Company website (hereinafter, "Company", "we", "us" or "our") are committed to protect and respect your privacy. This Privacy Policy governs the collection, processing and use of Users' Personal Information of Company website.
1.1. The basic definitions used in this Privacy Policy:
- Personal Information (personal data): any information which identifies you personally or which may help us to identify you (e.g. your name, address, e-mail address, trades etc.).
- Data subject: an identified or identifiable person (our User).
- Data controller: a company which determines purposes and means of personal data processing.
- Data processor: a company which processes personal data on behalf and upon instructions of the Data controller.
- Personal data processing: any operation or set of operations performed on personal data (e.g., collection, storage, use, disclosure erasure).
1.2. Other terms, not defined above, have the meanings as defined in the applicable data protection legislation.
2.1. The purpose of this Privacy Policy is to inform about:
1. Company website;
2. the kinds of Personal Information which Company may collect about its users, the reasons for collecting this information, how it may be used and for how long Company will keep it;
3. the use of information by Company regarding IP addresses and use of cookies by users of platform;
4. disclosure of Personal Information to third parties;
5. information on international data transfer;
6. user’s ability to access, correct, update, restrict use, ask Company website to transfer and/or delete his/her Personal Information;
7. the use of user’s Personal Information by Company;
8. the security measures that Company has to prevent the loss, misuse, or alteration of Personal Information under control of Company, and
9. the rights of the users to lodge a complaint.
3.1. Company may collect user’s Personal Information when he/she uses an Company website and opens an Account to use the Company website or perform any actions on the platform. This is defined as a collection for the purpose of provision of service(s) of Company.
Please note that if the user refuses to share his/her Personal Information for these purposes Company can limit the services to the user.
4.1. The types of Personal Information which Company collects may include:
1. the name of the user;
2. user’s photographic identification;
3. details from user’s ID documents (such as driver license, passport), number of the document, date of issue and expiration, photographic identification, address etc.;
4. user’s address;
5. user’s phone number;
6. user’s email address;
7. user’s IP address, Browser and Operating System information, geolocation details;
8. user’s banking details including account numbers and payment card data;
9. user’s date of birth;
10. your transactions and;
11. information on sources of user’s funds.
5.1. Company will process user’s Personal Information only for the purpose(s) of providing the service(s) that user asks Company to provide, to satisfy the legal obligations stemming from regulatory obligations that arise from providing the service(s) and legitimate interest of Company.
5.2. Based on legal obligations of Company and legitimate interests, Company may request other documents for identity verification of users and the sources of their funds confirmation for the purposes of money laundering and fraud prevention.
6.1. Company may use user’s Personal Information for the following purposes:
1. to allow user to open and operate an Account on the website;
2. to enable user to complete the transactions on the website;
3. to reply to user’s queries if he/she contacts Company;
4. to analyze the use of website of Company;
5. as required for regulatory purposes such as Tax, prevention of Money Laundering, prevention of Fraud, adherence to Company statistical reporting obligations etc.;
6. to provide user with information about the products and promotions that may be of interest to user, from Company and third parties, if user has specifically agreed to receive such information;
7. for market research e.g. surveying Users' needs and opinions on issues, such as performance of Company etc. Unless consented, user’s data for this purpose would be anonymised.
7.1. Services of the Company are exclusively offered to individuals at least 18 years old.
7.2. Company does not process any Personal Information of children under this age.
8.1. Company website may collect the information about the user's computer, including where available the user's IP address, operating system and browser type, for system administration and to report aggregate information to advertisers.
8.2. This is statistical data about users' browsing actions and patterns. This information will not be used to identify any individual.
9.1. Company uses a browser feature known as a "cookie", which assigns a unique identification to the user's computer. Cookies are typically stored on the computer's hard drive of the user.
9.2. The information collected from cookies is used by the Company to evaluate the effectiveness of the website, analyze trends, and administer the website.
9.3. The information collected from cookies allows the Company website to determine what pages of Company are the most visited, the difficulties visitors of Company may experience in accessing the website. With this knowledge Company can improve the quality of the website by recognising and delivering more of the most desired features and information, as well as by resolving the access difficulties.
9.4. Company also uses cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm the user’s receipt of, and response to, our emails and to provide the users with a more personalized experience using the Company website.
9.5. Company uses the services of a third party service provider(s), to assist us in better understanding the use of our website. Our service provider(s) will place cookies on the hard drive of the user's computer and will receive information that Company selects that will educate Company about how visitors navigate around the site, what products are browsed, and general information.
9.6. The service provider(s) of Company analyses this information and provides Company with aggregate reports. The information and analysis provided by the service provider(s) will be used to assist Company in better understanding of visitors' interests in the Company website and how to better serve those interests.
9.7. The information collected by service provider(s) of Company may be linked to and combined with information that the Company website collects about the users while they are using the website.
9.8. Service provider(s) is/are contractually restricted from using the information they receive from the Company website other than to assist us.
9.9. By using the Company website the users are agreeing that the Company website may use cookies for the purposes set out above.
9.10. The company will keep records of all transfers of Personal Information to third parties and this information, if it is possible, can be provided to the user.
10.1. Company website uses the Personal Information for the purposes indicated at the time when the user provides Company with such information, and/or for the purposes set out in this Privacy Policy and/or permitted by the law.
10.2. Company may make available the Personal Information that the user provides to us for the limited purpose indicated for and during the provision of the service that the user would have requested in particular to:
- payment service providers and financial institutions;
- customer communications platforms;
- contractors of Company providing software for identity verification purposes;
- contractors of the Company providing us information on sanctions lists from the publicly accessible sources.
10.3. Company may also share Users’ Personal Information with financial institutions, insurance companies or other companies in the case of a merger, divestiture, or other corporate re-organisation and notify the user of such sharing of user’s information to be able to exercise any of the user's rights where applicable.
10.4. Company may also share Users' Personal Information with the law enforcement or regulatory agencies, as may be required by the law. In certain cases, Company may not be able to inform the user of such sharing of data due to the legal restrictions.
10.5. Any third party which receives or has access to Personal Information shall be required by Company to protect such Personal Information and to use it only to carry out the services they are performing for users or for Company, unless otherwise required or permitted by law. Such a third party, except for regulatory authorities, would be contractually bound to adhere to the same security and confidentiality policies as Company and assume the same responsibilities as Company.
10.6. The legitimate exercise of any of the user's rights with Company will also be notified to be applied by any third parties having been given access to your Personal Information.
10.7. Company will ensure that any third party is aware of our obligations under this Privacy Policy.
10.8. Company will enter into contracts with third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations that Company undertakes to the users under this Privacy Policy or which are imposed on Company under the applicable data protection laws.
11.1. Contractors of the website of Company are situated at different locations and countries and Company sometimes needs to transfer user’s personal data to third countries to provide our services to the users.
11.2. Company strives to ensure an adequate level of user’s personal data protection wherever our contractor is located.
11.3. Company may transfer user’s Personal Information only in the following cases:
- if the country where Company transfers user’s Personal Information provides the adequate level of personal data protection;
- if Company takes appropriate safeguards to ensure that user’s rights as data subject are protected;
- if any derogations for specific situations apply (for instance, if such transfer is necessary for the establishment, exercise or defense of legal claims or for an important reason of public interest).
12.1. Users have the right to access user’s Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to Company or where it is possible, users can do these actions in the user's account profile page by themselves.
12.2. Upon a user's written request at support service, Company will inform the user of the Personal Information relating to him/her that Company holds and the use and general disclosure of the user's Personal Information.
12.3. Company will also give the user a copy of the Personal Information that Company has retained. There may be a minimal charge for providing the user the additional copies of user’s Personal Information to cover the administrative costs.
12.4. The user may also request the deletion or destruction of both the Account and Personal Information by sending an email to the support service. Company will action the user's request immediately, except, if this is not consistent with its legal and regulatory obligations.
12.5. The user may also ask the Company to transfer his/her Personal Information to another controller of his/her choice.
12.6. To ensure the confidentiality, integrity and availability of user’s information, the Company may request the user to confirm his/her identity by providing the identification documentation and/or other methods prior to assisting the user in exercising any of his/her rights.
12.7. If the user refuses to prove his/her identity, Company may decline to take actions in respect of the user's data, save restricting processing, until Company can ensure that such actions are the true wish of the data subject.
12.8. In the carrying out of our services Company may use the automated processing and profiling to reduce the risks of fraud, money laundering and abuse of services of Company. Through this automated processing, the Company carries out an analysis of user’s identification, transactional and behavioral patterns.
12.9. Company may not be able to provide the user with some or all our services if the user does not wish this automated processing to be carried out. If the user feels that this processing might be detrimental to him/her, the user may contact the support service, and the Company will review this application.
13.1. Company has implemented technical and organizational security measures to ensure the confidentiality, integrity and accountability of user’s Personal Information and to protect user’s Personal Information from loss, misuse, alteration or destruction.
13.2. Such measures include:
- the encryption of personal data;
- the access control;
- the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services of Company;
- the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
13.3. Only authorized personnel of the Company have access to the user's Personal Information, and these personnel are required to treat the information as confidential.
13.4. Where the user has consented to, or Company is obliged to pass on Personal Information to third parties to provide the user with a requested service or in the carrying out of a regulatory or legal obligation, Company will request that the same levels of technical and organizational security measure be applied through the contractual arrangements, where possible.
13.5. Company conducts testing, assessment and evaluation of our technical and organizational measures effectiveness on a regular basis. Technical and organizational security measures will, from time to time, be reviewed in line with the legal and technical developments.
13.6. In the event of a personal data breach or the failure of the measures of protection of such information Company will immediately notify the user without undue delay.
14.1. There may be links from the Company website to other sites and resources provided by third parties. This Privacy Policy applies only to the Company website. Accessing those third-party sites or sources requires the user to leave the Company website.
14.2. Company does not control those third party sites or any of the content contained therein and the user agrees that Company is in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or any problems related to or arising from those sites.
14.3. Company encourages the user to review all policies, rules, terms and regulations, including the privacy policies, of each site that he/she visits.
15.1. User’s information is held on the servers of Company located in different countries. Access to this information is provided to employees of Company who adhere to the same principles of data security.
15.2. Company will hold the user's Personal Information only for as long as it is necessary for the purposes described in this Privacy Policy and legal and regulatory requirements.
15.3. In accordance with the record keeping activities for Anti-Money Laundering, Tax and Company legal obligations and considering the period during which the user may bring the legal claims against Company under the law.
15.4. Data stored for regulatory purposes will be protected from the unnecessary processing and will be held only for the purpose of being able to provide information or access to relevant authorities.
16.1. Once Company does not have any obligation to providing the user with a service he/she requested, nor an obligation to hold the Personal Information for regulatory or legal purpose, Company will anonymise or dispose of user’s Personal Information in line with acceptable industry and security standards so that this cannot be subsequently retrieved and associated to user.
16.2. Where Company cannot directly remove such records, such as archived backups, Company will retain a log of which Personal Information should be removed if ever the backup data is restored.
17.1. Company will ask the user's consent on registration or post-registration, by providing him/her the ability to check the marketing preferences check boxes located within the user’s account profile page to allow us to contact the user or use the user's Personal Information for marketing purposes.
17.2. Company platform may also notify the existing Users on our own products or services similar to those Company has already provided based on our legitimate interest.
17.3. User has the right to retract the consent for the Company to process the user's Personal Information for marketing purposes.
17.4. User can exercise his/her right to prevent such processing by unchecking marketing preferences check boxes on his/her account profile or by contacting the Company at any time on support service.
18.1. Company policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of Company.
18.2. If Company changes this Privacy Policy, it will take the steps to notify all users by a notice on the Company website and will post the amended Privacy Policy on the website.
18.3. If Company considers that the user's rights may be affected by any such changes, Company will request the user to confirm his/her consideration and acceptance prior to continuing our relationship with the user.
19.1. Please be notified that the Company is not in any partnership with entities who represent themselves as customer support agents, providing customer support services via phone and/or social media and promising to help to solve user’s issues for money.
19.2. Remember - customer support is provided only via the Company website and is always provided free of charge.
19.3. If the user discovers what he/she believes is a fraud, phishing, or scam which impersonates Company he/she can email Company at support service.