sites, and cannot accept responsibility or liability for their respective privacy policies and data security. Always check if the connection is secured (depicted by a lock next to the URL), if not please contact us directly and do not share personal data on a non-secured website.

You have the right to refuse to provide us with your personal information, but this may limit our ability to provide some services to you. You also have the right to restrict the processing of your personal data, which may impact our ability to provide certain services. Prop.com does not use technology for automated decision-making and profiling, but if we do in the future, our privacy policy will be updated and you will be informed. Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information.

We respect your right to object to direct marketing from Prop.com. Therefore, we always provide plenty of unsubscribe options throughout our content and in personal emails. If you have any questions about how we handle user data and personal information or have suggestions for improvements, please contact us.

In summary, we collect personal information such as your name, address, telephone number, email address, IP address, internet browser and device type, payment details, and details about activities on our website for the purpose of providing our services to you. We obtain your consent to collect and use this information, and you have the right to withdraw your consent at any time. We do not share your personally identifying information with third parties, except as required by law or in the case of a contract breach. We take steps to protect your data and respect your rights under data protection laws.

Questions and Answers regarding Privacy and Data

SECTION 1 – PERSONAL DATA

Q1: What information do you process?

Your first and last name; address details;  telephone number; email address;  IP address for geo-location; internet browser and device type for website optimization; payment details (e.g. wallet ID, Transaction IDs, bank account or credit card number, receipts of cash transactions), details about activities on the website and web applications; other personal data that you actively provide, for example by creating a profile on this website, in correspondence and by telephone & proof of acquisition. Your personal data such as ID, proof of address, photo & IP (geolocation) is collected by our third party service provider Sumsub, and used to identify you (KYC process) and monitored ongoingly in our anti money laundering process (AML process).

SECTION 2 – CONSENT

Q2: How do you acquire consent to use my data?

When you provide us with personal information to complete a transaction, verify your credit card, place an order or acquire our services, we imply that you consent to our collecting it and using it for that specific reason only.

When you register for our investment platform, prop.com, and provide your phone number and email address while accepting our privacy policy, this action signifies your legitimate interest in our services. Based on this interest, our customer success department will proactively reach out to you via email and WhatsApp. This communication aims to assist with the onboarding and Know Your Customer (KYC) process, ensuring a smooth start on our platform.

We’ve designed our approach to respect your rights and freedoms, ensuring you can easily opt out of future communications at any time, maintaining the balance between your legitimate interests and your privacy.

Please note: when signing up for our services and Important customer updates regarding Prop.com or official notices are not classed as email marketing.

Q3: When do you ask for my consent specifically?

If we ask for your personal information for a secondary reason, such as marketing, we will ask you directly for your expressed consent, and provide you with an opportunity to opt out. Only with your permission, will we send you exclusive information and invitations to Prop.com’s events, offers, and other updates.

Q4: How do I withdraw my consent?

After you opt-in, if you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use, or disclosure of your information, at any time, by contacting us at data@prop.com or posting a letter to:

Data Officer, PC HOLDING UAB (Prop.com), Žalgirio av. 90, LT-09303, Vilnius, Lithuania.

SECTION 3 – DISCLOSURE

Q5: What information do you disclose with third parties, why, and when?

We don’t share any personally identifying information publicly or with third parties, except when required to by law or if you are in violation of our Terms & Conditions. If you would like to object to any processing where our lawful basis is legitimate please write a formal notice to data@prop.com.

In the case of a contract breach, when all reasonable efforts fail and no dialogue or solution is possible, Prop.com reserves the right to disclose necessary personal data with legal partners, collection agencies, and public authorities.

Furthermore, Prop.com has no intentions at all of unlawfully processing special or sensitive data, if you observe this it is unintentional and we request you kindly contact us at immediately data@prop.com, Prop.com commits to solving the issue with the highest priority.

SECTION 4 – THIRD PARTY SERVICES

Q6: Where is my data?

Third-party providers, we chose to use disclose your information to the extent necessary to allow them to perform the services they provide to us. We choose partners that are GDPR compliant and have a clear privacy policy. An overview of our key suppliers and privacy/security policies can be found in the link below.

INFRASTRUCTURE – Google Cloud Services, Google Workspace Business

SOFTWARE – Hubspot, Gmail, Google Sheets.

PARTNERS – KYC provider Sumsub, Our website is hosted by Google Cloud Services.

Q7: Are there other third-party service providers that use my personal data?

Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Q8: Can I prevent third-party service providers from using my personal data?

You can opt out of targeted advertising by:

Facebook – https://www.facebook.com/settings/?tab=ads

Google – https://www.google.com/settings/ads/anonymous

Bing – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.

SECTION 5 – SECURITY

Q9: How do you keep my personal data secure?

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed. Our servers are secured in the Google Cloud Platform. Gmail and G-Suite are used for communication, file transfer, and storage, APIs are used from trusted sources over encrypted connections and personal data is protected on robust servers with firewalls.

Prop.com user management is regulated with Hubspot CRM, G-Suite Identity, and Access Management.

Communication to our website, customer digital environment, and payment platforms are encrypted with SSL/TLS Certificates approved by the ISRG Policy Management Authority.

Any CRM database access, change, and deletion is logged for future auditing in Hubspot. Prop.com users work in Hubspot and G-suite which are cloud-based, eliminating the need for local files or personal data on laptops or other devices.

SECTION 6 – COOKIES

Q10: Do you use Cookies?

Some of our Site pages use “cookies” and other tracking technologies. A “cookie” is a small file that may be used, for example, to collect information about Site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a Site user. You may block cookies, or delete existing cookies, by adjusting the appropriate setting on your browser. Please consult the HELP menu of your browser to learn how to do this.

Q11: Will turning off cookies affect the functionality of the Site?

If you block or delete “cookies” you may find the usefulness of our Site to be impaired. Our website uses “Cookies” as data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

Please note that we do not alter our site’s data collection and use practices when we see a ‘Do Not Track’ signal from your browser.

Q12: Can I request my personal cookie information?

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us by mail at data@prop.com.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.

SECTION 7 – AGE OF CONSENT

Q13: How old do I have to be to provide consent?

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

The Site is not intended for or structured to attract children under the age of 18. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years of age.

SECTION 8 – CHANGES TO THIS PRIVACY POLICY

Q14: Can this policy be changed and how do I stay informed?

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our store is acquired or merged with another company, your information may be transferred to the new owners so that services will not be interrupted. In which case you will be notified in advance with the option to opt out.

SECTION 9 – RELATION TO OTHER DOCUMENTS

The Privacy Policy is part of the Terms and Conditions & Terms of Website Service.

Q15: What if I have more questions?

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or do you simply require more information? Contact our DPO at data@prop.com.