Privacy Notice

    This Privacy Policy provides you, the subscriber to the Site (“you”), with the terms in respect to the use and subscription to the website of the Company, namely Safari (the “Site”) for the provision of the Services (the term “Services” shall bear the same meaning as the T&Cs of the Company, available on the Site) It also governs without limitation the provision and use of your personal data and information in relation to the provided Services.

As a user, by entering into an agreement with the Company, setup your account, access the Site and make use of the Services, you accept and consent to this Privacy Policy, and by doing so you consent to the use and disclosure of your personal information by the Company as provided for herein.

Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Policy.

“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.

The Company has developed this Privacy Policy, in accordance with the requirements set out in the EU 2016/679 General Data Protection Regulation (the “GDPR”), to explain how we may collect, retain, process, share and transfer your Personal Data when you subscriber to the Site and/or when you receive the Services by the Company. 

Unless it is expressly provided in this Privacy Policy, the Company will not sell, lease, or otherwise distribute any of the User’s information to third parties for marketing purposes unless the User explicitly consents to such sale, lease or distribution. 

The Privacy Policy may be amended from time to time at the Company’s sole discretion and as required by applicable laws and regulation. The amended version of the Privacy Policy will be posted on the Site and will be deemed as received by all Users. The Company shall not be obliged to send a notification to you in respect of any amendment and/or change of this Privacy Policy and to this end, it is your responsibility to check the Privacy Policy regularly and to be aware of any such amendment or changes.  Should you not agree to the Privacy Policy or any updated Privacy Policy, you are immediately deemed to have stopped using the Services and shall bear any consequences for not acting in accordance. Your continued use of the Services after such updates, changes, and/or modification, shall constitute your acceptance of such terms of the Privacy Policy.

This Privacy Policy does not cover any third-party websites whose access and use is governed by their own privacy policies. The Company may provide links to such websites and the User acknowledges that the provision of such links for access to such third-party websites, do not make the Company responsible for their operations and use of personal information practices. The Company strongly recommends to its Users to carefully review the privacy policies of such third party websites prior to submitting any personal information.

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.

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”). 

To the extent that the Company, as a controller and a Processor, processes any information that constitutes personal data, in the provision of the Services to the User, the Company undertakes to process such data in accordance with the provisions of the GDPR, in the manner and for the purposes indicated in this Privacy Policy, and/or as the Company may disclose on the Site, or notify you from time to time.

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. 

You hereby agree to the Processing of Personal Data relating to you, in accordance with the provisions of this Privacy Policy in relation to the Processing of personal data as described above, as may be required by or under the Applicable Laws.

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. 

Particularly, the Company will also use small data files such as cookies and place them on the Client’s device in an effort to enhance and personalize the Client experience, as well as to strengthen the security measures taken to protect the Client’s account by mitigating the risk of fraud. The Company has developed its own Cookie Policy that can be accessed via the Site by all visitors (both registered users and guests). All the Users of the Site have the right to accept or decline the Cookie Policy. The Company cannot guarantee that the browsing of its website and/or the access to the Services will be seamless and problem free if the Cookie Policy is declined.

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. 

All information procured during the account opening process, including the information used for verification of the information, the device specific and location information collected during the accessing of the Site, the Client account preferences and any correspondence between the Client and the Company will constitute the Account Information that relate to the Client for the purposes of this Privacy Policy.

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.

The Client acknowledges and agrees that acceptance of this Privacy Policy grants the Company the Client’s consent to transfer the Personal Data outside the EEA (in a jurisdiction that may afford less privacy).

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.

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.