Privacy Policy

Last updated: 12 October 2026

We respect your privacy and are committed to handling personal information responsibly, transparently, and securely.

This Privacy Policy explains how personal information may be collected, used, stored, disclosed, and protected when you visit this website, interact with advertising content, or submit a registration or enquiry form.

This website contains promotional and advertising information relating to financial and investment services. Please read this Privacy Policy carefully before providing personal information.

1. Data Controller and Website Operator

The operator responsible for the website is:

INDIVIDUAL ENTREPRENEUR OKSANA OLEKSANDRIVNA KAMCHATKINA
Operating as Nova Digital Agency
Tax Identification Number: 3036723489
3 Heroiv Dnipra Street, Apartment 128
Kyiv, 04209
Ukraine

Privacy contact: [email protected]

This contact may be used for questions about personal information, requests to access or correct personal data, withdrawal of consent, and privacy-related complaints.

2. Scope of This Policy

This Privacy Policy applies to personal information processed in connection with this website, including information collected through:

• Visits to the website and its pages.
• Registration and enquiry forms.
• Advertising and referral links.
• Website analytics and measurement tools.
• Contact and support communications.
• Technical systems used to operate the website.

Third-party financial platforms may maintain separate privacy policies governing their own collection and processing of personal information.

3. Personal Information We Collect

Depending on your interaction with the website, we may collect the following categories of personal information.

3.1 Information Provided Voluntarily

• First name and last name.
• Email address.
• Telephone number.
• Country or region, if requested.
• Information included in enquiries.
• Preferences expressly submitted through forms.

We ask users not to submit passwords, payment card details, bank account credentials, copies of identity documents, or other sensitive financial information through general enquiry forms.

3.2 Technical Information

When you visit the website, technical systems may process information including:

• Internet Protocol (IP) address.
• Browser type and version.
• Operating system.
• Device type.
• Page URL and referring website.
• Date and time of access.
• Language and approximate location.
• Technical error and security information.

3.3 Advertising and Campaign Information

When a visitor reaches our website through an advertising campaign, the URL may contain campaign identifiers and referral parameters.

These may include:

• UTM source, medium, campaign, term and content.
• Campaign, ad group and advertisement identifiers.
• Click identifiers such as clickid and tblci.
• Sub-identifiers such as subid and subid1–subid7.
• Microsoft Advertising identifier msclkid.
• Google Ads identifier gclid.
• Meta advertising identifier fbclid.
• Publisher and placement identifiers.
• Other attribution parameters supplied in URLs.

Depending on the technology and context, these identifiers may constitute personal information or be linked to an individual.

They may be used to attribute enquiries to advertising campaigns, assess campaign performance, prevent abuse, and investigate technical issues, subject to applicable law and relevant consent requirements.

4. Why We Process Personal Information

Personal information may be used for the following specified purposes:

• Responding to registration requests and enquiries submitted by visitors.
• Arranging contact by the identified service provider, where properly disclosed.
• Operating and maintaining the website.
• Protecting the website against fraud, spam and unauthorised access.
• Understanding website performance.
• Measuring advertising campaign results where legally permitted.
• Handling privacy requests and complaints.
• Complying with applicable legal obligations.

Personal information should not be used for unrelated purposes without an appropriate legal basis and any additional consent required.

5. Registration and Enquiry Forms

When you submit a registration or enquiry form, the information entered may be processed to record your request and arrange a response.

The information may include your name, email address, telephone number, submission timestamp and applicable campaign attribution information.

Submitting an enquiry does not automatically create an investment account, constitute an investment transaction, or require a deposit or payment.

Submission of a form does not, by itself, authorise unrelated marketing communications or unrestricted sharing with third parties.

6. Storage of Registration Information

Registration submissions may be recorded in a server-side storage system to maintain a record of enquiries and support reliable processing.

Technical records may include a submission ID, time of submission, the information provided by the visitor, and relevant campaign attribution parameters.

Access to such records is intended to be restricted to authorised personnel and service providers who require access for legitimate operational purposes.

Personal information should not be stored in publicly accessible directories or exposed through unrestricted website URLs.

7. Lead Processing and Service Providers

Where clearly disclosed before submission, enquiry information may be shared with a designated lead-processing partner or the relevant financial service provider for the purpose of responding to the request.

The relevant recipient, its role, and the purpose of the disclosure must be explained to visitors before their information is submitted.

Depending on the arrangement, an external provider may process information on our instructions or act as an independent organisation responsible for its own privacy practices.

We do not treat submission of an enquiry as blanket permission to distribute contact details to unrelated organisations.

8. Advertising and Affiliate Relationships

This website may operate as an advertising or affiliate marketing platform.

The website operator may receive compensation for qualifying clicks, registrations, enquiries or other actions carried out through promotional links.

Advertising attribution information may be processed to determine whether a qualifying referral or conversion occurred.

The existence of a commercial relationship does not eliminate applicable privacy requirements or justify unrestricted disclosure of personal information.

9. Microsoft Clarity

This website may use Microsoft Clarity, a website analytics service provided by Microsoft.

Microsoft Clarity can help website operators understand how visitors interact with pages, including information about clicks, scrolling, navigation and technical performance.

Depending on the configuration, Clarity may use cookies, pseudonymous identifiers and session interaction data.

Measures should be implemented to protect information entered into forms and prevent unnecessary capture of sensitive data.

Analytics technologies are subject to applicable privacy and consent rules. Visitors should be offered appropriate choices where required.

Microsoft Privacy Statement: Microsoft Privacy

10. Taboola Advertising Pixel

This website may use Taboola advertising technology to measure the performance of advertising campaigns.

Depending on its configuration, the Taboola Pixel may register events such as page views, button clicks and completed enquiry submissions.

Advertising measurement may involve cookies or similar identifiers, device and browser information, event data and campaign identifiers.

We should not transmit names, email addresses, telephone numbers or other directly identifying form fields through advertising events unless there is an appropriate lawful basis, clear notice, and any required consent.

Taboola Privacy Policy: Taboola Privacy Policy

11. Cookies and Similar Technologies

Cookies are small data files that may be stored on a visitor's device when accessing a website.

Our website may use technologies for different purposes, including:

• Essential technical functionality.
• Security and fraud prevention.
• Remembering permitted preferences.
• Website analytics.
• Advertising attribution and measurement.

Non-essential analytics and advertising technologies should be controlled in accordance with the privacy requirements applicable to the visitor.

Browser settings may allow users to restrict certain cookies. However, browser settings alone may not control every tracking technology.

12. Consent and Privacy Choices

Where consent is required, we seek to provide information about the purposes of processing and the organisations receiving personal information.

Consent should be meaningful, informed and freely given in accordance with applicable law.

Visitors may request withdrawal of consent, subject to applicable legal or contractual limitations.

Consent for optional marketing or analytics activities should not be bundled unnecessarily with consent required to process a specific enquiry.

13. Age Confirmation

This website is intended for individuals aged 18 years or older.

Visitors may be asked to confirm their age and acknowledge financial risk warnings before accessing certain content.

Age confirmation and acknowledgement of investment risks do not constitute consent to unrelated advertising tracking or marketing communications.

14. Marketing Communications

Commercial emails and text messages are subject to applicable electronic communications and anti-spam legislation, including Canada's Anti-Spam Legislation (CASL), where applicable.

Marketing communications requiring consent should only be sent where an appropriate form of consent or another permitted legal basis exists.

Such messages should identify the sender and provide a functional way to unsubscribe when required by law.

Visitors may also contact us to request withdrawal from marketing communications.

15. International Data Transfers

The website operator is based in Ukraine. Some website services, hosting providers, analytics providers or commercial partners may operate in Canada, the United States, the European Union or other jurisdictions.

As a result, personal information may be processed or stored outside the visitor's province or country.

Information processed in another country may be subject to lawful access requests or legal requirements applicable there.

International processing arrangements should be assessed and appropriate safeguards implemented in accordance with applicable privacy legislation.

16. Data Security

We aim to apply technical and organisational safeguards appropriate to the nature and sensitivity of personal information.

Such safeguards may include:

• Encrypted website connections.
• Restricted administrative access.
• Protection of server-side records.
• Access controls and authentication.
• Security monitoring and updates.
• Measures to prevent unauthorised disclosure.

Although reasonable safeguards can reduce risk, no online system or method of transmission can be guaranteed completely secure.

17. Data Retention and Deletion

Personal information should be retained only for as long as necessary to fulfil the purposes for which it was collected, subject to applicable legal requirements.

Retention periods may differ for enquiry records, security logs, advertising attribution data and consent records.

When personal information is no longer required, it should be securely deleted, anonymised, or otherwise disposed of in accordance with applicable requirements.

Visitors may contact the privacy contact listed below to request information about retention and deletion of their data.

18. Access and Correction Requests

Subject to applicable law, individuals may request access to personal information held about them and ask for inaccurate information to be corrected.

We may need to verify the identity of a requester before providing access to personal information.

Requests will be reviewed in accordance with applicable legal requirements.

19. Withdrawal of Consent

Individuals may withdraw previously provided consent, subject to legal or contractual restrictions and reasonable notice.

Withdrawal may affect our ability to provide certain requested services.

A withdrawal request does not necessarily require deletion of records that must be retained for legitimate legal purposes.

20. Data Breaches and Security Incidents

In the event of a security incident involving personal information, we will assess the nature, scope and potential consequences of the incident.

Where required by applicable law, appropriate notifications and reports will be made to affected individuals and competent authorities.

Measures will be considered to contain the incident, reduce potential harm, and prevent recurrence.

21. Third-Party Websites

Our website may contain links to independently operated external websites, including financial service providers.

We encourage visitors to review the privacy practices of those organisations before providing personal or financial information.

This Privacy Policy does not govern the independent data processing activities of external providers.

22. Canadian Privacy Laws

Personal information relating to Canadian visitors may be subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

These requirements may address consent, transparency, safeguarding, individual access, correction, retention and accountability.

Visitors can obtain additional privacy information from the Office of the Privacy Commissioner of Canada.

Website: www.priv.gc.ca

23. Privacy Complaints

If you have a concern about how your personal information has been handled, please contact us first using the details below.

Individuals may also contact a competent privacy regulator where applicable.

Office of the Privacy Commissioner of Canada: www.priv.gc.ca

24. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, data processing practices, technology, or legal requirements.

The date at the beginning of this document indicates the most recent published revision.

Where changes materially affect personal information processing, additional notice or consent may be required.

25. Contact for Privacy Matters

For privacy enquiries, access requests, correction requests, withdrawal of consent, or complaints, contact:

Nova Digital Agency
INDIVIDUAL ENTREPRENEUR OKSANA OLEKSANDRIVNA KAMCHATKINA
3 Heroiv Dnipra Street, Apartment 128
Kyiv, 04209, Ukraine

Email: [email protected]