Privacy Policy for the KodeX Financial Solutions website

1. General Provisions

This Privacy Policy (hereinafter referred to as the ‘Policy’) describes how KodeX Financial Solutions ApS (hereinafter referred to as ‘KodeX’, ‘we’, ‘us’, ‘our’), incorporated under Danish law, collects, uses, stores and protects the personal data of website users and individuals who contact KodeX for services.

KodeX acts as a data controller within the meaning of EU Regulation 2016/679 (GDPR) and the Law of Ukraine ‘On the Protection of Personal Data’ No. 2297-VI of 1 June 2010.

By using our website or contacting us to request our services, you confirm that you have read this Policy and agree to the terms and conditions governing the processing of your personal data.

KodeX Financial Solutions provides advisory, administrative and document preparation services. KodeX does not receive, hold, exchange or transfer clients’ funds or crypto-assets, nor does it provide banking, payment, investment or legal services.

2. Controller’s details

3. What personal data do we collect?

3.1 Data that you provide to us directly

• First name and surname

• Email

• Phone number

• Country of residence or nationality

• Information you provide in feedback forms, enquiries or correspondence with us

• Documents and details required to prepare documents as part of our services (where applicable)

3.2 Data collected automatically

• IP address and geolocation (country/city)

• Browser and operating system type

• Time and date of visit, pages viewed

• Cookie data (see our Cookie Policy for details)

• Referral source (where you came from to reach our website)

3.3 Data received from third parties

• Publicly available business information required to provide consultancy services

• Data from partners and analytics providers (in anonymised form)

4. Purpose and legal basis for processing

5. Data retention periods

• Customer data (contractual relationships) — for the duration of the contract and for 5 years after its termination (in accordance with the requirements of Danish accounting and tax legislation)

• Enquiry data (prospective customers) — up to 12 months from the date of the last contact

• Marketing subscriptions — until consent is withdrawn

• Technical logs — up to 90 days

• Cookies — in accordance with the Cookie Policy

Once the retention period has expired, the data is securely destroyed or anonymised.

6. Disclosure of data to third parties

KodeX does not sell or pass on your personal data to third parties for their own marketing purposes. We may pass on data:

• Service providers (data processors) — hosting, CRM, analytics, email — strictly in accordance with KodeX’s instructions and on the basis of data processing agreements entered into

• Regulatory and government bodies — in cases provided for by law

• Law enforcement agencies — in the event of a lawful request

Where data is transferred outside the EEA, we ensure an appropriate level of protection by applying the EU Standard Contractual Clauses (SCCs) or other mechanisms provided for under the GDPR.

7. Rights of data subjects

Under the GDPR and applicable legislation, you have the following rights:

• Right of access (Article 15 of the GDPR) — to obtain confirmation as to whether we are processing your data, and a copy of such data

• Right to rectification (Article 16 of the GDPR) — to request the rectification of inaccurate or incomplete data

• Right to erasure (Article 17 of the GDPR) — to request the erasure of your data (‘the right to be forgotten’) where there are valid grounds

• Right to restriction of processing (Article 18 of the GDPR) — to request a temporary suspension of processing

• Right to data portability (Article 20 of the GDPR) — to receive your data in a structured, commonly used format

• Right to object (Article 21 of the GDPR) — to object to processing on the basis of a legitimate interest or for direct marketing purposes

• Right to withdraw consent — at any time, without affecting the lawfulness of prior processing

To exercise any of these rights, please send a request to kodex.denmark@gmail.com. We will reply within 30 calendar days.

Supervisory authority in Denmark: Datatilsynet (www.datatilsynet.dk)

8. Data security

KodeX implements the following security measures:

• Data encryption during transmission (TLS/HTTPS)

• Restricted employee access based on the principle of least privilege

• Regular audits of security systems

• Confidentiality agreements with all employees and contractors

In the event of a data breach, we will notify the supervisory authority within 72 hours.

9. Changes to this policy

We reserve the right to make changes to this Policy. The latest version is always available on our website. In the event of any significant changes, we will notify you by email.

10. Contact details

Email: kodex.denmark@gmail.com

Feedback form: a page «Contact» on the website