Who we are
Our website address is: https://www.finmill.tech. This website is operated by:
| Company | Ithuba FinMill GmbH |
| Register number | FN 488607s (Commercial Court Vienna) |
| Address | Stallburggasse 4, 1010 Vienna, Austria |
| Data protection contact | dataprotection@ithubacapital.com |
Ithuba FinMill GmbH is the controller, within the meaning of Article 4(7) GDPR, for personal data processed through this website.
If you are an Investor in the Ithuba Stallburg Digital Carry fund, the processing of your personal data in connection with the Fund (KYC/AML, the Unit Register, subscriptions and redemptions, etc.) is governed separately by the Privacy Policy Annex to your Investment Agreement, not by this website policy.
What personal data we collect and why we collect it
This website does not have a comment function enabled, and visitors cannot upload media files. Accordingly, no personal data is collected through comments, and no image/EXIF metadata is exposed through visitor uploads
Contact forms
If you submit an enquiry through a contact form on this site, the data you provide (such as your name, email address, and message) is collected and used solely to respond to your enquiry. We do not use contact form submissions for marketing purposes unless you separately opt in. Contact form submissions are retained only as long as necessary to handle your enquiry and for a reasonable period afterward for record-keeping, and are then deleted.
Cookies
This site does not have a comment function, so no comment-related cookies are set.
If you visit our login page, we set a temporary cookie to determine whether your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. Login and screen-option cookies are set only for authenticated staff who manage the website (they are not set for general visitors, since the site has no public account/registration system).
We may also set general analytics-type cookies when you first visit the site (e.g., to distinguish visitors and measure basic traffic).
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Analytics
We do not currently use basic website analytics services to measure visits and traffic patterns.
Who we share your data with
We share personal data collected through this website with the following categories of recipients:
- Our website hosting provider — for the technical operation of the site, acting as a data processor under an Article 28 GDPR data processing agreement.
We do not sell personal data collected through this website to third parties.
If you are a Fund Investor, additional recipients relevant to KYC/AML compliance and Fund administration (auditors, regulators, the Austrian FMA, the Austrian Financial Intelligence Unit, etc.) are described in the separate Privacy Policy Annex to your Investment Agreement.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
Contact form submissions are retained as described above. Server and access logs are retained for a limited period for security and troubleshooting purposes, typically no longer than 12 months, unless a longer period is required to investigate a security incident or comply with a legal obligation.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Because Ithuba FinMill GmbH is established in Austria, these requests are handled in accordance with the GDPR and the Austrian Data Protection Act (Datenschutzgesetz — DSG). Depending on the legal basis for processing, you may have the right to:
- Access (Art. 15 GDPR) — confirmation of whether we process your data, and a copy of it.
- Rectification (Art. 16 GDPR) — correction of inaccurate or incomplete data.
- Erasure (Art. 17 GDPR) — deletion of your data, subject to legal retention obligations.
- Restriction of processing (Art. 18 GDPR) — in certain circumstances, e.g., while accuracy is disputed.
- Data portability (Art. 20 GDPR) — receipt of data you provided to us, in a structured, machine-readable format.
- Objection (Art. 21 GDPR) — objection to processing based on our legitimate interests.
To exercise any of these rights, contact us at compliance@finmill.tech. We will respond within one calendar month of receipt of the request, extendable by a further two months where necessary, and may request proof of identity before responding.
You also have the right to lodge a complaint with a supervisory authority. The competent authority in Austria is:
| Authority | Austrian Data Protection Authority (Datenschutzbehörde – DSB) |
| Address | Wickenburggasse 8, 1080 Vienna, Austria |
| Website | www.dsb.gv.at |
| dsb@dsb.gv.at |
Where we send your data
Personal data collected through this website is generally processed within the European Economic Area (EEA). If any processor is established outside the EEA, we rely on Standard Contractual Clauses approved by the European Commission, supplemented by additional technical and organisational measures where necessary. Visitor comments may be checked through an automated spam detection service.
Your contact information
| Company | Ithuba FinMill GmbH |
| Address | Stallburggasse 4, 1010 Vienna, Austria |
| compliance@finmill.tech |
Additional information
How we protect your data
We implement technical and organisational measures appropriate to the risk, in accordance with Article 32 GDPR, including:
- Access controls and authentication measures for systems containing personal data
- Encryption of personal data in transit and, where appropriate, at rest
- Confidentiality obligations and data protection training for personnel with access to personal data
- Data processing agreements with all processors, in accordance with Article 28 GDPR
- Regular review of security measures in light of the state of the art
What data breach procedures we have in place
In the event of a personal data breach, we assess the risk to affected individuals and, where required, notify the Austrian Data Protection Authority (DSB) without undue delay and, where feasible, within 72 hours of becoming aware of the breach, in accordance with Article 33 GDPR. Where a breach is likely to result in a high risk to the rights and freedoms of affected individuals, we notify those individuals directly without undue delay, in accordance with Article 34 GDPR.
What third parties we receive data from
In connection with general use of this website, we do not receive personal data about you from third parties.
What automated decision making and/or profiling we do with user data
We do not use your personal data to make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you within the meaning of Article 22 GDPR.
Industry regulatory disclosure requirements
thuba FinMill GmbH is authorized and regulated as an alternative investment fund manager (AIFM) by the Austrian Financial Market Authority (FMA) under the Austrian Alternative Investment Fund Managers Act (AIFMG). These regulatory disclosure obligations apply to our management of the Ithuba Stallburg Digital Carry fund and to our relationship with Fund Investors, as set out in the separate Privacy Policy Annex to the Investment Agreement — they do not extend to general visitors of this website.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in applicable law, our data processing practices, or the operation of this website. Material changes will be highlighted on this page, along with an updated effective date.