Last updated: 26/3/23
We (We”, “Us” or “Our) are committed to securing your Personal Data and your privacy.
We will uphold the following principles:
It is important to Us that you have at all times all the information required for you to make educated decisions about the processing of Personal Data about you when you visit our Website or when you agree to start trading with a third party trading platform. For this purpose, We will make use of various techniques and measures aimed to provide you with relevant information about the processing of Personal Data about you, in the proper manner and timing.
In addition, if We find you are required to be provided with specific information, We will provide it to you in the appropriate time and place.
We are also happy to answer any questions you may have and to provide you with any clarification you require, subject to legal limitations. For this purpose, you can approach Us by sending an email to the following address: firstname.lastname@example.org
The purposes for which We may process Personal Data about you include, inter alia, to make the Website available to you and provide you with a connection to a third party trading platforms (the “Services”), to enhance the user experience in the Website, to improve the Services (including the Website), to protect Our rights and interests, to perform business and administrative activity that supports the provision of the Services to the Website users, and/or to uphold any legal and/or regulatory requirements.
In addition, We will process Personal Data about you in order to understand your personal needs and preferences.
We apply significant resources to allow you to exercise your rights as a data subject. Therefore, you may approach Us any time you wish to review Personal Data about you, have Us amend it, erase it, cease using it for specific purposes or in general, or transfer it to you or to a third party. We will fulfill your wishes in accordance with the law.
While We cannot promise absolute protection of the Personal Data about you, We can promise that We use and will continue to use a wide array of means and measures aimed at ensuring the Personal Data about you is secured.
This Policy describes what kind of Personal Data the Company collects about natural persons, and how it collects it, uses it, shares it with third parties, secures it, processes it, etc.
In this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.
In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.
Our Services are intended for general audience and are not directed at children under the age of 18. We do not knowingly collect or solicit information from anyone under the age of 18 or knowingly allow such persons to access our Services. If We learn that information about a child was collected, We will take reasonable steps to delete such information as soon as possible.
We collect Personal Data about you whenever you use the Services, use the service channels and use the Website. In some instances, you will actively provide Us with the Personal Data, and in other instances, We will collect the Personal Data about you by examining and analyzing your use of Our Services and/or Our service channels or receive your data from our third party partners.
You are not obligated to provide Us with any Personal Data about you. However, in some instances, not providing such Personal Data will prevent Us from providing you with the Services, will prevent your use of the Website, and/or will cause the malfunctioning of the Services and the Website.
Personal Data We collect upon each browsing onto the Website: this information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, software crash reports and type of browser used, information regarding the device you used. Some of this information may not identify you personally, and therefore not constitute Personal Data.
Personal Data We receive from you: any Personal Data you provide to Us of your own free will when contacting with a third-party trading platform through Us.
Personal Data You specifically provide for submission to third-parties platforms in order to trade: this information includes your full name, telephone number and email address.
The Company processes your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.
The Company will not process Personal Data about you unless there is a legal basis for such processing. The legal bases according to which the Company may process Personal Data about you are as follows:
If you wish to receive more information detailing how processing is being necessary for the purposes of the legitimate interests pursued by the Company or by a third party, you may you may approach Us by sending a notice to the email address at any time.
The following list outlines the purposes for which We may process Personal Data about you and the legal basis for any such processing:
In order to submit your details to third parties at your request in order to approach digital, trading
We may collect Personal Data about you in order to submit it to third parties, if you specifically request that.
You have given consent to the processing of your Personal Data for one or more specific purposes.
In order to respond to your queries, requests, and/or complaints
Processing of Personal Data about you is required in order to respond to queries you have concerning your use of the Services.
Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.
In order to comply with any legal obligations or judicial or administrative orders
We process Personal Data about you in order to comply with Our various legal obligations.
Processing is necessary for compliance with a legal obligation to which the Company is subject.
In order to improve Our Services
We may use Personal Data about you in order to improve Our Services. Such processing will include, inter alia, any crash logs or other malfunction reports obtained in respect of Services.
Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.
In order to prevent fraud, abusive use of Our Services
Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.
In order to perform and maintain various activities supporting the provisions of Our Services
Such activities include back-office functions, business development activities, strategic decision-making, oversight mechanisms, etc.
In order to perform analysis, including statistical analysis
We use various analytical measures (including statistical ones) to make decisions on various issues.
In order to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims
We may process Personal Data about you in order to protect Our interests, rights, and assets, or those of third parties, according to any law, regulation, or agreement, including any of Our terms and conditions and policies.
The Company may also share Personal Data about you with third parties that provide Us services, such as storage and hosting providers, IP address information, analysis of user experience and research, analytical, technical, and diagnostic services.
In addition, you may specifically request that We submit certain Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data that you will provide to Us for such purpose, to such third parties, and their use of your Personal Data will be subject to their own privacy policies. We may share your Personal Data with multiple third party trading platforms.
The Company may also share Personal Data about you with its related entities and business partners, which provide it with resources that enable the Company to enrich and improve the level of services and products it provides to its users.
The Company may share Personal Data about you with governmental, local, official, and regulatory authorities, as well as if such disclosure is required to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims.
In addition, We may disclose Personal Data about you to potential purchasers or investors of, or lenders to, the Company and/or any company within the group of companies of which the Company is a part, or in the event of any similar transaction (including the sale of assets of the Company and/or of any company within the group of companies of which the Company is a part), and/or in connection with any merger, reorganization, consolidation, or bankruptcy of the Company and/or any company within the group of companies of which the Company is a part.
Cookie (which is a small text file) is installed on the device via which you visit or access the Website. The cookies shall allow to collect information about you and your behavior, in order to improve your user experience, to remember your preferences and settings, and to customize and offer you products and services that may interest you. Cookies may also be used to collect statistics and perform analytics.
Some of the cookies We may use are session cookies, which are downloaded temporarily to your device and last until you close your web browser, while others are persistent cookies, which last on your device after you cease browsing the Website and can be used to help the Website remember you as a returning visitor when you return to the Website.
Types of cookies:
The cookies We may use are classified according to their functionality, as follows:
|Type of Cookie||Purpose||Additional Information|
|Strictly Necessary Cookies||
These cookies are strictly necessary to enable you to navigate the Website and use features you have requested. They are used to provide you with Our content, products, and services that you have requested.
Such cookies are essential to help your device download or stream information so that you can navigate around the Website, use its features, and return to pages you have previously visited.
These cookies collect Personal Data about you, such as user name and last login date, and identify you as being logged in to the Website.
These cookies are deleted when you close your web browser (session cookies).
These cookies are used to recognize you when you return to the Website and allow Us to remember your choices and preferences.
These cookies survive the closing of your web browser, and last until their applicable expiry time.
These cookies are used to provide aggregated statistics in respect of the performance of the Website and to test and improve such performance, in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Website.
These cookies collect anonymized data that is not related to an identified or identifiable natural person.
These cookies are valid for varying periods; some are deleted once you close your browser, while others have an indefinite validity period.
Blocking and removal of cookies
You can change your browser settings to block and delete some or all cookies. Please see below links to instructions on how to do this in respect of some of the most popular web browsers:
Please note, however, that if you do so, some or all of the Website’s features and functionalities might not perform as intended.
ONLINE TRACKING NOTICE
AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.
The Company shall retain Personal Data about you for as long as is required to fulfill the purposes of the processing of the Personal Data as outlined in this Policy, or for a longer period as required according to the legislation, regulation, policies, and orders that apply to Us.
We will share your information with third party trading platforms for a 12 months period and subject to our consent will do so for additional 12 months.
In order to ensure that Personal Data about you is not retained for longer than is required, we periodically review Personal Data retained by Us to examine whether any Personal Data can be erased.
Personal Data about you may be transferred to a third country (i.e. jurisdictions other than the one you reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about you and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.
If you are an EEA (European Economic Area) resident, please note that these safeguards and protection will be available if any of the following are met:
The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR.
The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
You may request that the Company provide you with details concerning the safeguards employed by it to protect the Personal Data about you that are transferred to a third country or an international organization, by sending an email to the following address: email@example.com
We implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.
We cannot guarantee, nor do We represent, that there will be error-free performance regarding the privacy of your Personal Data, and We will not be liable for any indirect, incidental, consequential, or punitive damages relating to the use or release of Personal Data about You including, but not limited to, disclosure of Personal Data due to errors in transmission, unauthorized third-party access, or other causes beyond Our reasonable control.
We may be required, due to legal or other obligations outside Our control, to transfer Personal Data about you to third parties, such as public authorities. In such circumstances, We have limited control over the level of protection provided to the Personal Data about you by such third parties.
Any transfer of Personal Data via the internet cannot be fully secured. Therefore, the Company cannot ensure the protection of Personal Data about you when transferred via the internet to Us.
The Website may provide links to websites and/or applications of third parties. The Company does not control such websites and applications, nor the collection and/or processing of Personal Data about you by such websites and applications, and We are not responsible for such websites and applications, nor for their privacy and data protection policies and activities. This Policy does not apply to any actions taken via such websites and/or applications.
Whenever you access such third parties' websites and/or applications, We recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about you.
We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, We will notify you of such amendments by publishing the updated Policy on the Website. In addition, when We make significant amendments to this Policy, We will strive to inform you about such amendments via means of communication We believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on the Website. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our Website.
Generally, you have the right to request that We provide you with confirm whether Personal Data about you is being collected by us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict you consent to certain processing of your Personal Information.
If you are an EEA resident please read this section below:
You are entitled to the following rights in respect of the Personal Data about you. To exercise such rights, you may send a request to exercise your rights to the following email address: firstname.lastname@example.org
Right of access
You have the right to receive from the Company confirmation as to whether or not Personal Data about you is being processed, and, if that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) if possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from the Company rectification or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) if the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.
The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by you. If you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form.
The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request harms the rights and freedoms of others, the Company may not fulfill your request or do so in a limited manner.
Right to rectification
You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right for incomplete Personal Data about you to be completed, including by means of providing a supplementary statement.
Right to erasure
You have the right to obtain from the Company the erasure of Personal Data about you if one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data about you has to be erased for compliance with a legal obligation in European Union or Member State law to which the Company is subject.
This right is not applicable to the extent that the processing is necessary (a) for compliance with a legal obligation that requires processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defense of legal claims.
Right of restriction of processing
You have the right to obtain from the Company the restriction of processing of Personal Data about you if one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling the Company to verify the accuracy of the Personal Data about you; (b) the processing is unlawful and you oppose the erasure of the Personal Data about you and request the restriction of its use instead; (c) the Company no longer needs the Personal Data about you for the purposes of processing, but the Personal Data is required by you for the establishment, exercise, or defense of legal claims; (d) if the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims; or (e) if the Personal Data about you is processed for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.
If the processing of Personal Data about you has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
Right to data portability
You have the right to receive the Personal Data about you, which you have provided to the Company, in a structured, commonly used, and machine-readable format, as well as the right to transmit such Personal Data to another controller, if (a) the processing is based on your consent or on a contract to which you are a party, and (b) the processing is carried out by automated means.
In exercising your right to data portability, you have the right for the Personal Data about you to be transmitted directly from the Company to another controller, where technically feasible. The exercise of your right to data portability is without prejudice to your and the Company’s rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.
Right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by the Company or by a third party, including profiling based on such legitimate interests. In such case, We shall no longer process the Personal Data about you, unless We demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.
Right to withdraw consent
You may withdraw your consent provided to Us for the purpose of processing Personal Data about you at any time, without affecting the lawfulness of processing based on your consent before its withdrawal.
Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.
Your rights in respect of Personal Data about you as outlined in this section 13 may be restricted by European Union or Member State law to which the Company is subject.
We shall provide you with the information requested according to your rights outlined in this section 13 without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.
The information requested according to your rights outlined in this section 13 shall be provided free of charge, unless stated otherwise in this section 13. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, We may either (a) charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.
The Company may require you to provide additional information necessary to confirm your identity in order to fulfill your request according to your rights outlined in this section 13, if We have reasonable doubts concerning the identity of the natural person making the request.