Privacy Policy

1) Overview

BUH Consulting International LLC (“Company”, “we”, “our”, or “us”) is committed to protecting the privacy of individuals who access or use our website and services (“Website and Services”). This Privacy Policy (“Policy”) explains how we collect, use, disclose, and protect your personally identifiable information (“Personal Data”) when you interact with the Website and Services.

This Privacy Policy is subject to periodic revisions or amendments. Such updates may be necessitated by a variety of factors, including:

• The Evolving Legal Landscape: As data privacy laws and regulations continue to develop, we must adapt our policies accordingly to maintain compliance and best practices.
• Shifting Data Practices: Changes in how we collect, use, or store Personal Data will be reflected in this Policy to ensure transparency and user understanding.
• Website and Service Transformations: If we introduce new features or functionalities to the Website and Services, we will update this Policy to encompass them.
• Technological Advancements: We embrace emerging technologies that can enhance data privacy, and any such advancements will be duly incorporated into this Policy.

It is important to remember that the scope of this Privacy Policy is limited. It extends only to entities under our ownership or control, and individuals within our direct management. We cannot be held responsible for the data practices of independent third parties or entities outside our purview.

2) Scope and Application of Privacy Policy

This Privacy Policy (“Policy”) governs the collection, use, and disclosure of your Personal Data by BUH Consulting International LLC (“Company”, “we”, “our”, or “us”) in connection with your access and use of all Website and Services offered by the Company. This Policy does not extend to any products, applications, or services that maintain their own, separate privacy policies which do not expressly incorporate this Policy by reference.

In accordance with applicable data protection regulations, the Company acts as a data controller with respect to your Personal Data. This means that we are responsible for, and have control over, the processing of your information.

By accessing or using our Website and Services, you acknowledge that you have read and understood this Policy, and you signify your agreement to be bound by its terms and conditions.

For the purposes of this Privacy Policy, the term “Services” shall hold the same meaning, scope, and interpretation as defined within the Terms of Service Agreement entered into between you and BUH Consulting International LLC (“Company”, “we”, “our”, or “us”). This ensures consistent and unambiguous understanding of the Services encompassed by this Privacy Policy.

This addition clarifies the reference to “Services” by explicitly linking it to the previously established definition in the Terms of Service Agreement, eliminating potential ambiguity and reinforcing consistency across your legal documents.

3) Data Collection and Personal Data Inventory

This clause outlines the specific categories of data we collect, collectively referred to as “Personal Data,” to the fullest extent permitted by applicable Data Protection Laws. This list serves to inform you of the precise nature of the information we acquire and how it may be used.

1. Personal Identifiers and Demographics:

• Full name
• Date of birth
• Gender
• Country of residence
• Tax numbers (where applicable)
• Government-issued identification document data (e.g., passport, driver’s license)

2. Financial Information and Assets:

• Financial information (e.g., bank statements, account balances)
• Sources of wealth or income
• Level of anticipated activity
• Distributed ledger network wallet addresses (if applicable for cryptocurrency payments)

3. Verification Documents and Source of Funds:

• Government-issued identification documents (e.g., passport, driver’s license)
• Bank statements
• Utility bills
• Internet bills
• Income statements
• Account balances
• Financial transaction history
• Credit history
• Tax information
• Credit scores
• Other forms of identification, address verification, and source of funds verification

4. Corporate Entity Information:

• Legal entity name
• Trade name
• Legal domicile
• Fiscal domicile
• Object (purpose)

5. Corporate Documentation:

• Certificate of good standing
• Certificate of registration
• Constitution
• Memorandum & Articles of Association
• Bylaws
• Statutes
• Incumbency certificate
• Register of directors
• Register of shareholders
• Register of authorized signatories
• Registry excerpts
• Financial statements

6. Website and Services Usage Data:

• Interactions and actions undertaken on our Website and Services

7. Communication Data:

• Email exchanges
• Social media messages
• Customer support inquiries

8. Geolocation Data:

• Current and historical information regarding your geographic location (e.g., GPS, IP address)
• Transaction location
• IP addresses used to access our Website and Services

Transparency and Third-Party Tools:

We may leverage third-party services like Google Maps API to gather location data. Google utilizes various technologies like IP address, GPS, and other sensors to determine your location (see Google’s Privacy Policy for details).

4) Age Restriction and Minor Protection

Our Website and Services are not intended for or directed to any individual under the age of eighteen (18) (“Minors”). We have implemented appropriate age verification controls to prevent access and use by Minors. Therefore, we do not and will not knowingly or intentionally collect Personal Data from Minors.

If you are a parent or guardian and suspect that a Minor has provided us with Personal Data, please contact us immediately. Upon verification of such Minor’s age, we will promptly take all necessary steps to delete that information from our systems. We will also consider reporting such incidents to relevant child protection authorities as required by law.

5) Data Acquisition Methods and Sources

Subject to the full extent permissible under applicable Data Protection Laws, we acquire Personal Data about you and any other individuals whose details you provide to us through the following means:

1. Website and Service Interactions: We collect data when you access or utilize our Website and/or Services.
2. Interactive Forms and Participation: Completing online forms (including callback requests), downloading information, or engaging in other interactive areas within our Website and Services generates data.
3. Social Media Interactions: Engaging with us through social media platforms results in data collection.
4. Registration and Contact Information: Providing contact details for registration, access, or updates contributes to our data pool.
5. Direct Communication: Contacting us online or offline leads to data acquisition.

We may also collect Personal Data in situations where you only partially complete or abandon information input through our online forms. This data may be used to contact you for completion reminders or marketing purposes.

Device and Application Data Collection:

• We may collect information from your devices (including mobile devices) and applications used to access and utilize our Website and Services.
• This may encompass device identification numbers and types, location information, connection details (page views, traffic data, referral URLs, ad data), Internet Protocol (IP) addresses, browsing history, and web log information.
• We will explicitly request your permission before acquiring such data, potentially through cookies or similar technologies (further elaborated upon below).

Third-Party Data and Consent Responsibilities:

• Should you provide us with Personal Data about someone else, you are solely responsible for ensuring compliance with all relevant Data Protection Laws and consent obligations.
• When applicable under Data Protection Laws, you must acquire their explicit informed consent beforehand and explain our data collection, use, disclosure, and retention practices (or direct them to our Privacy Policy).

6) How your Personal Data may be used

1. Contractual Fulfillment: “Provide any information or Services that you have requested or ordered”

2. Data Verification and Accuracy: “Compare information for accuracy and to verify it with third parties”

3. Website and Service Optimization: “Provide, maintain, protect and improve our Website and Services”

4. Personalized User Experience: “Manage, monitor, and administer your use… and provide an enhanced, personal, user experience”

5. Relationship Management: “Manage our relationship with you (for example, for the provision of Services)”

6. Legal Compliance: “Provide you with any information that we are required to send you to comply with our regulatory or legal obligations”

7. Regulatory Compliance: “Comply with applicable Know Your Customer, Anti-Money Laundering, Counter-Terrorism Financing, and Anti-Corruption laws and regulations”

8. Legal Protection: “Detect, prevent, investigate or remediate, crime, illegal activities or to otherwise protect our legal rights. (including liaison with regulators and law enforcement agencies for these purposes)”

9. Aggregated Data Analysis: “Monitor, carry out statistical analysis and benchmarking (provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual)”

10. Personalized Marketing and Communications: “Deliver advertising, marketing (including but not limited to in-product messaging) or information which may be useful to you”

11. Joint Services with Third Parties: “Deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers, government registration authorities, and/or our channel partners)”

12. Governmental Disclosure: “In addition to the legal and commercial uses listed above, we may be required to provide any and all of your Personal Data to governmental authorities as necessary to comply with the law”

7) Our Website incorporates technology which:

1. Performs a direct comparison of specific device and system information relevant to your platform usage with our records.
2. Ensure conformance with our end-user agreements and facilitate troubleshooting of any technical difficulties.
3. Acquire information pertaining to any technical errors or other issues encountered on our Website.
4. Gather data regarding your utilization of our website features.
5. Compile aggregated statistical information about your operating system and access environment

8) Third parties with whom your personal data may be shared.

Channel partners such as but limited to Facebook, Twitter, Telegram, and Google Analytics. These vendors assist us in operating our Website and Services, including tasks such as:

1. Data analysis for website performance improvement.
2. Marketing and advertising campaigns tailored to your interests.
3. Providing customer support and communication channels.
4. Government and State Authorities for the legal obligations with but not limited to:

1. Responding to valid subpoenas, court orders, or legal process.
   1. Fulfilling law-enforcement requests or legal claims.

1. Providing information in response to government inquiries.

This disclosure is necessary to protect and defend the rights, interests, safety, and security of:

1. Our company and its affiliates.
   1. Our clients and website users.
2. Our company’s affiliates, channel partners, subcontractors and/or agents as required for the provision of the Services
3. Third-Parties in connection to corporate transactions such:
4. Selling a website or a portion of our business: We may share your data with potential buyers to facilitate due diligence and transition processes.
5. Merger, consolidation, or reorganization: Your data may be shared with the merging or acquiring entities to ensure a smooth and seamless continuation of services.
6. Financing: If we seek financing, lenders or investors might need access to certain data to assess our business and risk.
7. Change of control or acquisition: If another company acquires all or part of our business, your data will likely transfer to them as part of the ownership change.
8. Asset sale: If we sell specific assets, the relevant user data associated with those assets may be included in the sale.
9. Unlikely event of bankruptcy: In the rare case of bankruptcy or insolvency, your data may be transferred as part of the legal proceedings and asset sale.

9) Retention of Data

1. Contractual Performance and Legal Compliance:

• We will retain your Personal Data for as long as it is necessary to fulfill our contractual obligations, including providing you with the Services.
• This also includes complying with all applicable legal and regulatory requirements, such as data protection laws.

2. Retention Periods and Legitimate Interests:

• We reserve the right to retain your Personal Data for specific purposes beyond the initial contractual period:
• Know Your Customer (KYC), Anti-Money Laundering (AML), Counter-Terrorism Financing (CFT), and Anti-Corruption (AC) compliance: We may retain data for a minimum of seven (7) years after the Services terminate, as mandated by these regulations.
• Legal proceedings, complaints, and disputes: We may retain data for as long as necessary to protect our legitimate interests, such as defending ourselves in legal matters or resolving disputes.

10) Personnel who may have access to your Personal Data

1. Authorized Personnel Access:

• Access to your Personal Data is strictly limited to authorized Company personnel on a “need-to-know” basis. This includes, but is not limited to, our Compliance Officers.
• All authorized personnel are bound by confidentiality and non-disclosure agreements and subject to strict internal policies governing data access and usage.

2. Third-Party KYC/AML & CFT Providers:

• We may engage specialized third-party service providers to assist us in implementing our KYC/AML & CFT Policy and complying with relevant regulations.
• These third parties will only process your Personal Data to the extent necessary for their specific tasks, such as data verification or analysis.
• We will enter into data processing agreements with these providers to ensure the security and protection of your Personal Data against data breaches.
• Disclosure to Competent Authorities:
• We may disclose your Personal Data to competent authorities upon their request, but only:
  • To the extent legally required, such as by court order or subpoena.
  • To defend our rights in legal proceedings or investigations.

11) Data Security

• We implement all reasonable precautions and adhere to industry best practices to safeguard your Personal Data. This includes measures to:
  • Prevent loss, misuse, improper access, disclosure, alteration, or destruction of your data.
  • Employ robust security technologies and data encryption.
  • Maintain strict access controls and monitoring procedures.

12) You have the following rights as our client:

1. Request information on information kept by the company regarding your personal data.

2. Correct your data if it’s wrong.

3. Request for your data to be deleted if we no longer require access to it.

4. Pause your data to be processed.

5. Object to data use in certain cases with the approval of BUH Consulting International LLC.

The assertion of these rights is of a personal nature, and as such, it is incumbent upon the concerned party to exercise them directly by submitting a formal request to the Company. This implies that any client, user, subscriber, or collaborator who has previously provided their data may communicate with the Company to solicit information regarding the data stored, its acquisition methods, request rectification of said data, seek portability of their Personal Data, express objections to processing, restrict its usage, or request the deletion of their data from the Company’s records.

Clients are to email our compliance team – compliance@buh-consulting.com, accompanied by a valid proof of identity, such as a government-issued identification document and clearly outline the requested desired action and outcome.

13) Third-Party Content

1. Our Website may incorporate embedded content such as videos, images, and articles from external sources.
2. This embedded content operates as if you directly visited the originating website:

• It may independently collect data about you, similar to any other website you visit.
• It may utilize cookies, embed additional third-party tracking code, and monitor your interaction with said code.

14) Cookies policy

1. Our Website utilize cookies, small files containing unique identifiers, to enhance your browsing experience. These files are sent by our servers and stored on your device, allowing us to recognize you across different pages and visits.
2. Persistent Cookies: These cookies remember your preferences and activity on our Website for a set period, even after you close your browser. This allows for features like remembering your login information or tailoring your experience to past visits.
3. Session Cookies: These temporary cookies expire when you close your browser, essentially lasting for the duration of your session. They help us track your current activity and ensure smooth navigation within our platform.

How cookies are used

Cookies allows us to personalize your experience and improve our website functionality. We use cookies for the following purposes:

1. Website Optimization: We analyze cookie data to understand how users navigate our site and identify areas for improvement.
2. Website Analytics: Cookies provide valuable insights into how users interact with our platform, allowing us to track trends and measure performance.
3. Website Management: Cookies assist us in maintaining and securing our website by detecting potential issues and ensuring smooth operation.

Deleting and blocking cookies

1. You can restrict, block, or delete them from our website on your browser at any time.

15) Navigation

1. While using our website, we collect non-identifiable data like IP address, geolocation, usage patterns, and browsing habits to analyze trends, manage the platform, understand navigation, and gather demographic information.

16) Accuracy of Personal Data

1. By providing your information to the Company, you confirm its accuracy, completeness, and currency. You are solely responsible for ensuring all data you submit is correct and up-to-date, and the Company bears no liability in this regard.

17) Acceptance and consent

• By accepting this Privacy Policy, you confirm that you have been informed and agree with the Company’s practices regarding the protection of your Personal Data.

18) Revocability

• To access, rectify, erase, port, or object to the processing of your Personal Data, please email with a valid government-issued ID document as proof of identity. This right does not extend to Personal Data the Company must retain for administrative, contractual, legal, or security reasons.

19) Change of Ownership

• In the event of the Company being incorporated, acquired, merged, or experiencing any other change in ownership or operational control of the Website and Services, you expressly authorize the transfer of your registration data and information to the new operator.
• The Company will inform you of this transfer.

20) Privacy Policy Amendment

• The Company reserves the right to modify this Privacy Policy to reflect legislative changes and industry best practices.