“Personal Data” shall mean any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing of personal data” or “Processing” shall mean any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
“Processor” shall mean a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the Company.
“Service(s)” shall have the same meaning as it is defined under the Terms and Conditions of the Company.
“We/us/our” means the Company.
“You/your/User/Client” means, jointly and severally, the individual(s) who is/are the user(s) of the Site.
Persons under the age of 18 are not eligible to use the Company services. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Site and the Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of majority, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of majority.
COLLECTION OF INFORMATION:
We collect Personal Data about you when you visit the Site or you use the Services, including the following:
Registration and use information: during the registration process the Company requires you to provide verifiable information, such as but not limited to:
The Company shall request the provision of your personal details (including name, surname in case of individuals email and any other personal data of the Subscriber that might be required from time to time) ("client information”).
The Company will process such Personal Data as may be necessary for the provision of the Services, in accordance with the Terms and Conditions of the Company as amended from time to time and which are available at the Site, and as the Company may be obliged or authorised to do by or under the applicable laws (including but not limited to, compliance with applicable prevention of money laundering and funding of terrorism legislation and requirements thereunder applicable to the Company) or in line with any data subject consent to Processing that it may obtain from time to time.
Any Processing of Personal Data carried out by the Company or any Processor appointed by it, shall be undertaken in compliance with the GDPR.
The Company shall ensure that any Processors engaged by the Company, which are located outside the EEA shall be subjected to standard contractual clauses or any other equivalent protection measures specified under the GDPR which ensure that transfers outside the EEA are subject to safeguards and protection which are equivalent to those provided to data subjects under the GDPR. The Company shall furthermore ensure that personal data is only disclosed and processed as authorised or otherwise for contractual necessity, in compliance with its legal obligations or pursuant to the Company’s legitimate interests.
Additional Client Information: The Company shall be entitled to request additional client information of the User in case when it is required for the Company to be compliant with its anti-money laundering obligations under applicable laws.
The Company may use a variety of information sources that do not violate any personal information privacy rules including sources from private, government, municipal data bases. It may also request additional information from you if it is unable to verify your identity with the personal data in hand.
Client provided information may be verified with third party providers as a measure to enhance the Users’ protection. Such verification may involve the receipt and Processing of information that will verify the Client’s identity.
Information about your account: the Company does not keep and/or store information in respect of your trades and/or history of your trades through the Site and/or your movements on the Account as all these information are stored at your private computer and/or the browser of your computer from which you access the Account and/or the Site.
Records of our discussions: All communication between the Client and the Company will be recorded and retained for reference purposes when and if required by the Company.
Information collected from Clients are primarily used for the provision of the Services in a manner that the Company deems fit to enhance the Client experience by making it safer, more targeted, efficient and effective.
The Client acknowledges and agrees that personal information provided for the provision of the Services (in the beginning and during the course of the relationship), can be used by the Company to predominantly:
The Company may communicate with its clients regularly through direct email communication and through general announcements/postings on its website. It also reaches Clients via telephone for even more direct communication for a variety of reasons including but not limited to:
The Company will contact the Client via email to confirm account opening.These email notifications are compulsory, and the Client has no option to stop receiving them.
The Company may also send other email notifications which are of a promotional or general information nature, such as news and third-party promotions, and are therefore not compulsory giving the Clients the option to stop receiving them. The option to receive or stop such email communication can be managed through the Client’s online account interface, or alternatively by contacting one of the Company’s representatives and asking them to opt-out of such email service.
The Company will treat your Personal Data as confidential, even when you are no longer a client. The Company will keep your Personal Data for as long as it is required by applicable laws. You agree, however, that the Company may disclose Personal Data without the obligation to obtain your additional approval:
to other companies in the Company’s group (Affiliates);
to anyone to whom the Company transfers or proposes to transfer either the Company’s rights or duties under the Terms and Conditions of the Company.
to any third party as a result of any restructuring, sale or acquisition of any company within the group provided that any recipient uses your information for the same purposes as it was originally supplied to the Company and/or used by the Company;
to regulators and governmental agencies, in any jurisdiction, where the Company is required to do so by Applicable Laws.
to the auditors of the Company;
to courts, courts of arbitration, or for the sake of out-of-court dispute resolution pursuant to the provisions of Applicable Laws;
to other third parties, where there is a public duty to disclose or the Company’s interests require disclosure, or where the information was previously publicly available, or at your request or in other cases, if permitted under applicable laws.
Our operations are supported by a network of computers, date from several sources, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers.
SECURITY OF INFORMATION:
Security of Client information is of outmost importance to the Company, which has adopted commercially reasonable standards to ensure that the personal information is protected. The Company uses a range of safeguards to insulate information from unauthorized access.
In any case the Company needs the Client’s contribution to achieve the high level of security and protection it aspires to reach. Without the Client’s password protection, intrusion measures are only that much effective, and the Company asks its Clients to protect their password and not divulge or expose such information to anyone. The Company’s representatives will never ask you for your password and neither will any email communication received from the Company will ever ask you to enter or provide such password information. Any email received requesting such information should be treated as suspicious and unauthorized. The Company would like to be informed of such unauthorized emails and asks its Clients contact customer support via contact form of the site.
Where a Client provides a third person with the password to access the account, the Client acknowledges that the account is at risk and takes full responsibility for any actions the third party takes when accessing the account. If a Client believes that such access was never granted intentionally, and that the third party obtained unauthorized access to the account, the Company asks the Client to change the password immediately and contact the Company. If the Client is unable to change password by accessing your account, he/she can immediately contact the Company, inform them of the inability, and have one of the customer support staff reset the password.
YOUR RIGHTS AND PRIVACY CHOICES:
As a data subject, you are entitled to a number of rights under the GDPR. These rights include the right to:
Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it;
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Such rights may be exercised by contacting support via contact form on the site. Requests must be made by the relevant data subject and will be handled by us in accordance with the GDPR.