Privacy Policy

INTRODUCTION

 
Victus Ventures Limited (“Victus”, “we”, “us”, or “our”) is committed to protecting your privacy  and ensuring transparency in how we collect, use, and safeguard your personal information. This  Privacy Notice explains how we collect, process, and share information when you use our  Website (https://www.victusglobal.com), engage with our services, or interact with us in any other way.  

This Privacy Notice applies to all personal data collected through our Website, services, and  related interactions, whether you are a visitor, customer, or other user (“User”, “you”, or  “your”). It outlines your rights regarding your personal data and how you can exercise them in  accordance with applicable privacy laws, including but not limited to the General Data  Protection Regulation (GDPR) and other relevant data protection regulations.  

Victus acts as the “Data Controller” for any personal data of Users that we collect. Data  Controller means the person who, alone or jointly with others, determines the purposes and  means of the processing of personal data.  

By using our Website and services, you acknowledge that you have read and understood this  Privacy Notice. If you do not agree with our practices, please refrain from using our services  and/or our Website.  

This Privacy Notice does not apply to third-party websites, applications, or services that may be  linked to or from our website. We encourage you to review the privacy policies of any third party services you interact with.  

This Privacy Notice is an integral part of our Terms of Service. Any capitalized terms used but  not otherwise defined herein shall have the meanings assigned to them in the Terms of Service.

1.1. Information You Provide Directly  

1.1.1.We collect the information you choose to give us when:  

● You fill out a contact form, newsletter subscription, or other form on our Website; 

● You communicate with us by email or otherwise request information from us; 

● You submit inquiries, feedback, or other information in connection with our services (for example, crypto-fiat exchange, market making, staking, or custody solutions). 

1.1.2.Depending on the nature of your interaction, this may include your name, email address,  phone number, or any other details you choose to provide.  

1.2.Information Collected Automatically.  

1.2.1.When you visit or use our Website, certain data may be collected automatically through  cookies and similar tracking technologies:  

● Essential/Functional Cookies: Our Website is built on the Webflow platform, which  may use cookies strictly necessary for security, network management, and basic  functionality.  

● Mailchimp Cookies (if enabled): If we embed or utilize subscription forms and email  marketing features through Mailchimp, Mailchimp may set cookies to track form  submissions, user interactions, and related analytics.  

● Log and Device Information: We may record your device’s Internet Protocol (IP)  address, browser type, operating system, referring URLs, and pages visited, along with  timestamps and related metadata. These logs help us secure our Website, monitor  performance, and improve user experience.  

1.2.2.Currently, we do not set non-essential cookies by default. However, certain automatic data  collection may occur if you interact with embedded third-party forms or plugins.  1.3.Information from Third Parties  

1.3.1.In some instances, we may collect or receive information about you from:  ● Email Marketing Platforms: If you subscribe to our newsletter or other updates via  Mailchimp or a similar platform, those providers may share relevant registration and  usage details with us.  

● Hosting/Infrastructure Providers: Our site is hosted on Webflow, which utilizes  Amazon Web Services (AWS) and Cloudflare for infrastructure and content delivery; in  providing these services, they may generate technical data (e.g., server logs). 

● Other Business Partners: We may receive data from service providers or vendors that  assist us with fraud detection, compliance, customer support, or analytics.  1.3.2.Whenever we obtain personal data from a third party, we take steps to ensure it has been  collected lawfully and that we have a legitimate basis for using it as described in this Privacy  Notice.  

Victus does not collect, process, or store personal data from individuals who are citizens or  residents of the United States of America. Our services are not directed at individuals located in  the U.S., and we do not conduct business, offer services, or engage in transactions with U.S.- based persons, entities, or organizations. Any information inadvertently received from U.S.  citizens or residents will be promptly deleted upon discovery.  

If you are a U.S. citizen or resident and believe that we may have inadvertently collected your  personal data, please contact us immediately using the details provided in the "How to Contact  Us" clause 10.4 to request its removal.  

2.Legal Basis for Processing Your Information  

Depending on your location, we process personal information under one or more of the  following lawful bases (as recognized by the GDPR and similar data protection laws):  

2.1.Consent: Where you have given clear permission for us to process your data for a specific  purpose, such as subscribing to our newsletter.  

2.2.Legitimate Interests: Where processing is necessary for our legitimate business interests  (for example, ensuring the security of our Website, responding to inquiries, or carrying out  basic analytics), provided that such interests do not override your fundamental rights and  freedoms.  

2.3.Legal or Regulatory Obligations: Where we must process your data to comply with  applicable laws or lawful requests (e.g., disclosures to regulatory authorities or responding to  subpoenas).  

We will always ensure that we have an appropriate lawful basis before processing your personal  information.  

3.How We Use Your Information 

Because our Website is provided for informational purposes only and does not itself facilitate  services or transactions, we primarily use any personal information we collect to communicate  with you about our business or share updates. Specifically, Victus uses your data for:  

3.1.Responding to Inquiries and Requests.  

● Contact and Support: When you submit a form on our Website or email us with  questions, we use your contact details to respond or follow up on your requests (e.g.,  providing more information about our services, arranging a consultation, or answering  general inquiries).  

3.2.Newsletter and Marketing Communications 

● Subscription Management: If you choose to receive our newsletter or other marketing  messages, we will use your personal data (e.g., email address) to send you relevant news,  updates, or promotions about Victus.  

● Third-Party Email Tools: We may rely on tools like Mailchimp (or similar providers) to  manage subscription lists and send out marketing materials on our behalf. You can opt  out at any time by using the “unsubscribe” link within the emails or contacting us  directly.  

3.3.Website Functionality and Analytics  

● Site Performance and Security: Webflow, our hosting platform, and/or essential  cookies may capture technical data such as IP addresses or browser info to ensure the site  operates reliably and securely.  

● Limited Tracking: We do not set non-essential cookies by default. However, certain  third-party integrations (like Mailchimp signup forms) may use cookies to measure  subscription events or user interactions. This helps us understand the effectiveness of our  outreach and improve your overall browsing experience.  

3.4.Legal and Regulatory Compliance  

● Fulfilling Legal Obligations: We may process and retain information where we believe  it is necessary to comply with applicable laws or lawful requests and legal processes  (e.g., responding to subpoenas or lawful government requests).  

● Protecting Rights and Interests: We may also process data to investigate or prevent  fraud, security breaches, or other violations of law—or to enforce our Terms of Use and  other agreements.  

3.5.Business Operations and Due Diligence  

● Potential Client or Partner Reviews: If you contact us expressing an interest in  engaging our services, we may collect and review the information you provide to assess  potential business opportunities.  

● Corporate Transactions: In the event of a merger, acquisition, restructuring, or similar  corporate transaction, your information may be transferred as part of that process, subject  to appropriate confidentiality and data protection measures.  

4.How We Share Your Information  

Victus values your privacy and only shares your personal data in limited circumstances,  consistent with the purposes described in this Privacy Notice. Specifically, we may disclose your  information in the following ways:  

4.1.Service Providers and Business Partners:  

● Website Hosting & Infrastructure: Our Website is hosted on Webflow, which leverages  Amazon Web Services (AWS) and Cloudflare. These providers may handle technical data  (e.g., server logs) in the course of delivering their hosting and security services. 

● Email Marketing & Form Submissions: If you subscribe to our newsletter or complete  a contact form integrated with a third-party tool like Mailchimp, that provider will  receive the personal data necessary to process and manage your subscription or inquiry.  

● Professional Advisors: We may engage lawyers, auditors, or other professional advisors  who require access to limited personal data for legitimate business or compliance  purposes.  

4.2.Compliance with Legal Obligations:  

● Regulators and Authorities: We may disclose personal information to governmental  agencies, regulators, or law enforcement as required by applicable law, regulation, court  order, or other legal process.  

● Protecting Rights and Safety: We may share personal data if necessary to protect our  rights, property, or safety, or those of our users or others (e.g., in cases of suspected fraud  or security issues).  

4.3.Corporate Transactions  

● Business Transfers: If Victus is involved in a merger, acquisition, financing,  reorganization, or sale of all or a portion of our assets, your personal data may be  transferred to the buyer or other successor entity. Should such a transfer occur, we will  use reasonable efforts to ensure the recipient honors this Privacy Notice or provides  equivalent safeguards. If we hold your contact details, we will also make reasonable  efforts to notify you of any such transfer and its potential impact on your personal  information.  

4.4.Consent or Direction  

● At Your Request: We may share your personal data with additional parties when you  specifically request or authorize it (for example, if you direct us to introduce you to one  of our partners).  

4.5.Aggregated or De-Identified Information:  

● Analytics and Reporting: We may compile usage statistics or aggregate anonymized  data (which cannot identify you personally) for internal analytics, administrative  reporting, or to improve our Website. Such aggregated information may also be shared  with potential partners or the public to demonstrate usage trends while maintaining your  anonymity.  

Outside of these limited instances, Victus does not sell, rent, or otherwise share your personal  data with unaffiliated third parties for their independent marketing or commercial purposes. If  we ever need to share your data beyond these parameters, we will notify you and, where required  by law, seek your consent.  

We share data under appropriate lawful bases recognized by the GDPR—such as your consent  (for newsletters) or our legitimate interests (for hosting, security, or basic business operations). If 

our providers or partners are located outside the European Economic Area (EEA), we rely on  suitable safeguards (e.g., EU Standard Contractual Clauses) to protect your personal data.  

5.How We Protect Your Information  

Victus is committed to safeguarding your personal information and employs a variety of  technical, organizational, and administrative security measures to help protect against  unauthorized access, loss, misuse, alteration, or disclosure. Specifically, we use:  

5.1.Technical Safeguards  

● Secure Hosting Environment: Our Website is hosted on Webflow, which uses Amazon  Web Services (AWS) and Cloudflare for infrastructure. These industry-leading providers  maintain robust security measures (e.g., firewalls, monitoring, access controls) to guard  against attacks.  

● Data Transfer Protections: Where feasible, our Website and integrated form  submissions use encrypted connections (HTTPS/SSL) to help ensure data in transit  remains confidential.  

● Limited Access: Only authorized personnel and trusted third-party service providers can  access personal data, and such access is restricted to what is necessary for legitimate  business purposes.  

5.2.Organizational Measures  

● Staff Training: We ensure that relevant team members understand best practices for data  privacy and security, including how to handle inquiries and maintain the confidentiality  of collected data.  

● Third-Party Due Diligence: Before engaging any new parties who may handle personal  data on our behalf, we assess their security policies and practices to ensure they meet or  exceed our standards.  

5.3.Incident Response  

● Monitoring & Alerts: We monitor our systems and infrastructure for unusual activity. In  the event of a suspected data breach or security incident, we respond promptly to contain  the issue.  

● Notification: If a breach is confirmed to pose risks to your rights or freedoms, we will  notify the relevant supervisory authority (and affected individuals if required by law)  within the applicable legal timelines.  

5.4.No Absolute Guarantee  

● Despite our best efforts, no method of data storage or transmission can be guaranteed to  be 100% secure. While we strive to protect your personal data, you acknowledge that you  share information at your own risk.  

By implementing these measures, Victus seeks to maintain a high standard of security and  reduce the risk of data compromise. We regularly review and update our practices to keep pace  with changes in technology, business operations, and regulatory requirements. 

6.How Long We Retain Your Information  

Victus will not retain your personal data for longer than necessary to fulfill the purposes for  which it was collected unless retention is required or permitted by law. Specifically:  

6.1.Website Inquiries & Communication  

● If you contact us via our Website forms or by email, we generally retain your personal  information for as long as needed to address your request, inquiry, or complaint.  Afterward, we may store records for record-keeping and audit obligations or for  defending legal claims.  

6.2.Newsletter and Marketing Lists  

● Subscriptions: If you subscribe to our newsletter or other marketing messages, we keep  your email address and related subscription data until you opt out or otherwise request  deletion. We may also periodically remove inactive or undeliverable addresses from our  lists.  

● Opt-Out Requests: If you unsubscribe, we will promptly remove or suppress your email  address from marketing communications but may keep a record of your request to ensure  we honor your preferences.  

6.3.Compliance & Legal Obligations  

● Regulatory Requirements: Certain data may be retained for a legally mandated period  if those obligations arise in future engagement or offline contexts.  

● Litigation & Dispute Resolution: We may retain data if we believe it is necessary for  handling any actual or potential legal disputes or to enforce our agreements.  6.4.Aggregate or Anonymized Data  

● Usage Analytics: Information that has been anonymized or aggregated may be retained  indefinitely to help us analyze and improve our Website or for other legitimate business  purposes. This data cannot be used to identify you personally.  

After the expiration of the relevant retention period, or once the data is no longer needed for any  of the above purposes, we will securely delete or anonymize your personal information in  accordance with our data retention and deletion policies. If you have questions about specific  retention times for particular types of data, please contact us using the details provided in the  “How to Contact Us” сlause of this Privacy Notice.  

7.Your Rights  

Depending on where you reside, applicable data protection laws (such as the EU General Data  Protection Regulation (GDPR)) may grant you specific rights with respect to your personal  information. While these rights can vary by jurisdiction, Victus generally strives to honor the  following principles, defined under the GDPR: 

7.1.Right of Access. You have the right to request confirmation of whether we are processing  your personal data and, if so, to receive a copy of that data, along with information about how  and why it is processed.  

7.2.Right to Rectification. If you believe that the personal data we hold about you is inaccurate,  outdated, or incomplete, you can request that we correct or update it.  

7.3.Right to Erasure (the "Right to be Forgotten"). Under certain circumstances—such as  when your information is no longer necessary for the purposes for which it was collected, or  where you withdraw consent (if our lawful basis was consent)—you can request that we delete  your personal data.  

7.4.Right to Restrict Processing. You may ask us to restrict or "pause" the processing of your  personal data in situations where you contest its accuracy or object to our use of it. If we restrict  processing, we will store your data but generally not use it until the issue is resolved.  

7.5.Right to Object. If we rely on legitimate interests as our lawful basis for processing, you  have the right to object to such processing if it affects your fundamental rights and freedoms.  You can also opt out of any direct marketing communications at any time.  

7.6.Right to Data Portability. Where we are processing your personal data based on consent or  a contract, you have the right to request a copy of the data you provided to us in a structured,  commonly used, and machine-readable format and – where technically feasible – ask us to  transmit it to another controller.  

7.7.Right to Withdraw Consent. If you have given us consent for any specific processing  activities, you can withdraw it at any time without affecting the lawfulness of processing based  on consent before its withdrawal.  

7.8.Right to Lodge a Complaint. If you believe we have violated your data protection rights,  you can lodge a complaint with a supervisory authority (for example, in the EU country where  you live or work). We invite you to contact us first so we can address your concerns directly.  

8.How you can exercise your rights  

8.1.To exercise any of the above rights, or if you have questions about your data rights in  general, you may contact us at the details set out in the "How to Contact Us" clause 10.4. We  may request specific information from you to verify your identity and process your request.  

8.2.We will respond within applicable legal timeframes. Please note that some rights may be  limited if fulfilling your request would impair the rights of others, override compelling public  interest considerations, or if we are otherwise legally or contractually required to retain the  data.  

8.3.If you believe we have failed to respect your data protection rights or if you have any  unresolved concerns, you have the right to lodge a complaint with your local data protection  authority. In particular, if you are in the European Economic Area (EEA), the United Kingdom 

or Switzerland, you may contact the supervisory authority in the country where you live, work,  or where you believe the infringement occurred.  

8.4.Additionally, you may have the right to seek a judicial remedy or compensation if you suffer  damage as a result of an infringement of applicable data protection laws. We encourage you to  contact us first so we can address your concerns directly. However, this does not limit your  ability to file a complaint or seek other forms of legal relief.  

9.Children’s Information  

9.1.Our Website and related services are not intended for individuals under the age of 18 or those  who have not reached the age of majority in their jurisdiction, whichever is higher. We do not  knowingly collect personal information from individuals who are legally considered minors. If  you learn that a minor has provided us with personal data without parental or guardian consent,  please contact us promptly. We will take immediate steps to delete the data from our records or  otherwise address the situation in compliance with applicable law.  

10.Use of Cookies  

Cookies are small text files stored on your device to make websites work more efficiently and  provide certain features or insights. Victus strives to keep cookie usage to a minimum and  transparent. However, some cookies may be placed if we enable third-party tools such as  Mailchimp or certain Webflow functionalities. Below is an overview of what cookies or similar  technologies may be active on our Website:  

10.1.Essential or Functional Cookies. These cookies are necessary for the operation and  security of our Website. They enable core functionality like page navigation, proper display,  and server balancing. Without them, the site cannot function properly. We do not seek consent  to place these cookies, as they are strictly necessary. 

● We use essential cookies from Cloudflare, which help Cloudflare manage bot traffic and  enhance security and ensure page loading performance; and essential cookies from  Webflow, which manage user sessions, ensuring the correct display of pages and  fundamental site services.  

10.2.Preference Cookies. Also known as functionality cookies, these cookies remember your  Website preferences, such as language selection or region, to offer enhanced and more  personalized features.  

10.3.Statistics (Analytics) Cookies. These cookies help us understand how visitors interact with  our Website by collecting and reporting information anonymously. They allow us to improve  site performance and user experience.  

10.4.Marketing Cookies. Marketing cookies track your online activities, typically to show you  more relevant advertisements or measure the effectiveness of email marketing or ad campaigns.  They may also be used by third parties to build a user profile across multiple sites. 

● We use MailChimp cookies, which record how users arrive at the site and interact with  signup forms and help measure campaign results. MailChimp may track form  completions or subscription success.  

Managing Cookies. You can usually configure your browser to block or delete cookies. Check  your browser’s help section for instructions. However, blocking or removing certain cookies  (especially strictly necessary ones) may affect Website functionality.  

For questions regarding our cookie usage or to modify your cookie preferences (where  applicable), please contact us using the details provided in the "How to Contact Us" clause 10.4.  

11.Other  

11.1.We may update this Privacy Notice from time to time to reflect changes in our data  practices, the services we offer, or applicable legal requirements. When we do, we will revise  the "Effective Date" at the top.  

11.2.Our Website may contain links to external websites or services that are operated by third  parties. Please note that we have no control over the content, policies, or practices of these  external sites. We encourage you to review the privacy policies of any third-party services  before providing them with your personal data.  

11.3.This Privacy Notice is an integral part of our Terms of Use, which governs your use of our  Website. In the event of any inconsistency between this Privacy Notice and our Terms of Use  regarding privacy or data protection, this Privacy Notice shall govern.  

11.4.How to Contact Us. If you have any questions, concerns, or requests regarding this Privacy  Notice or your personal information, please reach out to us using the following email: complaints@victusglobal.com. We will respond to your inquiry as promptly as possible and in  accordance with any applicable legal timeframes.

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