CONNECTEE OÜ (hereafter “Connectee”, “we,” or “us”), we aim to make privacy structures less complicated. This document explains how we handle your information when you interact with our Services, use our Platform or visit our Website. Any terms you see capitalized here have the same meaning as in our Terms of Use, unless we explicitly say otherwise. We collect Personal Data only as far as needed to provide, maintain, and improve our Services. Anything beyond that we only process it if the law permits or requires.
By using our Services, creating an account, or otherwise showing interest, you agree to share with us, and our parent/subsidiary/affiliate network, the necessary Personal Data. Your continued use of our Services is our mutual handshake: you trust us with your data, and we promise to handle it responsibly.
We might handle your data alone or alongside others – banks, payment providers, KYC/AML partners, crypto custodians, CRM systems, and other necessary tools to make the platform work seamlessly.
1. Details of the controllers
CONNECTEE OÜ, company code: 14891451, address: Narva mnt. 7, 10117 Tallinn, Estonia, email: office@connectee.io.
2. What we collect
To operate, identify, and comply with regulations, we need certain data from you. This can include – but is not limited to:
3. Why we collect it
Your data is not just a number in a database. Here’s how we put it to work:
4. Legal basis for collection
We process Personal Data under EU rules – GDPR, Lithuanian law, and ePrivacy rules for cookies/online identifiers. Our legal grounds include:
5. AML/CTF and Travel Rule
We process certain identification and transaction data to meet anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions compliance. It’s not optional – we can’t provide Services without it. Missing or incorrect info may result in delays, blocks, or refusals to process transactions. We use the minimum required data, apply robust security measures, and retain records only as long as legally required.
6. Who might get your data
Your Personal Data sometimes leaves our servers – for good reasons we may share it with:
7. International data transfers
We operate globally. This means your data sometimes travels – servers, computers, cloud platforms, wherever our partners happen to be. Wherever your data goes outside the EEA, we make sure it’s safeguarded according to law. Usually one of two ways:
8. How long we keep your data
Here’s how we handle it:
9. Guarding your data: security measures
We implement technical wizardry and organizational safeguards – encryption, firewalls, regular audits, access controls, and the works. We also review our procedures constantly. Our goal is clear: keep your information safe and sound, while learning and adapting along the way.
10. Your rights: what you can do
The law gives you certain rights over your Personal Data. A quick rundown:
Important: if you provide incomplete or incorrect info, it might delay or prevent us from fulfilling your request.
We respond within one month – usually sooner. Sometimes, for tricky cases or multiple requests, we may need up to two months. If a request is excessive or manifestly unfounded, we might refuse to proceed, but we’ll explain why.
Please note that these rights are not absolute, and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations (such as AML/CTF regulations).
11. Automated decisions and profiling
We use risk scoring, profiling, blockchain analytics, and fraud signals. These tools help us assess transaction and account risk in a fair and consistent way. Any decision that could seriously affect you – like blocking a transaction or asking for extra verification – is never left entirely to a machine. A trained human reviews these cases. You can request a human review of any automated decision. We promise to consider it and explain outcomes, as much as legally possible.
Why we do this: lawful obligations, AML/CTF compliance, and our legitimate interest in preventing fraud and keeping the platform secure.
12. Cookies
We use Cookies and Pixels to see how you interact with us, customize your experience, measure performance, and keep things safe. Not into cookies? Fine. You can disable them in your browser. Just know that doing so might prevent you from using some Services. For more details, check our Cookies Policy page.
13. Complaint handling
We have a no-cost complaint channel: complaints.it@cleverlee.com. To make this process easier, please refer to the Complaints Handling procedure page.
14. Children’s privacy
We don’t work with anyone under the age of 18. If we find out we’ve collected data from anyone under the age of 18 without parental consent, we delete it promptly.
15. Changes to this Privacy Policy
This Privacy Policy exists in Estonian and English. If there’s ever a conflict between versions, the English one usually takes precedence, unless the law says otherwise. We may update this page from time to time. We’ll keep you up-to-date by email, or a clear notice on the Platform. Changes take effect the moment this page is updated.
If you don’t agree with the new terms, the easiest route is to stop using the Services. Continuing to use them – that’s your quiet nod of acceptance.
16. Unsubscribe
The email address you gave us – whether signing up for news, communication channels, or opening an Account – may receive updates, info about your Orders or Transactions, and occasionally news about our products and offers.
Want out of marketing emails? Hit the unsubscribe link at the bottom. It won’t affect essential emails, like password resets, transaction confirmations, or critical service notices.
17. Contact information
For any questions, clarifications, or concerns about your data or this Privacy Policy:
By using our Services, creating an account, or otherwise showing interest, you agree to share with us, and our parent/subsidiary/affiliate network, the necessary Personal Data. Your continued use of our Services is our mutual handshake: you trust us with your data, and we promise to handle it responsibly.
We might handle your data alone or alongside others – banks, payment providers, KYC/AML partners, crypto custodians, CRM systems, and other necessary tools to make the platform work seamlessly.
1. Details of the controllers
CONNECTEE OÜ, company code: 14891451, address: Narva mnt. 7, 10117 Tallinn, Estonia, email: office@connectee.io.
2. What we collect
To operate, identify, and comply with regulations, we need certain data from you. This can include – but is not limited to:
- Full name, date and place of birth, personal ID numbers (if applicable), nationality, mailing address, phone number, email;
- Government-issued IDs (passport, national ID, etc.);
- Photos or videos, sometimes required by our KYC partners;
- Employment or professional info;
- Purpose of account, projected transactions, financial info, source of funds;
- Payment data (cards, bank accounts, etc.);
- Digital asset wallet addresses;
- Usage data: IP address, browser/device info, pages clicked, timestamps, device identifiers, network info;
- Cookies and other tracking information;
- Order/transaction details (crypto quantity, transaction metadata);
- Location info;
- Travel Rule data for crypto transfers (originator/beneficiary info, accounts, IDs);
- QR codes or barcodes scanned through your device.
3. Why we collect it
Your data is not just a number in a database. Here’s how we put it to work:
- To verify your identity;
- To run and improve our Services, troubleshoot, and ensure smooth performance;
- To manage your account and access;
- To execute contracts and meet legal obligations;
- To reach out via email, SMS, push notifications, or phone with updates, security alerts, or relevant info;
- To share news, offers, or information about our products or services;
- To handle customer support requests;
- For business transfers, mergers, acquisitions, or restructuring, where data might be part of assets;
- To analyze trends, improve marketing campaigns, and enhance your user experience;
- To comply with legal obligations, including Travel Rule transfers of crypto-assets;
- For marketing, modeling, or targeting purposes – if you’ve opted in.
4. Legal basis for collection
We process Personal Data under EU rules – GDPR, Lithuanian law, and ePrivacy rules for cookies/online identifiers. Our legal grounds include:
- Contract: running accounts, onboarding (KYC/KYB), and service execution;
- Legal Obligation: AML/KYC, sanctions screening, Travel Rule compliance;
- Legitimate Interests: fraud prevention, platform security, operational efficiency;
- Consent: marketing communications, analytics cookies – withdrawable anytime.
5. AML/CTF and Travel Rule
We process certain identification and transaction data to meet anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions compliance. It’s not optional – we can’t provide Services without it. Missing or incorrect info may result in delays, blocks, or refusals to process transactions. We use the minimum required data, apply robust security measures, and retain records only as long as legally required.
6. Who might get your data
Your Personal Data sometimes leaves our servers – for good reasons we may share it with:
- Third parties who help us run and expand the Services, or make your experience smoother. Think banks, crypto custodians, payment processors, KYC/AML partners, marketing service providers, software hosts, or maintenance personnel;
- Other obliged entities when required for Travel Rule compliance;
- Our affiliates and parent/subsidiary companies during mergers, acquisitions, or internal transfers of assets;
- Professional consultants – auditors, lawyers, tax and finance advisors;
- Public interactions – if you share info in public forums or features, others may see it and even redistribute it;
- Business partners – but only when you’ve opted-in or it’s part of offering you a Service.
7. International data transfers
We operate globally. This means your data sometimes travels – servers, computers, cloud platforms, wherever our partners happen to be. Wherever your data goes outside the EEA, we make sure it’s safeguarded according to law. Usually one of two ways:
- The destination country has an EU adequacy decision – basically, a “we trust their privacy laws” stamp;
- We rely on Standard Contractual Clauses from the European Commission – formal agreements binding recipients to protect your info.
8. How long we keep your data
Here’s how we handle it:
9. Guarding your data: security measures
We implement technical wizardry and organizational safeguards – encryption, firewalls, regular audits, access controls, and the works. We also review our procedures constantly. Our goal is clear: keep your information safe and sound, while learning and adapting along the way.
10. Your rights: what you can do
The law gives you certain rights over your Personal Data. A quick rundown:
- Access: Ask if we process your data and get a copy of what we hold;
- Information: Want to know how we treat your data? Drop us a message, we will be happy to explain;
- Correction: Spot something wrong? Tell us, and we’ll fix it;
- Erasure: You can ask us to delete your data – unless law says we can’t;
- Restriction: Pause the processing of your data temporarily;
- Objection: Don’t like how we’re using it? You can object;
- Data portability: Take your data elsewhere;
- Complaint: Unsatisfied? Complain to the State Data Protection Inspectorate (VDAI);
- Consent withdrawal: Previously said yes? You can change your mind.
Important: if you provide incomplete or incorrect info, it might delay or prevent us from fulfilling your request.
We respond within one month – usually sooner. Sometimes, for tricky cases or multiple requests, we may need up to two months. If a request is excessive or manifestly unfounded, we might refuse to proceed, but we’ll explain why.
Please note that these rights are not absolute, and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations (such as AML/CTF regulations).
11. Automated decisions and profiling
We use risk scoring, profiling, blockchain analytics, and fraud signals. These tools help us assess transaction and account risk in a fair and consistent way. Any decision that could seriously affect you – like blocking a transaction or asking for extra verification – is never left entirely to a machine. A trained human reviews these cases. You can request a human review of any automated decision. We promise to consider it and explain outcomes, as much as legally possible.
Why we do this: lawful obligations, AML/CTF compliance, and our legitimate interest in preventing fraud and keeping the platform secure.
12. Cookies
We use Cookies and Pixels to see how you interact with us, customize your experience, measure performance, and keep things safe. Not into cookies? Fine. You can disable them in your browser. Just know that doing so might prevent you from using some Services. For more details, check our Cookies Policy page.
13. Complaint handling
We have a no-cost complaint channel: complaints.it@cleverlee.com. To make this process easier, please refer to the Complaints Handling procedure page.
14. Children’s privacy
We don’t work with anyone under the age of 18. If we find out we’ve collected data from anyone under the age of 18 without parental consent, we delete it promptly.
15. Changes to this Privacy Policy
This Privacy Policy exists in Estonian and English. If there’s ever a conflict between versions, the English one usually takes precedence, unless the law says otherwise. We may update this page from time to time. We’ll keep you up-to-date by email, or a clear notice on the Platform. Changes take effect the moment this page is updated.
If you don’t agree with the new terms, the easiest route is to stop using the Services. Continuing to use them – that’s your quiet nod of acceptance.
16. Unsubscribe
The email address you gave us – whether signing up for news, communication channels, or opening an Account – may receive updates, info about your Orders or Transactions, and occasionally news about our products and offers.
Want out of marketing emails? Hit the unsubscribe link at the bottom. It won’t affect essential emails, like password resets, transaction confirmations, or critical service notices.
17. Contact information
For any questions, clarifications, or concerns about your data or this Privacy Policy:
- Email: support@connectee.com
- Address:
- Email: office@connectee.io.
- Address: Narva mnt. 7, 10117 Tallinn, Estonia.