Privacy Policy

1. Introduction

Faktorist ("we", "our", or "us") operates a B2B trade platform connecting buyers and suppliers worldwide. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our platform and any of its modules.

By accessing or using Faktorist, you agree to this Privacy Policy. If you do not agree, please do not access the platform. Questions? Email [email protected] or call +380 73 369 6160.

2. Information We Collect

3. How We Use Your Information

We use collected information to:

• Provide and maintain all platform services and modules
• Match buyers with suppliers using Sofiia AI and search data
• Process RFQs, tenders, and group buy pool memberships
• Generate anonymised Buyers Intent Feed signals for suppliers
• Manage FTR token rewards, staking, and wallet transactions
• Process company verifications (KYB) and maintain trust scores
• Power lead generation search with AI-enriched company data
• Track UAmbassador referrals, commissions, and tier progression
• Send service notifications (RFQ responses, tender deadlines, MOQ threshold alerts)
• Improve AI matching accuracy through aggregated usage patterns
• Prevent fraud, verify identity, and ensure platform security
• Send marketing communications (with explicit opt-in consent only)
• Comply with legal and regulatory obligations

Legal bases (GDPR Art. 6): we process your data to perform our contract with you or take pre-contractual steps (account creation, RFQs, tenders, deal rooms, subscriptions and billing); on the basis of our legitimate interests in operating, securing, improving and marketing the platform, in B2B lead generation and in fraud prevention (you may object at any time); to comply with legal obligations (KYB/AML, tax, sanctions and trade-compliance screening); and on the basis of your consent for non-essential cookies and electronic marketing, which you may withdraw at any time. Some features — including Sofiia AI buyer–supplier matching, trust scoring and lead scoring — involve automated processing and profiling to rank and recommend counterparties. These do not produce legal or similarly significant effects on you without human involvement; you may object to such processing or request human review by contacting us.

4. Information Sharing

We share your information only as follows:

• Buyers ↔ Suppliers: When an RFQ is submitted, the buyer's company name, contact, and product requirements are shared with the receiving supplier.
• Tender Board: Sealed bids are not visible to other bidders or to the buyer until the tender deadline passes.
• Group Buying: Your participation quantity is visible to the group buy organiser. Your individual identity is not shared with other pool participants.
• Logistics Hub: Contact requests to freight forwarders are direct. Faktorist does not store or share these communications.
• Lead Generation: Company search results are derived from publicly available registry data and AI enrichment. Your search queries are not shared with searched companies.
• UAmbassador Program: Referral relationships are tracked internally. Referred users can see the name of the ambassador who invited them.
• Service Providers (sub-processors): Trusted sub-processors who process personal data only on our instructions, under data-processing agreements. The current list is shown below.
• Legal Requirements: When required by law, court order, or to protect the rights, property, or safety of Faktorist or others.

We never sell your personal information to third parties.

5. Data Security

We protect your data with:

• TLS/SSL encryption for all data in transit
• Hashed passwords and encrypted blockchain wallet keys; verification (KYB) documents held in access-restricted storage
• Role-based access controls — employees access only what they need
• Audit logging of record changes and of verification, consent and compliance events
• Regular security reviews and penetration testing

6. Your GDPR Rights

If you are in the EU/EEA or the UK, you have the following rights over your personal data:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your account and data
• Portability: Receive your data in a structured, machine-readable format
• Restriction: Restrict certain processing activities
• Objection: Object to processing based on legitimate interests, including profiling and direct marketing
• Withdraw consent: Where processing is based on consent (e.g. marketing, non-essential cookies), withdraw it at any time without affecting processing carried out beforehand
• Lodge a complaint: Complain to a data protection supervisory authority — in the EU, your local authority; in the UK, the Information Commissioner's Office (ICO); in Ukraine, the Ukrainian Parliament Commissioner for Human Rights (Ombudsman)

You can download a copy of your data, or delete your account and erase your personal data, at any time from Settings → Data & privacy. To exercise any other right — or if you prefer help from a person — email [email protected] or call +380 73 369 6160. We respond within one month, extendable by two further months for complex requests as permitted by GDPR Art. 12.

7. Data Retention

We retain data as follows:

• Active account data: retained while your account is active
• RFQ and tender records: 5 years (trade documentation obligations)
• Search log data (for Buyers Intent): 14 days rolling window, then aggregated/anonymised
• Blockchain/FTR transactions: permanently on-chain (immutable by design)
• Internal CRM notes: retained until you delete them or close your account
• KYB verification documents: retained for the duration of the business relationship plus applicable legal retention period
• UAmbassador referral records: retained for commission tracking and audit purposes
• Deleted accounts: anonymised within 30 days; legal records retained per applicable law

8. International Data Transfers & Representatives

Faktorist is operated by Faktorist Ukraine LLC (EDRPOU: 45683528), based in Lviv, Ukraine. Because we offer services to users in the EU/EEA and the UK, our processing is subject to the EU GDPR and the UK GDPR. Ukraine is not currently the subject of an EU adequacy decision, and some of our processors (for example hosting, analytics, email, identity verification and AI providers) are located in the United States and other countries. Where we transfer personal data internationally, we rely on appropriate safeguards under GDPR Chapter V — principally the European Commission's Standard Contractual Clauses (with the UK International Data Transfer Addendum where relevant), supplemented by additional technical and organisational measures where necessary. You may request a copy of the safeguards we rely on by emailing [email protected].

EU & UK representatives (Art. 27 GDPR / UK GDPR): Faktorist is established in Ukraine. We keep our obligation to designate Article 27 representatives in the EU and the UK under active review and will appoint them as our processing activities grow; once appointed, their contact details will be published here. In the meantime you can raise any data-protection matter with us directly at [email protected], and you retain the right to contact the supervisory authorities listed above.

9. Children's Privacy

Faktorist is a B2B platform intended solely for businesses and professionals aged 18 or older. We do not knowingly collect data from minors. If we discover we have done so, we will delete the data immediately.

10. Cookies

We use cookies for authentication, analytics, and platform functionality. For details on what cookies we use and how to manage them, see our Cookie Policy.

11. Changes to This Policy

We may update this Privacy Policy when we add new features (e.g. Escrow, eCustoms, Factoring). Material changes will be communicated via email or an in-platform notice.

12. Contact

Data Controller: Faktorist Ukraine LLC (EDRPOU: 45683528), Lviv, Ukraine. Data protection contact (for privacy questions and data-subject requests): [email protected] — Phone: +380 73 369 6160. Please direct all data-protection matters to this contact.

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