Privacy Notice

This website is owned and operated by Incluence Limited (hereinafter – “Incluence”, the “Company”, “we”, “us”, “our”). During its operation the Company may use the information provided by the Users under this Privacy Notice. All individuals, who would like to use our service should accept this policy or not to use our services. By acceptance of Incluence’s Privacy Notice and providing `the private information Users agree that the Company may use this information in the way as specified below.

Protecting your privacy is very important to us. We have prepared this Privacy Notice (hereinafter – "Notice") in order to explain our practices regarding the collection, use and disclosure of information during provision of services and doing business.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

1. Who are we?

We are Incluence Limited, registered in Hong-Rong, Rm 7B, One Capital Place, 18 Luard Road, Wan Chai. We are the controller of personal data of our users which means that we determine what, for what purpose and how your personal data will be processed. If you have any questions, you can contact us by sending an email to You can also send us a letter at the address: Rm 7B, One Capital Place, 18 Luard Road, Wan Chai.

2. What is the Privacy Notice covered by?

This Privacy Notice applies to our website and the personal data processing process.

Website Address:

3. The definition of «personal data»

In accordance with Article 4 of the General Data Protection Regulation (hereinafter – “GDPR”):

“personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

“Personal data” and “personal information” are used interchangeably in this document. Our Users are “data subjects” in terms of GDPR.

4. Types of personal data

The data we process is divided into some categories:

The directly collected information (D)

This type of information that the User directly provides himself (e.g. by filling out the website forms).

Indirectly collected information (I)

This type of information is when the User doesn’t provide it directly (e.g. a language).

5. What information do we collect?

Please, see the list what personal data we collect:

Personal Data



for User identification
Phone number
for communications
for communications
for communication with the User his/her language or language he/she understands

6. The additional verification

The additional verification will apply in order to provide a legal services to our Users. We may ask you to provide the following information:

Personal Data


ID/passport data
D/passport scans or photo
Residence confirmation
Proof of funds confirmation
Relationship to politically exposed persons
Tax identification number
Social security number (if applicable)
LanguaType of activityge
Relationship to USA

7. How long do we keep your data?

We store personal data of users for the duration of the service and 24 months after completion. After the expiration of this period, we anonymize the data and store it for statistics and analytics.

We store personal data of users for the duration of the service and 24 months after completion. After the expiration of this period, we anonymize the data and store it for statistics and analytics.

8. Ways of data collection.

Incluence collects information directly via its website. It case it will use services of the third parties Incluence should inform the Users about it.

9. Lawfulness of Processing and Disclosure

Prior to using of the Services, the Users shall accept this Privacy Notice. After that moment the data processing is necessary and according to Article 6 (b) of the GDPR is lawful.

In all other cases the User is required to express their consent prior to the collection and processing of personal data. The Company doesn't use preset checkboxes when the User expresses their cosent thus making it explicit.

10. What legal bases do we rely on to process your information?

GDPR require us to explain the valid legal basis we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

11. Where we store or use your data

We may store your data electronically in __________. Any data stored electronically will be stored in secure servers, premises in ___________. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our websites and any transmission is at your own risk.

12. Rights of the User

To exercise your rights, write us an email at to

13. Communications

During using of our services and account maintenance you will receive information messages (through email, phone, push-notifications, messages in account) from us in case you agree to receive them or in case these messages are necessary and important for using of our Services.

At any time you may unsubscribe from e-mail communication by sending your request at

14. Cookies

A cookie policy is a declaration to our Users on what cookies are active on our website, what user data we track, for what purpose, and where in the world this data is sent.

The cookie policy is contained information in order how our users may refuse the cookies or change their settings regarding the cookies on our website. Whereas most of the remaining privacy policy may be static, the cookies used on a website are dynamic and might change often.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. For more information about the cookies we use, please see OUR COOKIE POLICY.

15. Conclusions

If you would like to use our Services you shall accept this Privacy Notice as without your permission we can’t use your data and so we can’t provide our Services to you

 We are committed to protecting the privacy of personal data and try to disclose the processing details in a transparent and easy way. In case you have any questions concerning the information above, please, don't hesitate to contact us through the contacts above provided.

In case we lawfully receive your Personal information from a third party you will have the same rights regarding information in question as regarding to information that you have provided to us directly or we have collected during cooperation with you.

If you have questions or comments about this Notice, you may contact our Data Protection Officer (hereinafter – the “DPO”) by email at, or by post to: Rm 7B, One Capital Place, 18 Luard Road, Wan Chai.  


This website uses cookis to improve user experience.