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Privacy Policy

1. Introduction

Innovest Pvt. Ltd. (“Innovest,” “we,” “us,” or “our”) is committed to protecting the privacy and security of the personal data we collect from our clients and website visitors. This Privacy Policy outlines our practices for collecting, using, disclosing, and protecting your data, and explains your rights concerning that information. By using our services or accessing our website, you consent to the practices described in this policy.

2. Information We Collect

We collect personal data to provide our investment services, comply with legal obligations, and improve our operations. The types of data we collect depend on your interaction with us and may include:

  • Identity Data: Your full name, marital status, gender, date of birth, and nationality.
  • Contact Data: Billing address, delivery address, email address, and telephone numbers.
  • Financial Data: Bank account details, payment card details, and details about your income, assets, and investment history.
  • KYC (Know Your Customer) Data: Copies of identity documents like passports, national ID cards, and any other information required for regulatory compliance.
  • Transaction Data: Details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data: Your IP address, browser type, time zone setting, and other technology on the devices you use to access our website.
  • Profile Data: Your username, password, feedback, and survey responses.
  • Usage Data: Information about how you use our website, products, and services.
  • Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties.

3. How We Use Your Personal Data

We will only use your personal data when the law allows us to. We use your data for the following purposes:

  • To provide our services: To facilitate the registration process for investments in Bhutan and the Gelephu Mindfulness City Special Administrative Region (SAR). This includes preparing and submitting legal and financial documents on your behalf.
  • For legal and regulatory compliance: To fulfill our obligations under anti-money laundering (AML), counter-terrorism financing (CTF), and other applicable laws in Bhutan and other relevant jurisdictions.
  • To manage our relationship with you: This includes providing you with information, responding to your inquiries, and sending you service updates.
  • For internal business purposes: To improve our services, analyze our business operations, and for data analytics and research.
  • For marketing purposes: To send you information about our services, newsletters, and investment opportunities that may interest you, but only with your explicit consent.

4. Legal Basis for Processing Personal Data

We process your personal data under one or more of the following legal bases:

  • Contractual Necessity: When processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
  • Legal Obligation: When we need to process your data to comply with a legal or regulatory obligation.
  • Legitimate Interests: When the processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights don’t override those interests.
  • Consent: When we have obtained your clear and explicit consent for a specific purpose. You have the right to withdraw this consent at any time.

5. Data Disclosure

We will not share or sell your personal data to third parties for their marketing purposes without your explicit consent. We may share your data with the following categories of recipients:

  • Regulatory and government bodies: To comply with legal requirements and reporting obligations, such as the Royal Monetary Authority of Bhutan, the Gelephu Mindfulness City Authority, and other government agencies involved in the investment and registration process.
  • Service providers: Third-party vendors who provide services on our behalf, such as IT support, data storage, or legal and accounting services. These parties are contractually obligated to protect your data and only use it for the purposes for which it was provided.
  • Financial institutions: Banks and other financial institutions involved in processing your transactions
  • Professional advisors: Our lawyers, auditors, and other professional advisors.

6. Data Security

We have implemented robust technical and organizational measures to protect your personal data from unauthorized access, accidental loss, disclosure, or alteration. We also limit access to your personal data to employees, agents, contractors, and other third parties on a need-to-know basis.

As an FDI (Foreign Direct Investment) partner, we act solely as a data processor and acknowledge that our clients remain the data controllers and owners of all personal information entrusted to us. All access to client data is subject to the security requirements, instructions, and technical controls defined by the client. These may include, but are not limited to, zero-trust identity management, multi-factor authentication, device management, and context-aware access rules.

We do not copy, store, or transfer client data outside of the platforms and systems designated by the client (for example, Google Workspace or other approved tools). Our personnel are contractually bound by confidentiality obligations, trained in data protection practices, and required to follow client-directed security policies at all times.

7. Your Data Rights

You have the following rights regarding your personal data:

  • Right to Access: You can request a copy of the personal data we hold about you.
  • Right to Rectification: You can request that we correct any inaccurate or incomplete data we hold about you.
  • Right to Erasure (Right to be Forgotten): You can ask us to delete your personal data in certain circumstances.
  • Right to Restriction of Processing: You can ask us to suspend the processing of your personal data in certain situations
  • Right to Data Portability: You can request that we transfer your personal data to another organization.
  • Right to Object: You can object to our processing of your personal data in certain circumstances, including for direct marketing purposes.

To exercise any of these rights, please contact us using the details provided below. We may need to request specific information from you to confirm your identity and ensure your right to access your data.

8. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including to satisfy any legal, accounting, or reporting requirements.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be posted on our website. We will notify you of any significant changes.

10. Contact Us

If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact our Data Protection Officer at: Innovest Pvt. Ltd.

Address: 4th Floor Ata Khanzang Building, Norzin Lam, Thimphu, Bhutan

Email: hello@innovest.bt

Phone:  +975 – 17137777

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