HFF NOW S.R.L. hereby informs Users about how the personal data collected from users accessing https://www.hitfinancialfreedom.com/ (“Platform”) and the rights granted by European data protection legislation.
Please read carefully this privacy policy, before accessing the Platform.

1. Who we are

The Platform, both through the website available at https://www.hitfinancialfreedom.com/ and through any other mobile application, is owned and provided by HFF NOW S.R.L., a private limited liability company, incorporated under the laws of Romania, with its headquarters in Bucharest, at 12 Nerva Traian Street, building M37, 3rd entrance, 3rd floor, ap. 69, room 1, 3rd District, registered with the Bucharest Trade Registry under no. J40/10243/2020, CUI 42942615, e-mail: support@hitfinancialfreedom.com (“HFF NOW”, “we” or “us”), under the trademark HitFinancialFreedom.
The Platform is provided by HFF NOW in accordance with our Terms of Use, available here.
 
In this Policy:

• User: any natural person using the Platform for personal purposes.
• Services: means the services provided by HFF NOW to the Users which consist of providing access to the Platform a complex tool for managing data and generating reports on the content, distribution and performance of the investment portfolio based on the User Data uploaded by Users, as detailed in our Terms of Use available here.
• Platform: the personal investment management platform owned by HFF NOW, available at https://www.hitfinancialfreedom.com/, including any subsequent updates, revisions, adaptations enhancements or new versions of the product, which Users can access by creating a user name and password, against a fee.
• E-mail Address: the personal email provided by the User for the purpose of creating an account on the Platform and for communication with HFF NOW.
• Fee: the fee charged to the User by HFF NOW for each month during which the User has access to the Platform including any costs for Technical Support.
• Term: the period for which the User paid the applicable Fee during which the User is entitled to access and use the Platform.
• Technical Support: means the maintenance and support services provided by HFF NOW to the Users, in respect to the use of the Platform, in accordance with the applicable Terms of Use.
• Personal data: means any information concerning an identified or identifiable natural person – data subject.
• Data Subject: means any identified or identifiable natural person, directly or indirectly, in particular by reference to an identifying element, such as a name, an identification number, location data, an online identifier, or one or more factors: specific identity of his physical, physiological, genetic, mental, economic, cultural or social, accessing and using the features of the Platform and its content regardless of the means or duration of such interaction.

2. Personal Data we collect

In order to make the Platform and our Services available to the Users, HFF NOW collects the following data:

• a. as a result of the voluntary provision by the user, upon creating an account and paying the Fee, we might collect the following: personal email address, standard invoicing data – name, surname, address, Personal Data shared by the User during Technical Support. For the payment of the Fee, HFF NOW partners with Stripe!. Users can find their applicable privacy policy here.
• b. data collected automatically, upon accessing the Platform/Services – when the Users access the Platform, using their registered e-mail, we might collect the following data: IP address, time and duration of accessing the Platform, device-specific information such as operating system version, unique identifiers, name of the mobile network used, traffic reports recorded by the servers hosting the Platform.
• c. through cookies and other technologies: the Platform uses cookies and other technologies necessary for running the Platform and providing Users access to its features, or optional, to optimize the experience on the Platform.
  The cookies needed to run the Platform (eg: Google Analytics) may possibly collect information about Users including the websites from which the Platform was accessed, date and time of each visit, performed searches, accessed content and Services and their order, advertising banners, User interaction with advertising materials and duration of the visit.
  This data is collected for the purpose of providing access to the Platform and / or Services and is processed anonymously in the analytic reports on the traffic and use of the Platform.
  The policy on how cookies and similar technologies are used by HFF NOW on the Platform is available here.

3. Purposes and basis for processing Personal Data collected

The Personal Data collected through the Platform will be used in accordance with the applicable legal provisions and based on the consent of users for the following purposes:

• a. performing the agreement entered into with the User and granting Users access to the Platform and Services – for the purpose of identifying the Users and granting them access to the Platform and services as well as for processing the payment of the corresponding Fee, HFF NOW processes the name, surname, residential and e-mail address provided by the Users.
• b. for the payment of the Fee, we use external payment providers. Depending on the payment method, Users will be required to provide their name, surname, e-mail, as well as credit card details which will be collected and processed in accordance with this policy and the applicable privacy policy of our provider.
• c. for providing Technical Support based on explicit user consent, we collect and process the User’s email address and any other Personal Data shared by the User for this respect.
• d. based on our legitimate interest to analyze and improve the performance of the Platform, Services or Reports, in order to keep Users informed in respect to the Services and to provide Users with Technical Support.
• e. based on explicit user consent  – the User expresses their consent for non-essential communication by clicking the corresponding option on the privacy notice prompted upon registration or by accessing the corresponding section of the User’s account .
• f. in the event of a legal obligation in this regard.

The name and surname of the Users, as well as the e-mail address provided by the Users are used exclusively for the purposes of carrying out the agreement between HFF NOW and the Users, related the use of the Platform and Services and will not be shared to third parties without the express consent of the Data Subject unless required by the law.

4. Third party technologies and services

HFF NOW also uses third-party services and scripts in order to provide the Platform and make its features available to the Users as well as for providing Technical Support. 
In some cases we might share Users’ Personal Data for the purposes detailed in section 3 above with these beneficiaries or types of beneficiaries: 

• a. Hosting services

The Platform and all User Data is hosted by DigitalOcean,LLC, our server provider on servers located in Frankfurt, Germany. Their privacy policy is available here.

• b. Payment Provider

In order for the User to pay the applicable Fee for accessing the Platform they will be directed to Stripe! our payment provider. 
Based on the Users’ consent, for the purpose of accepting and processing Users’ payments, Stripe! will request and collect the following User Data: name, surname, credit card number, e-mail address, billing address, purchase amount, date of purchase.
Payments managed by Stripe! fall under their particular terms of use. Before making any payment, Users are required to review and agree to Stripe! privacy policies available here.

• c. Invoicing Partner

In order to issue the correspondent invoices for the Fee paid by the Users, HFF NOW uses the services of www.smartbill.ro a platform provided by Intelligent IT S.R.L., headquartered in Romania, Sibiu, 22 Aciliu Str., registered with the trade register under no. J32/1274/2006 tax no. RO18990059, bank account no. RO15BACX0000000239459000, opened with Banca Unicredit Ţiriac Sibiu, represented by Radu Hasan – director. Users can find their privacy policy here and their terms of use here .

• d. Other third party technologies

HFF NOW will not transfer Personal Data to third parties without the Users’ consent.

Any sharing of Personal Data outside the EEA will always be subject to the safeguards provided for by the applicable legal provisions or a data transfer agreement that clearly defines the obligations of the parties and ensures the technical and organizational measures for protection of the data concerned.

We currently use services and scripts provided by third parties strictly for providing the functionalities of the Platform and allowing Users to access its features as well as to request and receive Technical Support. These third party technologies may be subject to particular terms of use and privacy rules. Users must agree to their particular privacy policies. The Platform itself or certain of its features may otherwise not be available.

Tool – Purpose and link to applicable privacy policies

POEditor

We use this tool for providing Users with the content of the Platform in several languages. POEditor is operated by CODE WHALE INC., 1004 Sandstone Drive, Jeffersonville, IN 47130, United States and their privacy policy is available here.

Mobile detect
The Platform uses this lightweight PHP class script for detecting mobile devices, including tablets, for the purpose of providing Users the best experience on the Platform, while using such devices. Their privacy policy is available here.

Google Charts
The Platform uses Google Charts to provide Users with various ways to visualize the User Data, such as portfolio content, distribution, evolution, etc. Google’s privacy policy is available here.

Google Two Factor Authentication

The Users are required to use two factor authentication, in order to maintain security over their accounts and any User Data uploaded on the Platform. Users must review and agree to Google’s specific terms, available here. Personal Data will be processed in accordance with Google’s terms of use and privacy policies, available here.

HFF NOW may disclose User Personal Data to prosecutors, public or governmental authorities and other relevant third parties, in compliance with legal or regulatory requirements.
The list of cookies and similar technologies used by the Platform and HFF NOW is provided in our Cookie policy, available here..

5. The rights of the Data Subject

Data Subjects – Users, whose personal data are collected and processed through the Platform have the following rights:

• a. the right to be informed in respect to the collection and use of their personal data;
• b. the right to request access to personal data in order to obtain a copy of the personal data held by HFF NOW;
• c. the right to request the correction of any incomplete or inaccurate data;
• d. the right to request the deletion of personal data depending on the specifics of the processing, insofar as the person can be identified and if: (i) the data have been processed unlawfully; (ii) the data are no longer necessary for the purpose for which they were collected; (iii) the period provided by law, regarding data retention, has expired; (iv) the Data Subject objects to the processing and there is no legitimate interest in the further processing of personal data; or (v) consent is withdrawn;
• e. the right to request the restriction of the processing of personal data depending on the specifics of the processing, insofar as the person can be identified and if: (i) a claim has been made regarding the accuracy of the personal data processed (for a period allowing verification the correctness of the data in question the correctness of the personal data); (ii) if the data are being processed illegally; or (iii) the processing of the data is no longer necessary, but the user wishes to keep it, in connection with any legal claims;
• f. the right not to be subject to a decision based exclusively on automatic processing, including the creation of profiles, which produces legal effects concerning the data subject or similarly affects them to a significant extent in which case the processing of personal data will be stopped unless it is based on the consent of the data subject, is required for the performance of a contract or permit by law;
• g. right to portability, i.e. the right to require the provision of personal data in a format that can be read by an electronic device (computer), portable format, depending on the specific processing to the extent that the person can be identified;
• h. the right to withdraw at any time the consent to the processing of the User’s personal data without affecting the legality of any processing on the basis of the consent previously expressed;
• i. the right to file a complaint with the competent data protection authorities.

The National Supervisory Authority For Personal Data Processing
28-30 G-ral Gheorghe Magheru Bld.
Sector 1, Post Code 010336
București, România
E-mail: anspdcp@dataprotection.ro
dpo@dataprotection.ro
Phone: +40.318.059.211
Fax +40.318.059.602

6. Communication and marketing

HFF NOW will communicate with Users via email, in order to confirm the User’s request to register an account on the Platform to provide them the invoice for the Fee, as well as to carry on further communication in respect to the Services. 

Certain communications may be mandatory for the use of the Platform and Services. 
Users may receive marketing communications based on their express consent and can always withdraw such consent for any non-essential communications.

Users can request to stop marketing communications at any time by accessing the deactivation link in the email provided by HFF NOW. If you encounter problems in changing these settings please contact privacy@hitfinancialfreedom.com.

7. Personal Data storage and duration

The Personal Data collected through the Platform will be stored and processed inside the EEA on secure servers to provide users with the best possible experience. The Personal Data collected for invoicing purposes will be stored only for the period necessary to fulfil the purposes. Invoices issued to the Users will be retained as per the applicable accounting legal provisions, for a period of 10 years, as of the end of the financial year during which such invoices were issued.
Any other Personal Data will be stored for a period of 5 years or for the time necessary to fulfil the purposes for which it was collected, whichever is longer, including in order to meet any legal, accounting, or reporting requirements.

8. Technical and organizational measures, processing security

All information collected by HFF NOW is stored on secure servers and presents appropriate and necessary technical and organizational measures to protect personal data. HFF NOW continuously evaluates network security and the adequacy of its internal information security program, including through risk assessment and periodic testing.

9. Links to third party websites

The Platform may contain links to web pages or third party applications. Access to these links by Users will determine the application of privacy policies specific to each of these sites for which HFF NOW does not assume any responsibility.

Contact details:
For any additional information or to exercise their rights, users can contact us at:
HFF NOW S.R.L.
12 Nerva Traian Street, building M37, 
3rd entrance, 3rd floor, ap. 69, room 1, 3rd District, 
registered with the Bucharest Trade Registry under no. J40/10243/2020, CUI 42942615
privacy@hitfinancialfreedom.com.
This policy was revised on 04.02.2021.