Velta Capitals LLC respects your privacy and is
committed to protecting and respecting your personal data. This privacy policy aims to give you
information on how we collect and process any personal data i.e. information about
a Client (as defined below) who is a natural person on the basis of which that Client can be
identified (hereinafter the data) in accordance with the applicable data
protection legislation and best
practice.
We strive to create the most secure infrastructure
of any broker in the world. In this privacy policy we would like to tell why you can trust us
with your data and rest assured that your data is safe.
It is important that you read this privacy policy
together with any other privacy policy we may provide on specific occasions when we are
collecting or processing your data about you so that you are fully aware of how and
why we are using your data.
In this Privacy Policy, unless the context otherwise
requires, expressions defined herein shall have the meaning ascribed to them in the Terms & Conditions.
Please note that this Privacy Policy is addressed to
Clients and potential customers. If you are an Velta Capitals employee, a contractor to Velta
Capitals or a third-party service provider, your personal information will be used in
connection with your employment contract, your contractual relationship or in accordance with
our separate policies which are available by contacting us at the contact details listed in the
section OUR CONTACT DETAILS
below.
1. WHO WE ARE
Velta Capitals LLC, is a company registered in St.
Vincent and the Grenadines and having its registered address at Hinds Building, Kingstown, St.
Vincent and the Grenadines (hereinafter Velta Capitals). Velta Capitals is
the controller and responsible for the data of the Client disclosed to us in order to register
for a Trading Account, Demo Account and/or to make use of any other services offered by the
Velta Capitals Group (as defined in
Appendix A) through the website (hereinafter
“Website”) (this term shall at all times include Website’s desktop and mobile versions).
This Privacy Policy is issued on behalf of Velta
Capitals Group so when we mention “Velta Capitals”, “Company”, “we”, “us” or “our” in this
Privacy Policy, we are referring to the relevant company in the Velta Capitals group responsible
for collecting and/or processing your data when you use the Trading Platform through the
Website, either for a Trading Account or a Demo Account (or their mobile/desktop versions)
(hereinafter the
Service(s)). In Velta Capitals we respect your privacy and therefore all
companies within the Velta Capitals group are committed to protect your data, which it collects,
uses and/or has access to.
If you are participating in our affiliate and/or
introducing broker programs, we will process the data provided under our agreement with you to
exercise our rights and perform our obligations under or in connection with
the relevant agreement and the term Client in this Privacy Policy shall be read to include the
term Affiliate and/or Introducing Broker (as applicable).
The Company takes measures to implement advanced
data protection policies and procedures and to update them from time to time for the purpose of
safeguarding the Client's data and the Client’s account. Your data is protected
by the legal, administrative and technical measures that we take to ensure the privacy,
integrity and accessibility of data. To prevent security incidents with your data, we use a
mixed organizational and technical
approach based on the results of annual risk assessment.
The Company shall not divulge any private
information of its Clients and former Clients unless the Client approves in writing such
disclosure or unless such disclosure is required under applicable law or is required in
order to verify the Client's identity or it is required for Velta Capitals to perform its
contractual obligations under any agreement concluded with the Client. The Clients' information
is processed only by the employees
of the Company and/or employees of the Velta Capitals group and/or trusted third parties which
provide specific support services, dealing with the specific Client's Accounts and necessary for
the provision of our services.
All such information shall be stored on electronic and physical storage media according to
applicable law.
2. DATA USAGE
-
- We may collect, use, store and transfer different kinds of data about
you which we have grouped together as follows:
- Identity Data includes first name, last name,
and patronymic (if available), date of birth gender, passport, ID, Driver’s
number, and copy of photo.
- Contact Data includes billing address, email
address and telephone numbers.
- Financial Data includes bank account, payment
card details and tax identification number (including but not limited to
social security number, income tax identification number, national
insurance number).
- Transaction Data includes details about the
transactions performed by you, details about payments, withdrawals,
exchanges, trading history, profit, balance, deposited and withdrawal
amount methods, and any other details in relation to the services you have
made use of through our Website.
- Technical Data includes internet protocol (IP)
address, your login data, browser type and version, time zone setting and
location, browser plug-in type and versions, operating system
and platform, and other technologies on the devices you use to access the
Website and use of cookies stored on your device.
- Profile Data includes your Client’s account
details, username and password, transactions made by you, your interests,
preferences, feedback and/or information received through your interaction
with us within the course of providing our services and survey responses.
- Usage Data includes information about how you
use the Website, products and services, registration date, account category,
trading cluster, number of complaints, number of requests filed
and IP history.
- Marketing and Communication Data includes your
preferences in receiving marketing from us and your communication
preferences.
- Special Categories of Data/ ‘Sensitive’ Data
includes details about your religious belief, annual income, biometric data,
and/or criminal convictions and offences.
- Conformity Data includes details about your
education, employment status, trading experience, self-assessment test.
- Banking Data includes details of the number of
payment wallets and/or information of your bank card, including information
of the issuing bank, card number, cardholder name, card expiration
date, payment system, card validation code (CVV2 / CVC2), and photos of both
sides of the bank card.
- Data in KYC (Know your customer) includes
identity document information, including copies of recent dated Utility
Bills, Identity Card, Passport, and/or Driver’s License.
- Economic Profile Data includes details on
occupation, purpose of investment, annual income, net wealth, expected
annual amount of investment and sources of funds.
- Location Data includes details on your actual
location when interacting with our Website (for example, a set of parameters
that determine regional settings of your interface, namely
residency country, time zone, and the interface language).
- Audio Data includes full voice recordings of
calls that you receive from us or make to us.
(the above collectively
referred to as “Personal Data”)
- Aggregated Data includes statistical or demographic data for any
purpose. Such data can be derived from your data but may not be considered personal
data in law as it will not directly or indirectly reveal your
identity. An example of such Aggregated Data could be that we aggregate your Usage
Data to calculate the percentage of users accessing a specific website feature
and/or services/product preference.
Notwithstanding the above, if Velta Capitals combines Aggregate Data with data
in a way that the end result can in any way identify the data subject, Velta
Capitals shall treat such combined data as data which will
be treated as per the provisions herein contained.
- Processing of your data is carried out by Velta Capitals following the
principles of lawfulness, fairness, transparency, and always adhering to the
intended purpose of data processing, the principle of data minimization,
accuracy, limited data storage, data integrity, confidentiality and accountability.
- In general Velta Capitals collects and process the Personal Data, for
any of the following reasons:
- To perform its contract with you,
- To comply with its legal obligations including without
limitation to applicable anti-money laundering and terrorist financing laws
and regulations (hereby referred to as Money-Laundering Law), and/or
- To safeguard its legitimate interest
- The Client acknowledges that all or part of the data concerning the
Client's account and related transactions will be stored by the Velta Capitals and
may be used by the Company in case of dispute between the Client
and the Company.
- The Client is responsible for updating any data provided to us in case
of any change. Although we will strive to keep your data up to date and review and
inspect any information provided by you, we may not be
able to always do so without your help. The Client acknowledges that Velta Capitals
holds neither commitment nor responsibility to the Client due to any aforesaid
review or inspection of information.
3. HOW IS YOU PERSONAL DATA COLLECTED?
- We use different methods to collect data from and about you including through:
- Direct Interactions. You will provide to us your
Identity, Contact and Financial Data online through the Website and/or by filling in
online forms and/or by corresponding with us by emails or
otherwise. Data may be submitted to us by you when you wish to:
- Register for a Trading Account;
- Register for a Demo Account;
- Subscribe to our publications and ongoing updates;
- Request marketing and promotions to be sent to you;
- Enter a competition, promotion or survey; and/or
- Give us feedback or contact us.
- We require to collect the above data in order that we are able to (i)
provide our services efficiently, (ii) to comply with our ongoing legal obligations,
including, inter alia, to prevent fraud and money laundering
acts.
- If you fail to provide the data when requested we may not be able to
perform the contract we have or are trying to enter into with you (for example, to
provide you with our services). In this case, we may have
to cancel a service you have with us but we will notify you if this is the case at
the time. It is important that the data we hold about you is accurate and current.
Please keep us informed if your data
changes during your relationship with us.
- Automated Technologies or Interactions.
When using
our services, your device automatically transmits to us its technical
characteristics. Locale (a set of parameters that determine regional
settings of your interface, namely, residence country, time zone and the interface
language) is used for the purpose of providing you with the best possible service
within our platform.
Using the information
about IP address, cookies files, information about browser and operating system
used, the date and time of access to the site, and the requested pages addresses
allows us to provide you with the optimal
operation on our web application, mobile and/or desktop versions of our application
and monitor your behaviour for the purpose of improving the efficiency and usability
of our Services.
We use web analytics
tools to track performance of our website and marketing source of user by cookies in
order to optimize our marketing costs and provide users with better experience.
You may at any time request that we
refrain from any such transmissions (to the degree this is possible and subject to
any of our legal obligations) by sending your request to the DPO using our details
in the OUR CONTACT DETAILS below using
the registered email address you disclosed and registered with us through your
Account. We will address your request within 30 business days.
- About Cookies.
A cookie is a small amount of data
that often includes a unique identifier that is sent to your computer or device
browser from a website's computer and is stored on your
device's hard drive for tracking site usage. A website may send its own cookie to
your browser if your browser's preferences allow it, but, to protect your privacy,
your browser only permits a website to
access the cookies it has already sent to you, not the cookies sent to you by other
websites. Many websites do this whenever a user visits their website in order to
track online traffic flows. When you visit
our Website, our system automatically collects information about your visit, such as
your Technical Data, including inter alia to, your browser type, your IP address and
the referring website.
Cookies
stored may determine the path the Client took on our site and used to anonymously
identify repeat users of the website and what pages were most popular for Clients.
However, the Company protects the Client’s
privacy by not storing the Client’s names, personal details, emails, etc. Using
cookies is an industry standard and is currently used by most major websites. Stored
cookies allow the Website to be more user-friendly
and efficient for Clients by allowing Velta Capitals to learn what information is
more valued by Clients versus what isn’t. You can set your browser not to save any
cookies of this website and you may also delete
cookies automatically or manually. However, please note that by doing so you may not
be able to use all the provided functions of our website in full.
Please see our
Cookies
Policy for further details.
4. PURPOSE FOR WHICH WE WILL USE YOUR DATA AND ON WHAT LEGAL BASIS
-
- We process the aforementioned data in compliance with the applicable
legislation as amended from time to time in order to (i) be able to perform our
contractual obligations towards the Client and offer them
the best possible service, (ii) provide our Services efficiently, (iii) comply with
our legal obligations, including, inter alia, to prevent fraud and money laundering
acts, and (iv) protect our legitimate
interests and your vital interests.
- We process all data based on the following legal basis:
- For compliance with our legal obligations;
- For the performance of our contractual obligations towards the
Client;
- For the purposes of safeguarding our legitimate interests and
your interests and fundamental rights do not override those interests;
and/or
- On the basis of your consent.
- Indicatively we set out below a description of all the ways we plan to
use your data and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.
Note that we may process the data for more than one lawful ground depending on the
specific purpose for which we are using your data.
| - |
PURPOSE ACTIVITY |
TYPE OF DATA |
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST |
| a. |
1. To accept to register you as a Client
2. To notify you about changes to our
terms or privacy policy
3. To communicate with you and provide you with secure identifications,
authentication and support services
4. To confirm you are at age of majority as
recognized and declared by the laws of your
jurisdiction
|
1. Identity Data
2. Profile Data
3. Contact Data
4. Data in KYC
5. Financial Data
6. Economic Profile Data
|
1. Necessary to perform our contract with you
2. Necessary to comply with our
legal obligations
|
| b. |
1. To perform our Scoring Processing under which a Client is scored on a scale basis
with regard to the level of risk he is to Velta Capitals |
1. Banking Data
2. Economic Profile Data |
1. Necessary to perform our contract with you
2. Necessary to comply with our
legal obligations
|
| c. |
1. To confirm the information provided by You under (a) above in relation to your
location. |
1. Location Data |
1. Necessary to perform our contract with you
2. Necessary to comply with our
legal obligations
|
| d. |
1. To secure authentication, identification and support services via social networks
protocols and use the links to your accounts in social networks for these purposes.
|
1. Technical Data |
1. Necessary to perform our contract with you
2. Necessary to comply with our
legal obligations
|
| e. |
1. To process and deliver your transactions and requests (Deposits; Trades;
Withdrawals)
2. Manage payments, fees and charges;
3. To collect and recover
money owed to us. |
1. Banking Data
2. Transaction Data |
1. Necessary to perform our contract with you
2. Necessary for our legitimate
interest (recover charges owed to us, make a withdrawal in case of breach of our
contract) |
| f. |
1. To administer and protect our business and Website (including troubleshooting,
data analysis, testing, system maintenance, support, reporting and hosting of data)
|
1. Identity Data
2. Contact Data
3. Technical Data |
1. Performance of our contract with you
2. Necessary to comply with our legal
obligations
3. Necessary for our legitimate interests (take reasonable steps to
confirm that you do not use any ways to manipulate
our platform & for running our business, provision of administration and IT
services, network security, to prevent fraud) |
| g. |
1. To deliver relevant Website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you
2. To provide you with an optimal operation on our web application, mobile
and/or desktop versions of our application and monitor your behavior for the purpose
of improving the efficiency and usability
of our services.
|
1. Identity Data
2. Contact Data
3. Profile Data
4. Usage Data Technical
Data
5. Marketing and Communication Data |
1. Necessary to perform our contract with you
2. Necessary for our legitimate
interests (to study how customers use our products/services, to develop them, to
grow our business) |
| h. |
1. to study how customers use our products/services, to develop them, to grow our
business and to inform our marketing strategy;
2. statutory limitations
|
1. Transaction Data |
1. Necessary for our legitimate interests (including statutory limitations
provisions by applicable laws)
|
| i. |
1. To inform you about any of the following:
— new services and/or products we
may offer;
— Any new development and/or features of the current products/services
we offer |
1. Identity Data
2. Profile Data
3. Contact Data
4. Technical Data
5. Usage Data
6. Transactions
7. Marketing and Communication Data
|
1. Necessary to perform our contract with you
2. Necessary for our legitimate
interests (to study how customers use our products/services, to develop our
products/services and grow our business)
|
| j. |
1. To send direct marketing of our services to you always within the boundaries of
our legitimate interests.
2. To send to you newsletters, push-messages and calls to keep you in touch with
our new feature and new development of the current products/services we offer, news
and events and the efficient provision
of the full scope of our services.
Please note that we will never use your data
to communicate to you and/or promote any third party marketing material.
|
1. Identity Data
2. Profile Data
3. Contact Data
4. Data that may be
provided by you during your activity at the Website.
Marketing and Communication
Data |
1. Necessary to perform our contract with you
2. Necessary for our legitimate
interests (to provide effective and personalized customer services to you and to
update you in relation to our services that are
available to you. |
| k. |
1. To allow us to provide you with the optimal operation on our Website, mobile and
desktop versions of our application and monitor your behavior for the purpose of
improving the efficiency and usability of
our Services.
2. To use analytics tools to track performance of the Website and
marketing source of our Clients in order to optimize our marketing costs and provide
you with better experience.
|
1. Location Data
2. Technical Data
3. Usage Data
4. Marketing and
Communication Data |
1. Necessary to perform our contract with you
2. Necessary for our legitimate
interests (to provide effective and personalized customer services to you and to
update you in relation to our services that are
available to you). |
| l. |
1. to allow us to monitor and train our employees for your benefit
2. to
safeguard your or our interests in case of a dispute
3. to take steps for fraud
prevention
4. to improve the services provided
to you |
Audio Data |
1. Necessary to perform our contract with you
2. Necessary to comply with our
legal obligations
3. Necessary for our legitimate interests
|
| m. |
1. To confirm that your annual income corresponds with your employment status
2. To confirm that you have no criminal history.
|
Sensitive Data |
1. Necessary to comply with our legal obligations
2. Necessary to protect your
vital interests.
|
- If you are an existing Client of the Website where we have a legitimate
interest in communicating with you, or if you have given us your consent we will collect and
process your personal data to communicate with you
in case of support and/or sending newsletters, push-messages and calls to keep you in touch
with our new features, news and events and the efficient provision of the full scope of our
services. We will also use
your data to send you marketing information regarding our services that we believe may be of
interest to you via email or otherwise.
- Our Website is not intended for children and we do not knowingly collect data
relating to children. As we do not allow users under the age of 18 to use our services, we
need to obtain your birth date in order to confirm
the Clients’ age checks.
5. OPTING OUT
If you do not want to receive any marketing
newsletters or transmit your data to the third-parties for marketing purposes, you can configure
your preferences. Such configuring can be done when (i) opening an account or
(ii) when receiving such advertising content or (iii) by logging in and going to My Account >
Personal Details > Notification Settings. You may also send to the Company, at any time, an
email to admin@fundamental-trade.com using the
registered email address you disclosed and registered with us through your Account asking the
Company to cease from sending such advertising content or sending your data to the third-parties
for marketing
purposes. The aforesaid mark removal and/or e-mail received by Velta Capitals will oblige us to
cease sending advertisement content to you within 7 (seven) business days.
6. DISCLOSURE OF DATA
- We may share your data with the parties for the purposes set out above.
- We require all Velta Capitals Group companies and any third parties processing
data on our behalf to respect your data and to treat it in accordance with the provisions of
the General Data Protection Regulation and applicable
local legislation as amended from time to time. We take all reasonable steps so that our
third-party service providers do not use your personal data for their own purposes and only
permit them to process your data
for specific purposes and in accordance with our instructions.
- Velta Capitals group companies. In general, your data is used
by the processors of the Velta Capitals group.
- In addition, a transfer of your data to another legal entity may occur as part
of a transfer of our business or parts thereof in form of a reorganization, sale of assets,
consolidation, merger or similar.
- With regard to the transfer of data to recipients outside the Velta Capitals
group, we note that we strive to maintain discretion with respect to client related matters
and assessments of which we acquire knowledge. We may
disclose data that concerns you only if (i) we are legally required to do so; (ii) if
required when you expressly order us to process a transaction or any other service and (iii)
it is required for the provision
of our services under our contractual relationship and/or (iv) protection of our legitimate
interests and applicable legislation as amended from time to time.
- External Third Parties. Your data is shared with third party
organisations/entities including but not limited to:
- A. Service Providers. We may share your data with our
trusted third party service providers, who, on our behalf, operate, maintain, and/or
support our IT systems and IT infrastructure, our websites,
manage our payment solutions, perform statistical analysis, marketing and
advertising purposes, sending newsletters, provide customer support and perform
other important services for us.
- B. Other Velta Capitals Affiliates. We may also
disclose your data to other Velta Capitals Affiliate companies in order for them to
provide us with the relevant services.
- C. State authorities. The Client's details that are
provided and/or that will be provided by the Client during his/her activity on the
site may be disclosed by the Company to official authorities.
The Company will make such disclosure only if required to be disclosed by the
Company by applicable law or court order and to the minimum required extent.
- D. Other disclosures. In addition to where you have
consented to a disclosure of the data or where disclosure is necessary to achieve
the purpose(s) for which, it was collected, data may also
be disclosed in special situations, where we have reason to believe that doing so is
necessary to identify, contact or bring legal action against anyone damaging,
injuring, or interfering (intentionally
or unintentionally) with our rights or property, users, or anyone else who could be
harmed by such activities, or otherwise where necessary for the establishment,
exercise or defence of legal claims.
- Where reasonably possible, management shall ensure that third parties
collecting, storing or processing personal information on behalf of the Company have:
- a. Signed agreements to protect personal information consistent with
this Privacy Policy and information security practices or implemented measures as
prescribed by applicable laws;
- b. Signed non-disclosure agreements or confidentiality agreements which
includes privacy clauses in the contract; and
- c. Established procedures to meet the terms of their agreement with
third party to protect personal information.
- Remedial action shall be taken in response to misuse or unauthorized disclosure
of personal information by a third party collecting, storing or processing personal
information on behalf of Velta Capitals.
- If you want to obtain further information on any data transfers mentioned above
please contact us using the registered email address you disclosed and registered with us
through your Account through the points of contact
listed in the Section OUR CONTACT DETAILS below.
7. DATA RETENTION
We store your data for as long as reasonably
necessary to fulfil the purposes we collected it for, including for the purposes of satisfying
any legal, tax, accounting or reporting requirements. We may retain your personal
data for a longer period in the event of a complaint or if we reasonably believe there is a
prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for
your data, we consider the amount, nature and sensitivity of the data, the potential risk of
harm from unauthorised use or disclosure of your data, the purposes for which
we process your data and whether we can achieve those purposes through other means, and the
applicable legal, tax, accounting and other requirements.
We shall keep your data (including call recordings)
during our contractual relationship and for a minimum period of 5 (five) years from the date of
termination of the Platform/Service used by the Client.
In general, all other data is stored for a period of
30 (thirty) business days after the date of termination of the provision of our services unless
there is any other legal reason to keep it.
At the expiration of the data retention period the
data is erased by irreversible destruction and we also inform all third parties, to whom the
data was transferred, regarding such erasure and request implementation of
similar actions on their part.
8. YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE
- We ask you to provide us with true, accurate and updated information on your
identity and not misrepresent yourself to be another individual or legal entity. Any changes
in your identifying details shall be notified
to the Company immediately and in any case no later than the 7th day from the date of such
changes. If your data is incorrect or incomplete, please contact our support services at the
contact details listed in the
section OUR CONTACT DETAILS below in order to change your data.
- Under certain circumstances, you have rights in accordance with applicable
legislation and our policies as amended from time to time. Some of the rights are rather
complex and include exemptions, thus we strongly advise
you to contact us (at the contact details listed in the section OUR CONTACT DETAILS below).
You can find a summary of your rights below in this section.
- A. The right to access. You have a right to obtain the
confirmation as to whether or not your data are being processed by us. In addition,
you have a right to obtain more detailed information
about the data kept and the processing undertaken by us and under certain
circumstances the right to receive a copy of this data.
- B. The right to rectification. You have the right to
have inaccurate data about you rectified, and, taking into account the purpose of
the processing, to have incomplete data completed.
- C. The right to erasure. This enables you to ask us to
delete or remove personal data where there is no good reason for us continuing to
process it. Please note however that we may not always
be able to comply with your request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request. In case if you want
to obtain complete erasure of your
data (to apply the “right to be forgotten”), please note that we may not always be
able to comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at
the time of your request.
- D. The right to restriction of processing. You have
the right to request the restriction of processing of your personal data (a) if it
is not accurate;(b) where processing may be unlawful but
you do not want us to erase your data; (c) where you need us to hold the data even
if we no longer require it; or (d) where you may have objected to our use of your
data but we need to verify whether we
have overriding legitimate grounds to use it.
- E. The right to data portability. To the extent the
legal basis for the processing is your consent, and such processing is carried out
by automated means, you have the right to receive your
data in a structured, commonly used and machine-readable format. However, this right
does not apply where it would adversely affect the rights and freedoms of others
and/or in case it may be technically
impossible to do so.
- F. The right to object. Subject to the legal basis on
which the processing activity is based, you may object to processing of your
personal data. Please note that in some cases, we may have
compelling legitimate grounds to process your information which we need to comply
with.
- G. The right to withdraw consent. To the extent that
the legal basis for the processing is your consent, you have the right to withdraw
from that consent at any time. This may apply to marketing
purposes and/or with regards to the transfer of your data to third parties. In case
you withdraw from a consent given, then we will cease to process your data, unless
and to the extent the continued processing
is permitted or required according to the applicable data regulation or other
applicable laws and regulations. The withdrawal from your consent will in no event
affect the lawfulness of processing based
on consent before its withdrawal.
- H. The right to complaint to data protection supervisory
authority. We do our best to ensure that we protect your data, keep you
informed about how we process your data and comply with the applicable data
protection regulation. In case you are not
satisfied with the processing and protection of your data or the information you
have received from us, then we urge you to inform us in order for us to improve.
Please also do not hesitate to contact us,
if you want to make use of your rights.
- If you want to exercise any of your rights mentioned above and/or obtain more
information regarding your rights and/or our policies and procedures please contact us
through the points of contact listed in the Section
OUR CONTACT DETAILS below. Please also provide us with relevant information to take care of
your request, including your full name and email address so that we can identify you. We
will respond to your request without
undue delay.
- We may need to request specific information from you to help us confirm your
identity and ensure your right to access your data (or to exercise any of your other
rights). This is a security measure to ensure that personal
data is not disclosed to any person who has no right to receive it. We may also contact you
to ask you further information in relation to your request to speed up our response.
- We try to respond to all legitimate requests within one month. Occasionally it
could take longer than a month if your request is particularly complex or you have made a
number of requests. In this case, we will notify
you and keep you updated.
- We may charge you a reasonable administrative fee for any unreasonable or
excessive requests we may receive, and for any additional copies of the data you may
request.
9. DATA SECURITY
We have put in place appropriate security measures
to prevent your data from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed. In addition, we limit access to your data to those employees,
agents, contractors and other third parties who have a business need to know. They will only
process your data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any
suspected data breach and will notify you of a breach where we are legally required to do so.
Your help is always valuable in ensuring that your
data is kept safe. Upon registration to the Website (or its mobile version), the Client will be
asked to choose a username and password to be used by the Client on each
future login and for the performance of transactions and use of the Company's Services. In order
to protect the Client's privacy and operation with the Website sharing registration details
(including without limitation,
username and password) by the Client with other persons or business entities is strictly
prohibited. The Company shall not be held responsible for any damage or loss caused to the
Client due to improper use (including
prohibited and unprotected use) or storage of such username and password, including any such use
made by a third party, and whether or not known to or authorized by the Client.
Any use of the Website with the Client's username
and password is Client's sole responsibility. The Company shall not be held responsible for any
such use, including for validation that Client is actually operating in his/her
account.
The Client is obliged to forthwith notify the
Company's client service of any suspicion for unauthorized use of the Client’s account. You may
contact us at any time through the points of contact listed in the Section OUR
CONTACT DETAILS below.
Encryption of your data in transit.
Encryption provides a high level of security and privacy for your data. When you enter your data
in our platform we use strong encryption technologies (such as Transport
Layer Security) to protect your data during transmission from your devices to our servers.
For providing more trust and security we use digital
EV (Extended Validation) Certificates issued by trusted Certificate Authorities. You can see the
‘Green Bar’ in the supported browser versions which confirms what all
transmitted data is secure.
Protection of your data in our
infrastructure. We make it a priority to develop services that are secure "by
default". The "default" security of our services means that all new services and features are
designed with strict security requirements in mind before we even begin development. This is the
key to guaranteed protection and privacy of all data that our services handle and store, once
the service or new feature
is released.
To secure your data, we use the pseudonymisation
which allows most of our services to operate without using your actual data. Instead of that,
our services use a system ID that can't be traced back to identify you.
The Company is always vigilant about the security of
your data stored in our infrastructure. Because of that we locate all our equipment which is
used for your data processing in secure data centres. Network access to this
equipment is isolated from the Internet. We use network segmentation for isolation of services
which need different levels of security from each other. In addition, we restrict logical access
to your data for our employees
on a "need to know" basis. So, only the personnel that really requires access to your data for
the purpose of providing you with our best service, will have access to it.
Threats protection. Our Company is
highly knowledgeable about modern threats to data security and privacy, and we are well prepared
to combat them. All events that occur in our infrastructure are continuously
monitored, analysed and responded, which allows us to ensure proper protection of your data,
keeping it safe from threats, vulnerabilities, and the effects of malware.
In the event of a failure that affects the
accessibility of your data, we have data backup and recovery procedures in place that will help
us restore your data in a short time. To guarantee quick recovery, we use high availability
mode enabled for most critical databases which allows us to minimize downtime.
Employee awareness of data
security. Our employees may handle your data in order to provide you with the
first-class service. To guarantee the security and confidentiality of your data, we monitor all
employees’
actions with access to your data in our systems and grant access strictly on a "need to know"
basis: only employees who need access will receive it. We hold regular training sessions to make
sure that each employee
understands the principles that the Company follows to achieve robust data security and privacy.
If you choose not to give your personal
information. In the context of our business relationship we may need to collect
data by law, or under the terms of a contract we have with you. Without this data,
we are, in principle, not in a position to close or execute a contract with you.
If you choose not to give us this data, it may delay
or prevent us from meeting our obligations. It may also mean that we cannot perform services
needed to run your accounts or policies.
To what extent we carry automated
decision-making and profiling. In establishing and carrying out a business
relationship, we generally do not use automated decision-making. If we use this procedure in
individual cases, we will inform you of this separately. In some cases, we may proceed with
profiling in order to evaluate certain personal aspects. We shall inform you accordingly in case
we perform any profiling.
In general, any data collection that is optional would be made clear at the point of collection.
10. OUR CONTACT DETAILS
- Who is responsible for the data processing and who you can contact.
- The entity responsible for your data processing is Velta Capitals LLC and you
can contact us using the details set out below:
- Hinds Building, Kingstown, St. Vincent and the Grenadines
- Data Protection Officer
- We have appointed a data protection officer (hereinafter DPO)
who is responsible for overseeing questions in relation to this Privacy Policy. If you have
any questions about this privacy policy, including
requests relating to the data, please contact the DPO using the details set out below:
- Hinds Building, Kingstown, St. Vincent and the Grenadines
- internationaldpo@forexchasersbroker.com
- To enable us to process your request, please contact us using the registered
email address you disclosed and registered with us through your Account. We may require that
you provide us with proof of your identity, such
as by providing us with a copy of a valid form of identification. This is to ensure that we
appropriately protect the personal data we hold from unauthorised access requests and comply
with our security obligations.
- If you have any questions, or want more details about how we use your data, you
may contact us at the above contact details and we will be happy to provide you with further
details.
11. LINKS TO OTHER WEBSITES
We may provide links to third party websites in our
Website. These linked websites are not under our control, and we therefore cannot accept
responsibility or liability for the conduct of third parties linked to our websites,
including without limitation to the collection or disclosure of your data. Before disclosing
your data on any other website, we encourage you to examine the terms and conditions of using
that website and its privacy
policies.
12. CHANGES TO THIS PRIVACY POLICY
-
- This Privacy Policy was last updated 09 November 2020. We reserve the
right, at our discretion, to add, modify or remove portions of this Privacy Policy
in the future to ensure that the information herein provides
relevant and adequate information about our collecting and processing of your data.
- This privacy policy may be supplemented by other information received
from the Velta Capitals group and other terms and conditions applicable to the
Website or which you have agreed to as part of your interaction
with us.
- In case of updates, we will post the revised Privacy Policy on our
website. Changes will take effect as soon as the revised version is made available
on our website. Your comments and feedback are always welcome.
You may contact us at any time through the points of contact listed in the Section
OUR CONTACT DETAILS above.
APPENDIX A
-
- In relation to a company, that company, any subsidiary or subsidiary
undertaking or any holding company or holding undertaking or any connected company
from time to time of that company.
- An undertaking is a parent undertaking in relation to another
undertaking, a subsidiary undertaking, if
- a. it holds a majority of the voting rights in the undertaking,
or
- b. it is a member of the undertaking and has the right to
appoint or remove a majority of its board of directors, or
- c. it has the right to exercise a dominant influence over the
undertaking—
- d. by virtue of provisions contained in the undertaking's
articles, or
- e. by virtue of a control contract, or
- f. it is a member of the undertaking and controls alone,
pursuant to an agreement with other shareholders or members, a majority of
the voting rights in the undertaking.
- For the purposes of the above an undertaking shall be treated as a
member of another undertaking—
- a. if any of its subsidiary undertakings is a member of that
undertaking, or
- b. if any shares in that other undertaking are held by a person
acting on behalf of the undertaking or any of its subsidiary undertakings.
- A parent undertaking shall be treated as the parent undertaking of
undertakings in relation to which any of its subsidiary undertakings are, or are to
be treated as, parent undertakings; and references to its
subsidiary undertakings shall be construed accordingly.
- A company is connected with another company if:
- a. the same person has direct or indirect control of both
companies,
- b. a person (“A”) has control of one company and persons
connected with A have control of the other company,
- c. A has control of one company and A together with persons
connected with A have control of the other company, or
- d. a group of two or more persons has control of both companies
and the groups either consist of the same persons or could be so regarded if
(in one or more cases) a member of either group were replaced
by a person with whom the member is connected.