The Client’s Personal Data
To open a demo or live account, the Company will need certain information (Personal Data) about the Client. The Personal Data that is collected by the Company may include:
- Information provided on applications and other Company forms, such as name, address, date of birth, occupation, and personal mobile phone number;
- Financial information such as income, assets, investment experience;
- Documents provided to confirm identity, such as passport, utility bills, and/or bank statements or company incorporation information;
- Payment documents: money transfer orders, bank statements, bank card copies, etc.
Use of Personal Data
The Company may use a Client’s Personal Data for one or more of the following purposes:
- to confirm the Client’s identity;
- to process trading and non-trading operations;
- to carry out the company’s anti-money laundering policy;
- to inform the Client of Company products or services that may be of interest to the Client;
- to provide other services that are relevant to the Client’s business relationship with the Company;
- to keep a correct database of the Client’s account data;
- to analyze statistical data to provide Clients with the most suitable products and services.
Our Company Partners, Affiliates, and Business Introducers maintain the privacy of your information to the same extent the Company does in accordance with this policy. Information may also be provided to non-affiliated companies, providing technological, payment, professional, legal, and accounting services. Non-affiliated companies that assist the Company in providing services to you are required to maintain the confidentiality of such information and to use your personal information only in the course of providing such services for the purposes that the Company dictates and within the ambit of the applicable law.
We have a legal duty to keep records of the aforesaid details for a period of at least 5 years, the aforesaid period shall be calculated after you have been accepted as a client in accordance with our Client Agreement or after the termination of our business relationship.
The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. The retention of your personal information will be subject to periodic review. We may keep an anonymized form of your personal information, which will no longer refer to you without time limits, to the extent that we have a legitimate and lawful interest in doing so.
Cookies are small text files sent by a web server and stored on a visitor’s browser which are read later by the server when the visitor returns to the site. Cookies store information such as passwords (encrypted), usernames, shopping cart, certain preferences, etc. allowing visitors to visit sites repeatedly without having to enter the same information over and over. Cookies are not used to determine the personal identity of anyone visiting the site.
If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to have your computer notify you each time a cookie is sent to it, and thereby give yourself the choice whether to accept it or not. However, this may impair the quality of the services that we provide to you in relation to your account The client agrees and acknowledges that the company may use and collect existing or further information or both to treat you fairly, and to understand your financial objectives and to ensure that relevant services are appropriate to your profile as well as to improve the services we are providing to you and to inform you of additional products, new services, promotional offers or any other marketing information. Alternatively, you may wish to visit http://www.aboutcookies.org/, which contains comprehensive information on how to manage cookies on a wide variety of desktop browsers.
If you use our web services without blocking cookies, you are actually consenting to the cookies.
The Company may convey the Client’s Personal Data to associated or affiliated companies, auditors, agents (including payment agents), banks or other authorized organizations or persons (“Authorized Persons”) for the sole purpose of processing the Client’s trading and non-trading instructions. The Company guarantees that all Authorized Persons will adhere to the terms of this Policy and take all necessary steps to protect the Client’s Personal Data.
Disclosure of Information to external parties
Under the Agreement between us, we have the right to disclose Your Information (including recordings and documents of a confidential nature, card details) in certain circumstances. According to the Agreement between us, Your Information may be disclosed:
(a) where required by law or a court order by a competent Court;
(b) where requested by any regulatory authority having control or jurisdiction over us or you or our associates or in whose territory we have Clients or Providers, as applicable;
(c) to relevant authorities to investigate or prevent fraud, money laundering or other illegal activity;
(d) a Broker so as to execute your Instructions or Orders and for purposes ancillary to the provision of our Services to you as our Client;
(e) to credit reference and fraud prevention agencies, third authentication service providers, banks and other financial institutions for credit checking, fraud prevention, anti-money laundering purposes, identification or due diligence checks of you. To do so they may check the details you supplied against any particulars on any database (public or otherwise) to which they have access. They may also use your details in the future to assist other companies for verification purposes. A record of the search will be retained by us;
(f) to our professional advisors provided that in each case the relevant professional shall be informed about the confidential nature of such information and commit to the confidentiality herein obligations as well;
(g) to other service providers who create, maintain or process databases (whether electronic or not), offer record keeping services, email transmission services, messaging services or similar services which aim to assist us collect, storage, process and use Your Information or get in touch with you or improve the provision of our Services or activities under the Agreement between us;
(h) to a Trade Repository or similar;
(i) to other service providers for statistical purposes in order to improve our marketing, in such a case, the data will be provided in an aggregate form;
(j) to market research call centers that provide telephone or email surveys with the purpose to improve our Services or activities, but only contact details;
(k) where necessary in order for us to defend or exercise our legal rights to any court or tribunal or arbitrator or Ombudsman or governmental authority, as the case may be;
Use of Information
Security and Protection
The Company takes the issue of security very seriously and takes all possible measures to ensure the safety of your confidential information, including adhering to strict standards for the internal use of confidential information and using leading data storage technology. When making a payment with a credit/debit card, you will be transferred to the site of the processing center where you will fill out a form. To prevent the unauthorized use of your credit/debit card, your card information is transmitted to the Company in shortened form and through a secure server.
Our services are not available for users under the age of 18 (or the age of legal consent for the jurisdiction the user is located in) (a “minor”). We do not knowingly collect personal information from or about minors. If you are a minor, you should not download or use any of our services nor provide any personal information to us.
If we become aware that a minor has shared any information with us, we will delete such information. If you have any reason to believe that a minor has shared any information with us, please contact us at email@example.com.
The following disclosure about your rights as EU resident is made pursuant to the European General Data Protection Regulation (GDPR):
Edit and delete of Information
You may inform the Company at any time that Your Information has changed or that you wish the Company to delete information we hold about you by emailing us at firstname.lastname@example.org. We will change or delete Your Information in accordance to your instructions, except to the extent that we are required to hold Your Information for regulatory or legal purposes, to provide you with the Services you have requested or to maintain adequate business records.
Receiving promotional materials:
You can request to opt out from promotional emails by clicking on the “unsubscribe” or “opt-out” link in the promotional e-mails we send you. You will still receive operational emails as needed by regulatory or other purposes.
In case you do not want to get any promotional emails or other promotional communications you should send a request to email@example.com.
Right of Access and Portability
Under the GDPR, as amended or replaced form time to time, you as a natural person have the right to obtain a copy of any personal information which we hold about you and to advise us of any perceived inaccuracy. To make a request, please contact us, verifying your identity and specifying what information you require. You may contact us via e-mail at firstname.lastname@example.org.
Right of Objection
Have the right to object to have your personal information disclosed to our affiliates or other third parties as described in this Policy. You may contact us via e-mail at email@example.com. We will review and fulfill your request except to the extent that we are required to process your Information for regulatory or legal purposes, to provide you with the Services you have requested or to maintain adequate business records.
The right to complain
Have The right to complain about the use of their personal information to the Supervisory Authority.
Our legal basis for using your personal information
For other justifiable grounds, including legal obligation and legitimate interests: We process your personal information where necessary for the Company to comply with legal and regulatory obligations we are under, and also where it is necessary for legitimate interests we have in conducting our business. These include without limitation:
- Learning about your interests and preferences to contact you with information that is relevant to you and helping us maintain promotional communications with you.
- Analyzing and continually improving the Site and our services and helping us pilot test versions of the Site internally to develop new features and ensure the efficient running of our services.
- Detecting and reducing fraud and credit risk.
Company is not responsible for third party websites which are linked to company websites and has no control of the use or the protection of the information. Each time that a client is required to provide information for a link website which is a third party website the information is recorded by the third party and under his responsibility.
By visiting and/or accessing Company related websites and applications, you consent to Company to collect, maintain and use your personal information as per this policy
In case of further questions of information, requests or complaints do not hesitate to contact us firstname.lastname@example.org
Update date: May 2018