1. INFORMATION WE COLLECT
The following Personal Data may be collected from Clients depending on the product and/or service the Company provides to him:
(a) Contact details such as the Client’s name, e-mail address and phone number.
(b) Identification details such as the Client’s identification or passport number.
(c) Biographical and demographic data such as gender, age, ethnicity, education, occupation, the Client’s financial trading experience and whether he has a prominent public function status (PEP).
(d) Financial information such as the Client’s income status, bank account number and account details, tax information and other financial information.
(e) Information relevant to the services that the Company provides to the Client such as the Client’s transactions and communication records with the Company.
(f) Information in relation to criminal convictions and offences to the extent required and/or permitted by applicable law.
(g) Your marketing preferences.
2. INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE OUR SERVICES
When you access or use our Services, we automatically collect information about you, including:
a) Usage Information: If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the Website, we may collect such information into a file specific to you.
b) Log Information: We log information about your use of our Website, including your browser type and language, access times, pages viewed, your IP address and the Website you viewed before navigating to our Website.
c) Device Information: We may collect information about the device you use to access our Services, including the hardware model, operating system and version, unique device identifier, phone number, International Mobile Equipment Identity ("IMEI") and mobile network information.
d) Location Information: With your consent, we may collect information about the location of your device to facilitate your use of certain features of our Services, determine the speed at which your device is traveling, add location-based filters (such as local weather), and for any other purposes.
e) Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to you. A "cookie" is a small data file transferred to your computer’s hard drive that allows a Website to respond to you as an individual, gathering and remembering information about your preferences in order to tailor its operation to your needs, likes and dislikes. Overall, cookies are safe, as they only identify your computer to customize your Web experience. Accepting a cookie does not provide us access to your computer or any Personal Data about you, other than the information you choose to share. Other servers cannot read them, nor can they be used to deliver a virus. Most browsers automatically accept cookies, but you can usually adjust yours (Microsoft Internet Explorer, Firefox or Google Chrome) to notify you of cookie placement requests, refuse certain cookies, or decline cookies completely. If you turn off cookies completely, there may be some Website features that will not be available to you, and some Web pages may not display properly. To support the personalized features of our Website (such as your country and language codes and browsing functions) we must send a cookie to your computer’s hard drive and/or use cookie-based authentication to identify you as a registered Website user. We do not, however, use so-called "surveillance" cookies that track your activity elsewhere on the Web. We may also collect information using web beacons (also known as "tracking pixels").
f) “Web beacons” or clear .gifs are small pieces of code placed on a Web page to monitor behavior and collect data about the visitors viewing a Web page. For example, Web beacons or similar technology can be used to count the users who visit a Website or to deliver a cookie to the browser of a visitor viewing that page. We may use Web beacons or similar technology on our Services from time to time for this and other purposes.
3. HOW WE USE YOUR INFORMATION
I. We use the personal information we collect to fulfill your requests for services, improve our services, contact you, conduct research, and provide anonymous reporting for internal and external clients.
II. The Company collects and processes Personal Data which are required for the evaluation, establishment and maintenance of the contractual relationship between the Company and the Client and in order to comply with the Policy and applicable laws and regulations governing the provision of financial services. In some cases, the Company may also process the Client’s Personal Data to pursue its legitimate interests or those of third parties, provided that the Clients’ interests and fundamental rights are not overridden by those of the Company or the third party.
IV. Protection of Our Services and Others: We reserve the right to release Personal Data to unaffiliated third parties when we believe its release is appropriate to comply with the law, enforce or apply our Terms and Conditions and other agreements, or protect the rights, property or safety of Trader Interactive, our users or others. This includes exchanging information with other unaffiliated third parties in connection with fraud protection and credit risk reduction.
V. With Your Consent: Other than as set out above, you will receive notice and have the opportunity to withhold consent when Personal Data about you might be shared with unaffiliated third parties.
4. HOW WE SHARE YOUR INFORMATION
III. WE CAN (AND YOU AUTHORIZE US TO) DISCLOSE ANY INFORMATION ABOUT YOU TO LAW ENFORCEMENT, OTHER GOVERNMENT OFFICIALS, ANY LAWSUIT OR ANY OTHER THIRD PARTY THAT WE, IN OUR SOLE DISCRETION, BELIEVE NECESSARY OR WEBSITE APPROPRIATE IN CONNECTION WITH AN INVESTIGATION OF FRAUD, INTELLECTUAL PROPERTY INFRINGEMENT, OR OTHER ACTIVITY THAT IS ILLEGAL OR MAY EXPOSE US, OR YOU, TO LIABILITY.
5. ENSURING INFORMATION IS ACCURATE AND UP-TO-DATE
I. We take reasonable precautions to ensure that the Personal Information we Collect, Use and Disclose is complete, relevant and up-to-date. However, the accuracy of that information depends to a large extent on the information you provide. That's why we recommend that you:
a) Let us know if there are any errors in your Personal Information; and
b) Keep us up-to-date with changes to your Personal Information such as your name or address.
6. HOW WE PROTECT YOUR INFORMATION
I. We are very concerned about safeguarding the confidentiality of your Personal Data. We employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.
II. By using this Website or the Services or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this Website or Services.
III. Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property. However, nothing in this Policy is intended to limit any legal defenses or objections that you may have to a third party, including a government’s request to disclose your information.
IV. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us credit card information and/or other sensitive information through email. If you have reason to believe that your interaction with us is not secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the "Contacting Us" section available on our Website.
7. YOUR CHOICES ABOUT YOUR INFORMATION
I. You have several choices regarding use of information on our Services:
b) You may, of course, decline to submit Personal Data through the Website, in which case, we will not be able to provide our services to you.
8. STORING PERSONAL DATA
We retain your information only for as long as is necessary for the purposes for which we process the information as set out in this policy. However, we may retain your Personal Data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
9. RIGHTS OF THE DATA SUBJECT
You have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact us.b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
i. the purposes of the processing;
ii. the categories of personal data concerned;
iii. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
iv. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
v. the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
vi. the existence of the right to lodge a complaint with a supervisory authority;
vii. where the personal data are not collected from the data subject, any available information as to their source;
viii. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject;
ix. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact us.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact us.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
i. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
ii. The data subject withdraws consent to which the processing is based according to the point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
iii. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
iv. The personal data have been unlawfully processed.
v. The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
vi. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
vii. If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by us, he or she may, at any time, contact any employee of the controller. Any of our Employees shall promptly ensure that the erasure request is complied with immediately.
viii. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Any of our employees will arrange the necessary measures in individual cases.
e) Right of restriction of processing
i. Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
A. The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data. The processing is unlawful, and the data subject opposes the erasure of the personal data and requests instead of the restriction of their use instead. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims. The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by us, he or she may at any time contact any employee of the controller. We will arrange the restriction of the processing.
f) Right to data portability
i. Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
ii. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
iii. In order to assert the right to data portability, the data subject may at any time contact us.
g) Right to object
i. Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If we process personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects us to the processing for direct marketing purposes, we will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
ii. In order to exercise the right to object, the data subject may contact any employee of our Company. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
i. Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, we shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
ii. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact us.
i) Right to withdraw data protection consent
i. Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time.
ii. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact us.
j) Right to request access
You also have a right to access information we hold about you. We are happy to provide you with details of your Personal Information that we hold or process. To protect your personal information, we follow set storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. You can exercise this right at any time by contacting us on the above details.
k) Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details.
10. CHILDREN’S PRIVACY
The Company understands the importance of protecting children’s privacy. The Company's services are neither intended for children under eighteen (18) years of age nor are the Company’s website designed for use by children. Therefore, the Company does not knowingly or specifically collect children's personal data. If the Company collects such data mistakenly or unintentionally, the Company shall delete the information at the earliest possible once it obtains knowledge thereof. If the Client becomes aware of such data collection, he/she shall notify the Company.
11 LINKS TO THIRD PARTY WEBSITE
Our website can contain links to other websites. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Data from you. Other websites follow different rules regarding the use or disclosure of the Personal Data you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
12. NOTIFICATION PROCEDURES
13. OPTING OUT OF INFORMATION SHARING
We understand and respect that not all users may want to allow us to share their information with other select users or companies. If you do not want us to share your information, please contact us through the Contact Us page, and we will remove your name from lists we share with other users or companies as soon as reasonably practicable, or you can also click on unsubscribe. When contacting us, please clearly state your request, including your name, mailing address, email address and phone number. You may also hide details of Social Networking Accounts by opting for the same when you are creating an account with us.
I. However, under the following circumstances, we may still be required to share your personal information:
a) If we respond to court orders or legal process, or if we need to establish or exercise our legal rights or defend against legal claims.
c) If we believe it is necessary to restrict or inhibit any user from using any of our Website, including, without limitation, by means of "hacking" or defacing any portion thereof.
14. USER SUBMISSIONS
You understand that when using the Website, you will be exposed to Content from a variety of sources, and that we are not responsible for the accuracy, usefulness, safety, or intellectual property rights of or relating to such Content and you agree and assume all liability for your use. You further understand and acknowledge that you may be exposed to Content that is inaccurate, offensive, indecent, or objectionable, defamatory or libelous and you agree to waive, and hereby do waive, any legal or equitable rights or remedies you have or may have against us with respect thereto. If you find any content to be libelous, objectionable, defamatory, and indecent or infringing your Intellectual Property Rights, you may contact us directly through “Contact Us” page and we shall take appropriate action to remove such content from the Website.
15. PHISHING OR FALSE EMAILS
If you receive an unsolicited email that appears to be from us or one of our members that requests personal information (such as your credit card, login, or password), or that asks you to verify or confirm your account or other personal information by clicking on a link, that email was likely to have been sent by someone trying to unlawfully obtain your information, sometimes referred to as a "phisher" or "spoofer." We do not ask for this type of information in an email. Do not provide the information or click on the link. Please contact us if you get an email like this.
18. NO RESERVATIONS
19. NO CONFLICT
The policy constitutes a part of the user terms. We have taken utmost care to avoid any inconsistency or conflict of this policy with any other terms, agreements or guidelines available on our Website. In case there exists a conflict, we request you to kindly contact us for the final provision and interpretation.
20. CONTACT US