NEOETF Management Partner S.à r.l. (hereinafter referred to as the "Company", "we", "us", "our") does not collect or use information that can identify an individual ("personal data") when using the Company's products, services, mobile and software applications and websites by the user"), with the exception of an e-mail address, the provision of which is not mandatory. Each User is important to the Company, therefore, the protection of your personal data is very important to us, and we understand our responsibility to ensure the safety of personal data and compliance with the requirements of the legislation of the Grand Duchy of Luxembourg.

This Privacy Policy (hereinafter referred to as the Policy) applies to all information that the Company and / or its affiliates may receive about the user, client, (hereinafter referred to as the user) while using the website, services, programs and products of the Company (hereinafter referred to as - Services). The user's consent to provide personal information, given by him/her in accordance with this Policy applies to all persons using the Company's services.

The Policy describes the procedure established by the Company for processing personal data collected via an Internet resource: (hereinafter referred to as - website) and (or) the H2K mobile application, and related services and tools. In all these cases, the Company processes personal data of users exclusively within the framework of the requirements of the Luxembourg Law of August 2, 2002, on the protection of personal data (Loi du 2 août 2002 relative à la protection des personnes à l'égard du traitement des données à caractère personnel), and international treaties ratified by Luxembourg. This Privacy Policy has been developed in accordance with their standards.


1.1. For the purposes of this Policy, “personal information” means:
1) Personal information that the user provides about himself / herself on his / her own when registering or in the process of using the Services, including the user's personal data. At the same time, the Company does not establish requirements for the provision of any personal information by the user.
2) Other information about the user, if its collection and / or provision is provided for in other internal documents of the Company, agreements, contracts.
3) This Policy applies only to the Company Services. The Company does not control and is not responsible for the websites of third parties, to which the user can follow the links available on the Company's website. On such sites, other personal information may be collected or requested from the user, and other actions may also be performed.
1.2. The Company and its Services do not automatically collect data, including IP address, information about the user's browser (or other program that accesses the Services), access time, or otherwise.
1.3. The Company does not verify the accuracy of personal information provided by users and does not exercise control over their legal capacity. However, the Company assumes that the user provides reliable and sufficient personal information on the questions proposed in the registration form and maintains this information up to date. The risk of providing false information is borne by the user who provided it.


2.1. The Company may collect and store only information about the email address.
2.2. The Company may use the information specified in clause 2.1 of this Policy for the following purposes:
1) Identification of a party under agreements and contracts with the Company;
2) Providing the user with personalized Services;
3) Communication with the user, including sending notifications, requests and information regarding the use of the Services, the provision of services, as well as processing requests and applications from the user;
4) Improving the quality of the Services, the convenience of their use, the development of new Services;
5) Conducting statistical and other research based on depersonalized data.
2.3. If the user visits the site or uses the Company's services, we do not use so-called cookies. The use of the Company's services does not imply the need to use such technologies. Interaction is ensured by issuing a key pair to the user, providing the user with access to the Company's services.



3.1. The personal information of the user is kept confidential, except in cases where the user voluntarily provides information about himself / herself for public access to an unlimited number of persons.
3.2. The Company has the right to transfer the personal information of the user to third parties in the following cases:
1) The User has given his / her consent to such actions;
2) The Company does not transfer the user's personal information to third parties in any case.


4.1. The user can at any time change (update, supplement) or delete the personal information provided by him / her or part of it by sending a request to change, update or delete personal information or part of it using the feedback form on the Company's website.
4.2. The user cannot withdraw consent to the collection, processing of personal data in cases where this is contrary to the laws of the Grand Duchy of Luxembourg, or in the presence of an unfulfilled obligation.
4.3. Rights of users in connection with the processing of their personal data by the Company:
✓ to know that the Company, as well as a third party, has their personal data, as well as receive information containing: confirmation of the fact, purpose, sources, methods of collecting and processing personal data; list of personal data; terms of processing personal data, including the terms of their storage;
✓ to require the Company to change and supplement their personal data if there are grounds, confirmed by relevant documents;
✓ to demand from the Company, as well as a third party, the destruction of their personal data, the collection and processing of which was carried out in violation of the legislation of the Grand Duchy of Luxembourg, as well as in other cases established by the regulatory legal acts of the Grand Duchy of Luxembourg;
✓ to withdraw consent to the collection and processing of personal data, except in cases provided for in article 5 of the Luxembourg Law on the Protection of Personal Data
✓ to protect their rights and legitimate interests, including compensation for moral and material damage;
✓ to exercise other rights provided for by these laws of the Grand Duchy of Luxembourg.


5.1. The Company takes the necessary and sufficient organizational and technical measures to protect the user's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties with it.
5.2. All information that the Company collects is protected by reasonable security measures and procedures to prevent unauthorized access or use of the data. Company affiliates, partners and third-party service providers are committed to using the information received from the Company in accordance with our security requirements and this Policy.


6.1. If necessary, the Company may make changes to this Policy to keep the document up to date: in order to comply with legal requirements or for other reasons. The Company will notify you of material changes to this Policy by sending a message to your email or posting a notice on our website or mobile application. We recommend that you regularly check and review the Policy to be aware of what information the Company collects, how personal data is used.
6.2. The use of the Services means the user's unconditional consent to this Policy and the conditions for processing his / her personal information specified therein; in case of disagreement with these conditions, the user must refrain from using the Services.

6.3. This Policy and the relationship between the user and the Company arising in connection with the application of the Privacy Policy shall be subject to the law of the Grand Duchy of Luxembourg.