Privacy & Cookie Policy

VORON INVESTMENT GLOBAL · Effective Date: 1 January 2025

This is a combined Privacy and Cookie Policy: it explains what personal data the website collects and how it is used, and sets out the Firm’s use of cookies in the dedicated section below.

Premise

This Application collects some Personal Data from its Users. This document contains dedicated sections for consumers in California, Virginia, Colorado, Connecticut and Utah, for Users in Switzerland and Brazil, and a Cookie Policy. It can be printed for reference using the print command of any browser.

Owner and data controller

Voron Investment Group.
143 Av. Constitución, San Cristóbal 91000, Dominican Republic.
Owner contact email: support@voroninvestment.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Usage Data; Data communicated while using the service. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed before Data collection. Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide it may make it impossible for this Application to provide its services. Any use of Cookies — or other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy. Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases the Data may be accessible to certain types of persons in charge involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for, and may be retained for longer due to applicable legal obligation or based on the User’s consent.

The purpose of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Platform services and hosting, and Building and running this Application.

Detailed information on the processing of Personal Data

Building and running this Application (WordPress, self-hosted)

This Application is built and run by the Owner via a CMS software called WordPress. Personal Data processed: Data communicated while using the service; Usage Data.

Platform services and hosting (Hostinger)

Hostinger is a hosting service provided by Hostinger UK Limited. Personal Data processed: Usage Data. Place of processing: United Kingdom.

Cookie Policy

This document informs Users about the technologies that help this Application to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with this Application. For simplicity, all such technologies are defined as “Trackers” within this document — unless there is a reason to differentiate. This Application only uses Trackers managed directly by the Owner (so-called “first-party” Trackers).

Activities strictly necessary for the operation of this Application and delivery of the Service

This Application uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

How to manage preferences and provide or withdraw consent

Users can manage preferences related to Trackers from directly within their own device settings, for example by preventing the use or storage of Trackers. Additionally, Users can manage preferences via the relevant consent-preferences widget, if available, and may delete previously stored Trackers, including those used to remember the User’s initial consent preferences, by clearing the browsing history. Users are free to decide whether or not to allow the use of Trackers; however, if the User chooses to block them, the Owner may be unable to provide related features.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies: Users have given their consent for one or more specific purposes; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner; or processing is necessary for the legitimate interests pursued by the Owner or by a third party.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner. In particular, to the extent permitted by law, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if the Owner is processing Data, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law.

Further information for Users in Switzerland

This section applies to Users in Switzerland and, for such Users, supersedes any other divergent or conflicting information in the privacy policy. Under the Swiss Federal Act on Data Protection, Users may exercise, within the limits of law, the right of access to Personal Data; the right to object to processing (including to demand that processing be restricted, that Personal Data be deleted or destroyed, and that specific disclosures to third parties be prohibited); the right to data portability; and the right to have incorrect Personal Data corrected. Requests may be directed to the Owner through the contact details in this document.

Further information for Users in Brazil

This section applies to all Users who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (LGPD), and supersedes any other divergent or conflicting provisions. We process your personal information solely where we have a legal basis — such as your consent, compliance with a legal obligation, the carrying out of a contract and its preliminary procedures, the exercise of our rights in proceedings, the protection of your or a third party’s safety, or our legitimate interests.

You have the right to obtain confirmation of processing; to access, rectify, anonymise, block or delete your information; to obtain information on consent and on the third parties with whom we share your information; to portability; to revoke consent; to lodge a complaint with the ANPD; and to oppose processing carried out in breach of the law. You may file a request free of charge at any time using the contact details in this document, or via your legal representative, and we will strive to respond promptly.

Further information for California consumers

This section integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application. It applies to consumers residing in California, according to the California Consumer Privacy Act (CCPA/CPRA), and, for such consumers, supersedes any other divergent or conflicting information in this policy. This part uses the term “personal information” as defined in that law.

We have collected the following categories of personal data: internet information. We do not collect sensitive data, and will not collect additional categories without notifying you.

To find out why we process your data, and with which third parties we share it, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purpose of processing” within this document. Our use of your data may be considered a sale under this law; you have the right to opt out of such sale, and of the processing of your data for targeted advertising, at any time by contacting us using the details in this document.

For our purposes, a “sale” means disclosing personal information to a third party for monetary or other valuable consideration, and “sharing” means disclosing it for cross-context behavioural advertising. You have the right to opt out of both, and to limit the use of any sensitive personal information — though we do not collect sensitive personal information. You may exercise opt-out via a global privacy control such as the GPC, which we will honour. Once you have opted out, we will wait at least twelve months before asking you to reconsider.

Your rights and how to exercise them

You may exercise certain rights regarding your data: to access it and confirm whether we are processing it; to correct inaccurate data; to request its deletion; to obtain a portable copy; and to opt out of its sale, of targeted advertising, and of profiling that produces legal or similarly significant effects. We will not discriminate against you for exercising these rights.

To exercise these rights, submit your request using the contact details in this document. For us to respond, we must be able to verify your identity. We will respond without undue delay and at the latest within 45 days of receipt; where more time is needed we may take up to 90 days, and will explain why. Should we deny your request, we will explain our reasons, and you may appeal.

Further information for Virginia consumers

This section integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application. It applies to consumers residing in Virginia, according to the Virginia Consumer Data Protection Act (VCDPA), and, for such consumers, supersedes any other divergent or conflicting information in this policy. This part uses the term “personal data” as defined in that law.

We have collected the following categories of personal data: internet information. We do not collect sensitive data, and will not collect additional categories without notifying you.

To find out why we process your data, and with which third parties we share it, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purpose of processing” within this document. Our use of your data may be considered a sale under this law; you have the right to opt out of such sale, and of the processing of your data for targeted advertising, at any time by contacting us using the details in this document.

Your rights and how to exercise them

You may exercise certain rights regarding your data: to access it and confirm whether we are processing it; to correct inaccurate data; to request its deletion; to obtain a portable copy; and to opt out of its sale, of targeted advertising, and of profiling that produces legal or similarly significant effects. We will not discriminate against you for exercising these rights.

To exercise these rights, submit your request using the contact details in this document. For us to respond, we must be able to verify your identity. We will respond without undue delay and at the latest within 45 days of receipt; where more time is needed we may take up to 90 days, and will explain why. Should we deny your request, we will explain our reasons, and you may appeal.

Further information for Colorado consumers

This section integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application. It applies to consumers residing in Colorado, according to the Colorado Privacy Act (CPA), and, for such consumers, supersedes any other divergent or conflicting information in this policy. This part uses the term “personal data” as defined in that law.

We have collected the following categories of personal data: internet information. We do not collect sensitive data, and will not collect additional categories without notifying you.

To find out why we process your data, and with which third parties we share it, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purpose of processing” within this document. Our use of your data may be considered a sale under this law; you have the right to opt out of such sale, and of the processing of your data for targeted advertising, at any time by contacting us using the details in this document.

Your rights and how to exercise them

You may exercise certain rights regarding your data: to access it and confirm whether we are processing it; to correct inaccurate data; to request its deletion; to obtain a portable copy; and to opt out of its sale, of targeted advertising, and of profiling that produces legal or similarly significant effects. We will not discriminate against you for exercising these rights.

To exercise these rights, submit your request using the contact details in this document. For us to respond, we must be able to verify your identity. We will respond without undue delay and at the latest within 45 days of receipt; where more time is needed we may take up to 90 days, and will explain why. Should we deny your request, we will explain our reasons, and you may appeal.

Further information for Connecticut consumers

This section integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application. It applies to consumers residing in Connecticut, according to the Connecticut Data Privacy Act (CTDPA), and, for such consumers, supersedes any other divergent or conflicting information in this policy. This part uses the term “personal data” as defined in that law.

We have collected the following categories of personal data: internet information. We do not collect sensitive data, and will not collect additional categories without notifying you.

To find out why we process your data, and with which third parties we share it, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purpose of processing” within this document. Our use of your data may be considered a sale under this law; you have the right to opt out of such sale, and of the processing of your data for targeted advertising, at any time by contacting us using the details in this document.

Your rights and how to exercise them

You may exercise certain rights regarding your data: to access it and confirm whether we are processing it; to correct inaccurate data; to request its deletion; to obtain a portable copy; and to opt out of its sale, of targeted advertising, and of profiling that produces legal or similarly significant effects. We will not discriminate against you for exercising these rights.

To exercise these rights, submit your request using the contact details in this document. For us to respond, we must be able to verify your identity. We will respond without undue delay and at the latest within 45 days of receipt; where more time is needed we may take up to 90 days, and will explain why. Should we deny your request, we will explain our reasons, and you may appeal.

Further information for Utah consumers

This section integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application. It applies to consumers residing in Utah, according to the Utah Consumer Privacy Act (UCPA), and, for such consumers, supersedes any other divergent or conflicting information in this policy. This part uses the term “personal data” as defined in that law.

We have collected the following categories of personal data: internet information. We do not collect sensitive data, and will not collect additional categories without notifying you.

To find out why we process your data, and with which third parties we share it, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purpose of processing” within this document. Our use of your data may be considered a sale under this law; you have the right to opt out of such sale, and of the processing of your data for targeted advertising, at any time by contacting us using the details in this document.

Your rights and how to exercise them

You may exercise certain rights regarding your data: to access it and confirm whether we are processing it; to correct inaccurate data; to request its deletion; to obtain a portable copy; and to opt out of its sale, of targeted advertising, and of profiling that produces legal or similarly significant effects. We will not discriminate against you for exercising these rights.

To exercise these rights, submit your request using the contact details in this document. For us to respond, we must be able to verify your identity. We will respond without undue delay and at the latest within 45 days of receipt; where more time is needed we may take up to 90 days, and will explain why. Should we deny your request, we will explain our reasons, and you may appeal.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time, using the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application. It is strongly recommended to check this page often, referring to the date of the last modification listed. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent where required.

Definitions and legal references

Personal Data (or Data): any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person.

Usage Data: information collected automatically through this Application (or third-party services), which can include IP addresses, URI addresses, the time of the request, the method used, the country of origin, the features of the browser and operating system, and details about the path followed within the Application.

User: the individual using this Application who, unless otherwise specified, coincides with the Data Subject. Data Controller (or Owner): the natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.