Personal Data Protection Policy

(updated and effective from July 01, 2023)

T&C Investment Holding JSC (“T&C Group” or “We” or “Company” for short) always prioritizes security and the protection of personal data provided by Customers (website visitors, or individuals engaged in transactions with us) and Employees. This Personal Data Protection Policy outlines the purposes and methods by which we process Personal Data, as defined below, and provides information about the rights of the Data Subjects.

By sending or providing Personal Data, whether directly or through any third party, Customers/Employees have consented to T&C Group and related parties involved in the provision of services, recruitment, and communication to use such data in accordance with the provisions of this Personal Data Protection Policy. This Personal Data Protection Policy is considered a notice from T&C Group to relevant data subjects regarding our processing activities.

Our responsibility is to ensure transparency of information and we will regularly review our Personal Data Protection Policy. We may supplement, update, or adjust the terms outlined in this Personal Data Protection Policy where necessary, by updating a new version on our website. By continuing to interact with T&C Group or using T&C Group’s services thereafter, Customers/Employees accept such supplements, updates, and adjustments.

T&C Group collects Personal Data for the purpose that agreed by the parties only. During our operations, T&C Group may receive various types of Personal Data, including but not limited to the following data (“Personal Data”):

  • Personal information and contact details as shown on the citizen’s identity card and business card;
  • Financial information such as salary, other sources of income and investments, allowances, individual tax records, and other tax-related information;
  • Any personal identification information of the customer/employee, their spouse, and family members.

In addition to Personal Data that is directly provided to T&C Group, we may collect Personal Data of customers from other sources, including but not limited to: meetings, events, seminars, conferences, social networks, or dialogues organized, sponsored, or attended by T&C Group, and/or from records stored on the website.

At any given time, Customers/Employees may voluntarily provide additional Personal Data to T&C Group beyond the information requested by T&C Group (e.g., through the T&C Group website). By providing such information to T&C Group for any reason, Customers/Employees allow T&C Group to use that information in the manner outlined in this Personal Data Protection Policy or as stated at the time Customers/Employees share that information. Furthermore, Customers/Employees are kindly requested not to provide sensitive data such as racial or ethnic origin, political opinions, religious beliefs, health, genetic, or biometric data.

We do not collect Personal Data from anyone under 18 year old. If Customers/Employees have provided (or will provide) Personal Data about family members, spouses, or other dependents under the age of 18, customers/employees confirm that they have explained to these individuals about their Personal Data being provided to us and being processed by us. Furthermore, Customers/Employees certify that they have obtained the consent of these individuals for us to process their Personal Data (including providing and transferring data) in accordance with this Personal Data Protection Policy.

Customers/Employees understand and agree that providing their Personal Data to T&C Group (including and not limited to the information that T&C Group has collected before, during, and after Customers/Employees accept this Personal Data Protection Policy) constitutes full consent from Customers/Employees for T&C Group to use Personal Data throughout the process of receiving and processing Personal Data, starting from the time T&C Group receives the information until a request to terminate data processing from Customers/Employees.

We encourage Customers/Employees to carefully read these contents and regularly check for any changes that the company may make in accordance with the provisions of this Personal Data Protection Policy.

By using any service, product, or accessing any electronic platform, application, or device of T&C Group, or being connected to T&C Group in any manner, Customers/Employees accepts the entirety of this Personal Data Protection Policy. Customers/Employees agrees and commits to apply, cooperate with, and adhere to the T&C Group’s Personal Data Protection Policy.

T&C Group’s commitment to implementing Personal Data Protection.

  1. This Personal Data Protection Policy applies to all T&C Group’s Customers/Employees. Once accepted by Customers/Employees (in any form), this Personal Data Protection Policy constitutes an agreement between Customers/Employees and T&C Group regarding Personal Data in the establishment, maintenance, and development of relationships and transactions between Customers/Employees and T&C Group.
  2. T&C Group collects, processes, and stores Personal Data of Customers/Employees in accordance with legal regulations and/or contracts, agreements, documents entered into between Customers/Employees and T&C Group, and/or for recruitment purposes, the purpose of providing products, services to customers, or for research, development, and improvement of the quality of products and services provided to our Customers.
  3. Depending on T&C Group ‘s role in each specific situation as (i) the Data Controller, (ii) the Data Processor, or (iii) the Data Controller and Processor, T&C Group will exercise the respective rights, responsibilities, and principles for processing Personal Data in accordance with current legal regulations.
  4. This Personal Data Protection Policy shall take precedence in the event of any conflict or inconsistency with any agreements, terms, and conditions governing the relationship between Customers/Employees and T&C Group, whether entered into before, on, or after the date Customers/Employees accept this Personal Data Protection Policy.
  5. All rights and obligations of T&C Group and Customers/Employees under this Personal Data Protection Policy shall not replace, terminate, or alter but shall concurrently be the rights and obligations that the Company and Customers/Employees currently have in any document, and no provision of this Personal Data Protection Policy implies the restriction or elimination of any rights or obligations among the parties that have been established.
  6. This Personal Data Protection Policy governs how T&C Group protects the Personal Data of Customers/Employees during the Customer’s use or interaction with the Company’s products, electronic pages, or services.
  7. T&C Group strictly prohibits officers and employees at all levels and positions from engaging in any behavior involving the handling, leakage, or dissemination of Personal Data of Customers/Employees beyond the purposes specified in the Personal Data Protection Policy and in violation of the legal provisions on personal data protection. Any violation of the Personal Data Protection Policy will be dealt with severely.

For any questions related to the Personal Data Protection Policy, please send an email to us at