As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates.
This Policy is designed to help you to understand what kind of personal data we collect and how we process and use such data. It also sets out your rights in relation to how we look after your personal data.
We act as a data controller for the personal data we hold about you. In case we will be an appointed representative of another entity in relation to our regulated activities, we and the said entity will act as joint controllers of your personal data.
Personal data we collect
We collect your personal data typically when you register for our services, make an investment, or otherwise interact with us. Below are examples of the categories of the data we collect on you.
For the most part, you may visit our websites without having to identify yourself. However, certain technical information is normally collected by us as a standard part of our services. This information relates to your IP-address, information about your device and other technical information your browser provides us with, and metadata about your use of our websites (such as when you use the website and how you interact with content). If you call us, additional information such as your telephone number may be saved as a standard part of that communication.
Information you provide us
To allow us to provide you with the products and services you have requested, or to communicate with you, we may ask you to provide us with certain information such as your name, date of birth or age, email address, home or postal address, or financial situation.
In registering for our services, you create user names, passwords and other credentials that we use to authenticate you and to validate your actions. You will also be required to send us copies of your personal identity documents or details about your financial status.
You may also indirectly provide us with information through your consents, preferences and feedback.
Your transactions with us
We collect details of the queries or requests you have made, the products and services provided (including delivery details), Investments details (including payments made, bank account details, your digital wallet details, billing address, credit checks and other such financial information), details of agreements between us, records of contacts and communications, information and details relating to the content you have provided us with and other such transactional information. We may, in accordance with applicable law, record your communication with our customer care or with other similar contact points.
Certain services may involve the use of your location data. Use of your location data is, however, subject to your prior consent for each service.
Personal data obtained from third parties
We may obtain personal data about you from third party sources such as social media analytics, and other licensed financial services companies.
Why we need your personal data
We collect and process your data for one or more of the following grounds:
To fulfil our contract with you. We use your personal data as it is necessary to provide you with our products and services in line with our overall contract. We process and use your personal data to provide you with a personalized service and the product or service you have requested, to fulfil your other requests, process your investment(s), and as otherwise may be necessary to perform or enforce the contract between us.
We are required to do so by law or regulation. We are required by law and regulations to process and store some of your data in order to fulfil our regulatory obligations. We may capture and share your personal data with organizations who can confirm your identity and provide information necessary to prevent fraud or other financial crimes. We may also be required to share your personal details where requested to by legal authorities or other financial regulators.
There is a substantial public interest in doing so.
You have provided us with your consent. Where you have given your consent, we will process your data in accordance with the permission you have given us and this Policy. You may withdraw your consent at any time.
Our other legitimate interests in using your data
Taking into account your interests, we process your personal data for the following purposes:
To verify your identity and administer your account. We process and use your personal data to ensure the functionality and security of our products and services, to identify you and the instructions you give us, and to prevent and detect fraud and other misuses.
Development of products and services. We process and use your personal data to develop our products and/or services. However, for the most part we only use aggregate and statistical information in the development of our products and services, and not data directly identifiable to you. We may also process and use your personal data to personalize our investments offerings and to provide you with service more relevant to you, for example, to make recommendations and to display customized content. We may combine personal data collected in connection with your use of a particular product and/or service with other personal data we may hold about you.
Communicating with you and marketing. We process and use your personal data to communicate with you, for example, to provide information relating to our products and/or services you are using or to contact you for customer satisfaction queries. We may process and use your personal data for marketing. Marketing purposes may include using your personal data for personalized marketing or research purposes in accordance with applicable laws, for example, to conduct market research and to communicate our products, services or promotions to you via our own or third parties’ electronic or other services. When contacting you for the purpose of marketing, we will take into account any preferences you have expressed to us, including any desire not to receive marketing.
Profiling. We may process and use your personal data for profiling for such purposes as targeted direct marketing and improvement of our products or services. We may also create aggregate and statistical information based on your personal data. Profiling includes automated processing of your personal data for evaluating, analyzing or predicting your personal preferences or interests in order to, for example, send you marketing messages concerning products or services best suitable for you.
Tracking remuneration due to us or our partners. We use your personal data to ensure that we receive the remuneration or commission due to us from, or payable by us to, any third-party product providers or distributors.
Insurance. We process personal data as required to enable us to periodically obtain insurance cover for our business and to notify and process claims with our insurers.
Business continuity. In the event of an interruption or cessation of our business, we need to ensure that we can implement our business continuity procedures (for example, we may need to rebuild our IT systems) or wind down planning to protect your interests. This may involve a transfer of your personal data to a third party (see below).
Transfers of your personal data
We will transfer your personal data to the third parties noted below, or as obligated by law.
In relation to our regulated activities we may be an appointed representative of a licensed entity, Accordingly, such licensed entity will be a joint controller of your personal data.
Sponsors. We may transfer your personal data to our sponsors and business partners managing the products or services you invested in.
Material service providers. We will transfer your personal data to the other third parties who shall provide us with a material services.
Generic service providers. We may transfer your personal data to third parties who control or process personal data on our behalf to enable the efficient technical and logistical provision of our services. These service providers supply us with cloud data storage, data security services, customer relationship management software, and support ticketing services. We may substitute a technical or logistical service provider from time to time. Such parties are generally not permitted to use your personal data for any other purposes than for what your personal data was collected, and we require them to act consistently with applicable laws and this Policy as well as to use appropriate security measures to protect your personal data.
Event driven transfers. We may transfer your personal data to third parties in certain events where is it necessary to protect your, or our, legitimate interests. This includes the cessation, sale or transfer of our business; civil or criminal legal, or regulatory, proceedings; or insurance claims.
International transfers. Our products and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred outside the country where you use our services. We will only transfer data in such circumstances if the level of data protection in that jurisdiction is deemed adequate, or if there are appropriate safeguards in place to protect your privacy.
How long do we keep personal data?
We will only keep your personal data for so long as it is reasonable for us to do so, depending upon the nature of the data and our processing, and the grounds upon which we collected it. In general, we will delete redundant account information within 21 days of our relationship ending. However, we are obliged to keep certain records of our relationship to comply with the applicable laws and regulations, in which case we will instead restrict access through our archiving processes. Subject to any actual or potential legal claim, the maximum time that we envisage retaining any of your information is seven years of our relationship ending, after which time it will be destroyed.
Information we use for marketing purposes will be kept by us until you notify us that you no longer wish to receive this information. If you do notify us that you no longer wish to receive marketing information we will keep an encrypted version of your contact information to ensure we respect your wishes.
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
Our Policy Toward Children
This Site is not directed to children under 18 years of age. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at email@example.com. If we become aware that a child has provided us with personal information, we will delete such information from our files.
We are concerned with safeguarding your information. We employ a variety of measures designed to protect your information from unauthorized access and disclosure. However, we do not promise that your personal information or private communications will always remain private and secure.
Please note that no computer system is completely immune from intrusion. We cannot guarantee the absolute security or confidentiality of information transmitted to us and you hereby acknowledge and assume the risks associated with transmitting the information.
What are your rights?
You have the right to request information and access to the personal data we hold about you.
You also have the right to request that we correct or delete any incomplete, incorrect, unnecessary or outdated personal data we hold on you. However, we cannot delete such personal data that is necessary for compliance, our binding legal obligations or if the personal data must be retained according to applicable laws, or is required for the exercise or defense of a legal claim.
In case you consider your personal data collected by us to be inaccurate but you do not wish your personal data to be deleted; if we have used your personal data unlawfully; or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.
You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Further, where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.
In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this Policy. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you.
Please note that we may need to identify you and to ask for additional information in order to be able to fulfil your above requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.
How to contact us. If you wish to contact us, please send an email to firstname.lastname@example.org.
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Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
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If you want more information about how cookies operate, or how to manage them, please visit About Cookies.
Changes to this Policy. We may change this Policy from time to time. You should check this Policy occasionally to ensure you are aware of the most recent version.
This Policy was last updated on July 17, 2018.