Privacy Policy

Your privacy and security of your personal data are very important to us at the Partners Club.

The purpose of this Privacy Policy is to explain how we collect, store, use, and otherwise process your personal data when you use (the “Website”) and register to the Partners Club Backend platform (the “Platform”).

You can find information about our use of cookies and similar technologies in our Cookie Policy. Information related to personal data usage for direct marketing purposes is set out in Direct Marketing Notice. Both Cookie Policy and Marketing Notice are a part of our Privacy Policy. Therefore, when we refer to the Privacy Policy, we are referring to the Privacy Policy, Cookie Policy.

When using the Website, you may come across links to other websites, apps and services, or tools that enable you to share information with other websites, apps and services. We are not responsible for the privacy practices of these other websites, apps and services and we recommend you to review the privacy policies of each of these websites, apps or services before using the Website or sharing any personal data at all.

We may update this Privacy Policy from time to time unilaterally, in our sole discretion. Be sure to periodically check this page to ensure that at all times you are aware of any changes to this Privacy Policy. Changes of the Privacy Policy come in to force on the day they are published on the Website. Because of this reason, as you visit the website you have to make sure that you are aware of the latest version of the Privacy Policy that will be posted on the Website. If you continue to use the Website after the effective date of the changes, we will consider it as your agreement with the new Privacy Policy. 

Personal data – is any information about you, which allows us to directly or indirectly identify you by using an identifier such as name, identification number, geographical location data, online identifier or other factors associated to the physical, physiological, genetic, mental, economic, cultural or social identity.

We process your personal data according to EU Regulation No. 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and other legal acts, regulating the protection of personal data.

While processing your personal data we assure that your personal data is processed following these principles:

  • personal data is processed lawfully, fairly and in a transparent manner;
  • collected for specified, explicit and legitimate purposes;
  • adequate, relevant and limited to what is needed;
  • accurate and, where necessary, kept up to date;
  • kept in a form which allows identification of data subjects for no longer than is necessary;
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

The personal data we process

All your personal data we collect is required for the functioning of the Website and the Platform services. This information is necessary for the adequate performance of the contract between you and us, and to allow us to comply with our legal obligations.

Registration to the Platform

We collect personal data when you register and want to participate in the Platform (buy green energy, invest in to green energy, raise funds for green energy projects etc.). For this reason, we collect data such as name, surname, address, email, crypto wallet address, passport / ID photo, face photo, energy consumption data (annual), bank account, social media profile (facebook, gmail etc.), geographical location data. It is important, that the above mentioned personal data, including face recognition is processed for registration to the Platform. This data may be used for “Know Your Customer” purposes, and at all times based on your consent. We store your personal data for the duration of provision of Platform services and the period set by relevant legal acts.


We collect your personal data for communication purposes. When you participate in discussion boards, enter a competition, promotion or survey, messaging groups such as Telegram, Twitter, Facebook, Linkedin, Youtube, Bitcointalk, Reddit, Medium, Github and other similar services. For this reason, we collect name, surname, address, email, personal description and any other information you provide us with. The processed personal data we store as long as you are registered to the Platform.

You can communicate with us by using tools provided in our Websites, for example, clicking the button “Contact us”. In this case we process your personal data which you share with us. Your messages will be processed and stored until we analyze your information and make the best decision dedicated to which you share with us. Your messages will be processed and stored until we analyze your information and make the best decision dedicated to you.

Who we share your personal data with?

SMEFUNDS is the controller of your personal data, which is the parent company of the Partners Club. We have a legitimate interest to share your personal data with other companies of SMEFUNDS group, including our subsidiaries. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Website services globally.

We may also subcontract processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data may therefore be subject to privacy laws that are different from those in your country of residence.

We may share your personal data with a variety of third party service providers who provide services and process personal data on our behalf. These service providers have access to your information only to perform these tasks and are contractually bound to implement appropriate organizational and technical security measures to protect your personal data, and only to process personal following our instructions and to the extent necessary to provide their services to us. 

We must disclose your personal data to fraud and crime prevention agencies for the purpose of assessing the risk of crime, fraud and money laundering and this is a condition of us entering into any contract with you. In this case your personal data is disclosed under the regulatory requirements.

We may disclose your information to courts, law enforcement agencies, and governmental authorities that may request relevant information. Also, if we feel this is necessary, we may disclose your personal data to legal services providers in order to protect or defend our legitimate rights and interests.

How we use your information?

We use the information that you provided:

  • to carry out our obligations arising from any contracts entered into between us and to provide you with the information, products and services that you request from us;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
  • to notify you about changes in our services;
  • to ensure that content from our Website is presented in the most effective manner for you and for your computer.

We use the information we collected from you:

  • to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our Website to ensure that the content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our Website safe and secure;
  • to measure or understand the effectiveness of advertising that we serve you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our Website about goods or services that may best fit you or them.

Your rights and obligations

By implementing your rights, we are seeking to ensure transparency while processing personal data. The rights, which you have, as a data subject, are described below:

  • you have the right to be informed and request access to your personal data that we process about you. You may be entitled to request copies of your personal information, to know for what purposes your personal data is processed, the period for which personal data will be stored etc.;
  • you have the right to request that we amend or update your personal data where it is inaccurate or incomplete;
  • you have the right to request that we temporarily or permanently stop processing all or some of your personal data;
  • you have the right to object to us processing your personal data where we no longer have a legitimate or legal need to process it;
  • you have the right to request that we delete your personal data;
  • you have the right to request a copy of your personal data in a machine-readable format and the right to transmit that personal data for use in another party’s service.

In any case, above mentioned rights are not absolute and the implementation of your rights depends on some certain conditions indicated in regulatory acts.

While we are processing your personal data for the direct marketing purpose, you could be assigned to a proper category of customers. Therefore, you have the right to demand human intervention, to express your views or disagree with such a decision making.

If you are going to implement your rights, you should contact us via email, but before that, you have to prove your personal identity using electronic communication that allow proper identification of you in accordance with the procedure established by legal acts.

We will provide you with the information as soon as possible and not later than within one month from the day of your application. We provide information to you free of charge, but if the requests are going to be manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee with regard to administrative costs or refuse to act on your request.

You have the right to file complaints about data processing activities, but first of all we will try to resolve all the misunderstandings directly with you. If you will be unhappy with our reply, you have the right to lodge the complaint to a competent data protection authority (the list contacts of the authorities you may find:

Our rights and obligations

We have the right to not let you use the Website if you are less than 16 years old.

If we have doubts about accuracy of your submitted personal data or other related information, we have the right to ask clarification or supplement of your personal data or related information.

We have the right to send you the information, which is important to you, to your email about the updated services of the Website and its terms and conditions or other related information about our activities.

We make all reasonable efforts to ensure the smooth and further functioning of the Website and the Platform, but we do not ensure the continued functioning of the Website and the Platform, which may be influenced by other independent factors.

How do we take care of your personal data security?

We use appropriate organizational and technical personal data security measures including protection against unauthorized or unlawful processing, accidental loss, destruction or damage of your data. These chosen measures are based on the risks to your rights and freedoms.

In this case, we ensure strict access control to the processed personal data and provide access to those employees of the Company for which personal data are necessary for their work and monitor the use of the access granted.

We regularly monitor our systems for possible vulnerabilities and attacks. However, it is not possible to guarantee the security of information transmitted over the Internet. You use the Website and the Platform and provide us with information at your own discretion and risk.

We provide access to personal data with the correct level of passwords and create confidentiality agreements with individuals who access your personal data.

The employees of the Company, who have access to your personal data, are introduced to the personal data protection requirements, and they ensure the confidentiality of the personal data processed.