Consent to personal data processing

The User, meaning any natural person, including but not limited to a representative of a legal entity (hereinafter – the “User”), by interacting with the website at https://sigroup.com.ua/ (hereinafter – the “Website”), including by completing relevant electronic forms, submitting requests, and/or ticking the corresponding checkbox, provides STRATEGIC INVESTMENT GROUP LLC (hereinafter – the “Company”, the “Personal Data Controller”) with his/her voluntary, specific, informed, and unambiguous consent to the processing of personal data in accordance with the Law of Ukraine “On Personal Data Protection” and Regulation (EU) 2016/679 (GDPR) (hereinafter – the “Consent”), under the terms set out herein.

1. General Provisions

1.1. Providing personal data is voluntary; however, failure to provide such data may prevent the Company from reviewing the relevant request, providing information or services, or concluding transactions with the User.

1.2. The User confirms that the personal data are provided personally and are accurate.

2. Categories of Personal Data

2.1. The Company is entitled to process the following categories of personal data:

identification and contact data, including name, phone number, and email address;

information contained in application forms, inquiries, and requests, including information about interest in services, projects, and investment opportunities;

any other data voluntarily provided by the User during interactions with the Company.

2.2. A detailed list of personal data, as well as the specific features of their processing, is defined in the Privacy Policy, which the User has reviewed and which does not require additional confirmation from the Company.

3. Purpose of Personal Data Processing

3.1. The Company processes personal data, in particular, for the following purposes:

proper consideration of User inquiries and requests;

providing information regarding the Company’s activities, projects, proposals, programs, etc.;

preparation, conclusion, and performance of civil-law and commercial contracts;

communication with the User through any available communication channels;

for other purposes not prohibited by the laws of Ukraine, including but not limited to those deriving from the Company’s scope of activities.

4. Legal Grounds for Processing

4.1. Personal data processing is carried out on the basis of:

the User’s consent to the processing of personal data;

the necessity to conclude and/or perform a contract to which the User is a party;

the fulfilment of legal obligations imposed on the Company;

the Company’s legitimate interests, provided they do not override the User’s rights and freedoms.

5. Transfer (Disclosure) of Personal Data to Third Parties

5.1. The User consents to the transfer (disclosure) of personal data to the following categories of recipients:

affiliated persons and companies, including but not limited to those that are or may be part of the Company’s group;

counterparties, developers, investors, and other Company partners in connection with relevant projects;

service providers, including but not limited to hosting providers, CRM systems, automated, analytical, and marketing platforms, databases, and similar services;

payment organizations and payment infrastructure providers;

legal, audit, financial, and other professional advisors.

Personal data transferred to third parties as described in this Consent may be transferred for purposes identical or similar to those specified in paragraph 3.1.

5.2. Personal data may also be transferred:

in connection with corporate changes, including mergers, demergers, acquisitions, restructurings, asset disposals, or the sale of a business (in whole or in part);

to government authorities in cases provided by law, as well as for the protection of the Company’s rights and legitimate interests, fraud prevention, and security purposes;

to other persons — exclusively subject to obtaining separate consent from the User.

5.3. Personal data shall be transferred solely to the extent necessary to achieve the defined purposes, provided that third parties ensure an adequate level of protection and process such data strictly following the Company’s instructions.

6. Cross-Border Transfer of Personal Data

6.1. Personal data may be transferred outside Ukraine, including to jurisdictions that do not ensure an adequate level of personal data protection.

6.2. In such cases, the Company applies appropriate safeguards required by applicable law and international standards, including Standard Contractual Clauses (SCCs).

6.3. The User confirms that he/she has been informed about the potential risks associated with such transfers and consents to their implementation.

7. Rights of the Personal Data Subject

7.1. The User has been informed about his/her rights under Article 8 of the Law of Ukraine “On Personal Data Protection,” including the right to:

know the sources of personal data collection and their location;

receive information regarding the conditions of their processing;

access his/her personal data;

request their correction or deletion;

withdraw consent to personal data processing;

submit complaints to the competent supervisory authority.

8. Withdrawal of Consent

8.1. The User may withdraw consent by sending a written notice to the Company’s email address: [email protected]

8.2. A notice with the subject line “Personal Data” is considered a valid means of withdrawing consent and is equivalent to a written request.

9. Acknowledgement

9.1. The User confirms that he/she:

has been informed about the inclusion of his/her personal data in the Company’s relevant personal data database;

has been informed about the composition and content of the collected personal data;

has been informed about the purpose of their processing and the persons to whom such data may be transferred;

has read and understood the Privacy Policy;

provides consent voluntarily and knowingly.

10. Other Provisions

10.1. For legal relations not expressly regulated by this Consent, the Company and the User shall be governed by the applicable legislation of Ukraine in the field of personal data protection.

10.2. This Consent is valid for an indefinite period and is considered provided from the moment any of the events described in the preamble of this Consent occurs (individually or collectively).