(Last updated, 20 April, 2020)
1. Purpose for the Collection of Personal Data
Your personal information (“Personal Information”) is collected and used for the following reasons:
- to provide you with our services;
- to make more of such services available to you where possible and appropriate;
- for the purposes of security and control;
- to satisfy regulatory and legal requirements, and for historical and statistical purposes.
- to send email updates, of which you can opt out at any time.
2. Information We Collect
- The Personal Information which we may request to use and process shall include, without limitation:
- Any of the information that you provide to us when completing account registration, as well other data that you voluntarily submit via the Website or email.
- Correspondence made with us via the Website, email, web chat or through other means of communication.
- All transaction history, whether this takes place via the Website or other means of communication.
- Website logins and their details, including traffic data, GeoIP location data, browser/device data, weblogs, activity logs, and other traffic information recorded in our system.
- Survey participations or any other customer assessments that we may carry out from time to time.
3. Disclosing Personal Information to Third Parties
- We do not sell or rent your personal data to third parties. We may disclose your Personal Information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the legitimate interests of the Company, its customers or any third party. Personal Information will only be disclosed to third parties in the following cases:
- Where we are required to do so by law;
- If the Website needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies.
- To comply with our legal and regulatory duties and responsibilities to the relevant licensing and regulatory authorities as well as all duties and responsibilities owed under any other applicable legislation and to any other applicable regulators in other jurisdictions.
- When the Company believes that disclosure is necessary to protect the Company’s or the account holder’s safety, or the safety of others, investigate fraud, or respond to a government request.
- If our marketing service providers require the data to carry out their tasks.
4. Protection of Your Personal Information
We hereby acknowledge that in collecting and processing your Personal Information for the purposes of managing your Account, we are bound by strict legal provisions on the protection of personal data. Consequently, we endeavour to protect your personal information and respect your privacy in accordance with best business practices and applicable regulations. Being committed to providing secure services to account holders, we will take all reasonable precautions to ensure that all the data that you have submitted to us remains safe. Account holder Accounts can only be accessed with the account holder’s unique ID and password. In the event two-factor authentication (2FA) is required as additional protection from unauthorised use of your account, you are responsible for keeping your login information confidential and making sure it cannot be accessed by another person.
5. Access to Your Personal Information
- Cookies are small text files that are stored on your computer or equipment when you visit our web pages. Some cookies are essential for the Website to operate, while others improve your Website experience and help us deliver a better service. Below are the types of cookies we may use and their purposes.
- Required cookies: enable the navigation and basic functionality of the websites, e.g., access to member areas of the Website.
- Functional cookies: allow us to analyse your website usage and your selections on the website (e.g. your session key, language, or region), so we can save these settings and offer you a more personalised experience.
- Advertising cookies: allow us to gauge how effective our content marketing is. These cookies are provided by our partners to track website visits and new account holder registrations from advertising. We do not share your personal information (such as name or email) to affiliated partners except for site visit data collected directly by such advertising cookies. However your site visit data may be linked with other personal information collected through other sources by the providers. The latter external data processing is governed by the privacy notices and policies of these third-party providers.
- In addition to the above, we use a number of third party service providers who also set cookies on this Website, in order to deliver the services that they are providing to us. Such services include, but are not limited to, helping us to improve your experience by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns. Most online browsers automatically accept cookies. If you prefer, it is possible to block some or all cookies, or to delete cookies that have already been set by modifying your browser settings. However, we recommend that you do not block or delete your cookies as this may restrict your use of our Website.
7. Privacy Commitment
9. Data Retention
You may decide to have your Account closed at any time. Following closure of your Account, we will retain your personal data on record for as long as required by law. This data shall only be used should it be required by competent authorities in cases of enquiries regarding financial and fiscal records. You are to note that due to US and European tax ID regulations, we are required to retain an account holder’s personal data during the operative period of an Account for a minimum of five years from the last account holder transaction or account closure. Therefore, requests for erasure prior to the lapse of this period cannot be considered.
10. Contacting Us
You may always contact us in regards to this Policy should you wish to:
- Confirm the accuracy of the personal information we have collected about you.
- Enquire about our use of your personal information.
- Prohibit future use of your data for direct marketing purposes.
- Update or rectify any information that you have provided us.
Note: It is illegal to provide us with false information about you and it is your responsibility to ensure that we are always updated with your correct data. In addition, as per Article 77 of the GDPR, you have the right to lodge a complaint related to your data processing to a supervisory authority, in particular in the member state of your habitual residence, place of work or place of an alleged infringement.