PRIVACY POLICY TeleTrade - DJ Internatinal Cnsulting Ltd May 2018 1
1. Intrductin 1. We are cmmitted t prtecting and respecting yur privacy. This Privacy Plicy ("Plicy") describes hw we treat infrmatin that yu prvide t us r that we cllect abut yu. 2. By persnal data, we refer t data that may be used t identify yu as a persn. Persnal data include yur name, yur address, yur telephne number, yur e- mail address, yur age, yur gender, a part f yur credit card number. Annymus infrmatin, which we are nt in a psitin t relate t yu, des nt qualify as persnal data. 3. TeleTrade is the persnal data cntrller fr the data gathered frm yu, and will be respnsible fr the prcessing f yur persnal data and will act as data cntrller fr the purpses f the Decree issued by the Minister f Finance f Cyprus fr the implementatin f the Multilateral Agreement n the Autmatic Exchange f Financial Accunt Infrmatin signed by the Cyprus Gvernment n Octber 29, 2014, n the basis f the Cmmn Reprting Standard develped by the OECD (the CRS Decree ), the Administrative Cperatin in the Field f Taxatin (Amending) Law f 2016 (ACFT Law) and the General Data Prtectin Regulatin (EU) 2016/679 (GDPR). 4. We may cllect persnal data as well as ther infrmatin when yu use the fllwing services: Our websites, including https://www.teletrade.eu/, https://my.teletrade.eu/?, https://teletrade-dj.it/, https://teletrade-dj.lv/ru, https://teletrade-dj.cz/, http://teletrade-dj.r/, https://teletrade-dj.pl/, http://teletrade.hu/, https://teletrade.pt/, https://teletrade-dj.lt/, http://teletrade-dj.gr/ and any ther Teletrade sites n which this Plicy is psted (the "Sites"). Yur creatin and use f a Teletrade Client Lgin ID when cmpleting the registratin prcess at https://my.teletrade.eu/? (a Client ID ). Yur creatin and use f a Teletrade trading accunt (an "Accunt"). Fr mre infrmatin n Accunts and hw t create an Accunt please see ur Legal Dcumentatin. Yur use f any f ur ther prducts and services (including supprt services) which may be accessible via a third party platfrm, web applicatin r scial netwrking service (tgether the "Ancillary Services"). In this Plicy we refer t the Sites, the Client Lgin ID, the Accunt and the Ancillary Services tgether as the "Services". 5. Please read this Plicy carefully. If yu d nt agree t this Privacy Plicy, please d nt attempt t use the Services.. By registering an Accunt with Teletrade and using ur prducts and Investment Services Teletrade is legally bliged t cllect and prcess yur persnal data which is required fr the prvisin f the services. 2
By accepting this Plicy, yu signify yur cnsent t the cllectin and ther prcessing f yur persnal data in accrdance with and fr the purpses set ut in this Plicy 2. Wh we are We ("TeleTrade", "we", "ur" and "us") are: Teletrade-DJ Internatinal Cnsulting Ltd, Esperidn 5, 4 th flr, Strvls, Nicsia 2001 Cyprus We respect yur right t privacy and will nly prcess persnal data and ther infrmatin yu prvide t us r we cllect abut yu in accrdance with applicable privacy and persnal data prtectin laws. 3. Infrmatin we may cllect frm yu When yu use the Services we may cllect the fllwing categries f data: A) When yu sign up fr ur marketing cmmunicatins, register yur general interest in ur prducts and services at ur web-sites, r register a Client Lgin Page, we cllect and prcess the fllwing "Client Data": Yur first name and last name, e-mail address and phne number. B) When yu pen a Trading Accunt, we cllect and prcess the fllwing "Trading Accunt Data": Yur first name and last name, yur gender, date and place f birth, cuntry f citizenship, residential address, e-mail address, telephne number, Client Lgin ID, passwrd, financial backgrund and prir trading experience required in rder t carry ut the apprpriateness test as per the applicable regulatry framewrk Emplyment histry & surce f funds infrmatin required t accept yur funds depsits in accrdance with AML legislatin. Furthermre yur jurisdictin(s) f residence, tax identificatin number, and, in relatin t the accunt(s), the accunt number, the accunt balance r value as f the end f the relevant calendar year r ther apprpriate reprting perid, as well as any incme generated in the accunt(s) held with TeleTrade, are gathered and prcessed pursuant t the CRS Decrees, the ACFT Law and the GDPR. C) When yu depsit funds t yur trading accunt, we cllect and prcess the fllwing "Payment Infrmatin" that is necessary fr the adequate perfrmance f the cntract 3
between yu and TeleTrade and t allw fr the effective cmpliance with AML legal bligatins by Teletrade: A part f yur credit card number, and infrmatin abut yur credit card issuer. D) Financial infrmatin necessary t prcess yur rders with respect t Teletrade Services with the relevant payment merchant, which will nly be submitted directly t the payment merchant under secure prtcls. This Infrmatin may include the amunt f any payment transactins, the payment instrument used, date and time, payment amunt, payment instrument expiratin date, electrnic wallet email address, IBAN infrmatin fr bank transfers, yur address and ther related transactin details.when yu use the Services, we may cllect and prcess the fllwing "Tracking Data": Lcatin infrmatin assciated with yur IP address when yu visit ur Sites Infrmatin relating t yur use f ur Services including, but nt limited t, infrmatin abut when and hw yu use the Services and data traffic Lg files and statistics in relatin t actins taken n ur Sites Technical infrmatin abut any device that yu use when yu visit the Sites such as yur IP address and the brwser yu are using. Fr the cllectin and prcessing f Tracking Data n the Sites we use ckies. Their functinality and yur ptins regarding their use are explained in sectin 4 herein belw. 4. Ckies The Sites use ckies and similar technlgies that cllect Tracking Data t distinguish yu frm ther users. This helps us t prvide yu with a gd experience when yu access the Sites and use the Services. A ckie is a small file f letters and numbers that a website places n yur cmputer r device when yu visit a website. Yu are given the pprtunity t cnsent t using f ckies r refuse frm them as yu enter ur Sites. If yu have pted ut, we nly use the strictly necessary ckies (as described belw) and stre ne permanent cmpliance ckie which tells us that yu want t pt ut f use f any ther ckies. Fr mre infrmatin abut ckies, we recmmend that yu visit www.allabutckies.rg. The ckies that are used n the Sites fall int the categries described belw. These descriptins can help yu determine if and hw yu wuld like t interact with ur Sites and ther nline services: Strictly necessary ckies These ckies are essential in rder t enable yu t navigate the Sites and use certain features. Withut these strictly necessary ckies, the nline services prvided by the Sites cannt be prvided. It is therefre nt pssible fr yu t pt ut f use f these ckies. In additin, the cding language the Sites are written in uses sessin ckies and 4
their use cannt be avided. These are deleted each time yu clse yur brwser. These ckies d nt stre any infrmatin abut the visitr nce the brwser is clsed. Perfrmance ckies Our perfrmance ckies cllect annymus infrmatin abut hw yu use the Sites and their features. Fr instance, ur perfrmance ckies cllect infrmatin abut which pages n the Sites are visited mst ften, which advertisements yu view r interact with n the Sites r ther websites n which ur advertisements appear and if yu receive any errr messages. Analytics ckies The Sites use Ggle Analytics, a web analytics service prvided by Ggle, Inc. ("Ggle"). Ggle Analytics uses "ckies", which are text files placed n yur cmputer, t help us analyse hw users use the Sites. The infrmatin generated by the ckie abut yur use f the Sites (including yur IP address) will be transmitted t and stred by Ggle n servers in the United States. In case f activatin f the IP annymisatin, Ggle will truncate/annymize the last ctet f the IP address fr Member States f the Eurpean Unin as well as fr ther parties t the Agreement n the Eurpean Ecnmic Area. Only in exceptinal cases, the full IP address is sent by us t and shrtened by Ggle servers in the USA. On behalf f us, Ggle will use this infrmatin fr the purpse f evaluating yur use f the Sites, cmpiling reprts n website activity fr us and prviding ther services relating t website activity and internet usage t us. Ggle will nt assciate yur IP address with any ther data held by Ggle. The Sites may use ther similar analytics ckies. These ckies are used t cllect infrmatin abut hw visitrs use the Sites. The infrmatin is cllected annymusly, and used t reprt n the number f visitrs t the Sites, where the visitrs have cme frm, and the pages they have visited. Furthermre yu can prevent Ggle s cllectin and use f data (ckies and IP address) by dwnlading and installing the brwser plug-in available under https://tls.ggle.cm/dlpage/gaptut. Further infrmatin can be fund under http://www.ggle.cm/analytics/terms/gb.html (Ggle Analytics Terms f Service & Privacy). Please nte that n the Sites, Ggle Analytics cde is supplemented by "gat._annymizeip();" t ensure an annymized cllectin f IP addresses (s called IPmasking). Als, yu can prevent Ggle Analytics t cllect such data n behalf f Teletrade by clicking n the fllwing link: https://tls.ggle.cm/dlpage/gaptut. Functinality ckies Functinality ckies are used t remember chices yu make (such as language preference, cuntry lcatin, r ther nline settings) and cllect annymus infrmatin. If yu wish t refuse the use f ckies by us r by third parties, yu can change yur brwser settings t reject ckies. As the means by which yu can d this varies frm brwser t brwser, please visit yur web brwser's "Help" menu fr further details. Please nte that, shuld yu chse t refuse the use f ckies by us, this might impair sme f the functinality f the Sites and the Services. 5
5. Hw we use yur infrmatin We may use the infrmatin that yu prvide t us r that we cllect abut yu fr the fllwing purpses: 1. Prvisin f services. Client Data, Trading Accunt Data and Tracking Data may be cllected and prcessed by us t prvide yu with the Services that yu request frm us and t perfrm the respective Operative Agreement (e.g. Client Agreement, Terms & Cnditins) accepted by yu. Data cllected fr that purpse will nly be kept as lng as necessary t prvide the requested Services. 2. Cmpliance with applicable legislatin and regulatry framewrk. Any data cllected may be prcessed by us t detect, investigate and prevent activities that may be illegal, that may vilate the Operative Agreement and als t cmply with the requests fr infrmatin f the cmpetent regulatry r lawful authrities. Such data will be kept fr a minimum duratin f 5 years after the Accunt clsure in accrdance with the current applicable laws. 3. Creatin f additinal prmtin and advertising: We may use the e-mail address registered t yur Client Lgin ID t prvide yu with infrmatin abut prducts and services related t ur Services, if yu agree t this service at the time yur Client Lgin ID is created. Yu may als pt-ut frm use f yur e-mail address fr this purpse at any time, by sending an e-mail frm the e-mail address registered t yur Client Lgin ID t supprt@teletrade.eu stating that yu d nt wish t receive such infrmatin. Alternatively, yu may pt ut by fllwing the unsubscribe instructins at the bttm f each e-mail yu receive frm us. We may use Tracking Data t mnitr, imprve, r mdify the Services and ur peratins. We may use the e-mail address and/r phne number that yu registered with us via cntact frms at ur web sites, t prvide yu with infrmatin abut ur prducts, services and prmtins, if yu agreed t receive this kind f infrmatin while registering with us. Yu may als pt-ut frm use f yur e-mail address fr this purpse at any time, by sending an e-mail frm the e-mail that was registered with us t supprt@teletrade.eu stating that yu d nt wish t receive such infrmatin. Alternatively, yu may pt ut by fllwing the unsubscribe instructins at the bttm f each e-mail yu receive frm us. 6. Sharing yur infrmatin We will nt share yur persnal data with anyne else unless in the fllwing limited circumstances: T the extent that we are required t d s by applicable law, by a gvernmental/ regulatry bdy r by a law enfrcement agency, r fr crime preventin purpses. 6
In rder t prvide the Services t yu, Teletrade is legally required t pass n yur persnal data t the relevant tax authrities f the Republic f Cyprus, and they may als be exchanged with tax authrities in anther cuntry r in ther cuntries where Yu, the Client may be a tax resident in accrdance with the CRS decree, and the ACFT Law. In rder t prvide the Services t yu in accrdance with the Law L. 87(I)/2017 regarding the prvisin f Investment services, the exercise f investment activities and the peratin f regulated markets (the Investment Services Law) Teletrade is legally required t reprt t the Cyprus Securities and Exchange Cmmissin ( CySEC ), infrmatin abut yur transactins in financial instruments the underlying f which are traded n regulated markets. Such infrmatin includes yur persnal details, such as first name, last name, cuntry f citizenship, date f birth and ther persnal identificatin data.. Where necessary t, we may share yur persnal data with third parties wh prvide services t us, TeleTrade uses a variety f third party service prviders t help us prvide yu with Services yu request frm us. Service prviders may be lcated inside f the Eurpean Ecnmic Area ( EEA ). Service prviders may help us: (i) verify yur identity r authenticate yur identificatin dcuments, (ii) check infrmatin against public databases, (iii) cnduct backgrund r plice checks, fraud preventin, and risk assessment, (iv) perfrm prduct develpment, maintenance and debugging, r (v) prvide custmer service, advertising, r payments services. These prviders have limited access t yur infrmatin t perfrm these tasks n ur behalf, and are cntractually bund t prtect and t use it nly fr the purpses fr which it was disclsed and cnsistent with this Privacy Plicy. 7. Children We recgnize that we have a special bligatin t prtect persnal infrmatin btained frm children. We will nt knwingly cllect persnal infrmatin frm any child, r prcess such infrmatin, withut parental cnsent. Fr the purpse f this Plicy, a child means any individual wh is under the age f 18 (r the minimum legal age t cnsent t the cllectin and prcessing f persnal infrmatin where this is different under applicable law). 8. Security Teletrade has implemented all reasnable technical, administrative and physical security measures t prtect the security f yur persnal infrmatin and all client data including the placing f financial transactins and/ r rders. The whle netwrk cmmunicatin in the cntext f sharing financial and/ r persnal infrmatin is prtected by the use f a passwrd and fllwed by encryptin. All received infrmatin that the client prvides is stred n secure servers and nly authrized staff have access t this infrmatin. We take reasnable precautins t prevent the lss, misuse 7
r alteratin f yur persnal infrmatin. Our emplyees, cntractrs and agents may be given access t yur persnal infrmatin which we cllect, but their use shall be limited t the perfrmance f their duties in relatin t facilitating yur use f the Services. Our emplyees, cntractrs and agents wh have access t yur persnal infrmatin are required t keep that infrmatin cnfidential and are nt permitted t use it fr any purpses ther than thse listed abve r t deal with requests which yu submit t us. 9. Third party sites & services The Services may cntain links t ther websites perated and services prvided by third parties, including thse retailers yu enter int a transactin with. Please nte that this Plicy applies nly t the persnal infrmatin that we cllect thrugh the Services and we cannt be respnsible fr persnal infrmatin that third parties may cllect, stre and use thrugh their websites r their services. Yu shuld always read the privacy plicy f each website yu visit carefully. If yu link, cnnect, r lgin t yur TeleTrade client lgin ID via a third party service (e.g. Ggle, Facebk etc), the third party service site may send us infrmatin such as yur registratin and prfile infrmatin frm that service. This infrmatin varies and is cntrlled by that service r as authrized by yu via yur privacy settings at that service. If yu have chsen t cnnect yur TeleTrade persnal page t a third-party applicatin, yu can change yur settings and remve permissin fr the app by changing yur Client Lgin ID (Persnal Page) setting at any time. Yu are respnsible fr keeping yur persnal infrmatin with such third party applicatins up-t-date and secure s as t ensure the integrity f yur TeleTrade Client Lgin Page. 10. Yur rights In additin t yur pt-ut right under sectin 5.3., yu may exercise the fllwing rights at any time: Yu may ask us t prvide yu with cpies f the persnal infrmatin that we hld abut yu, r with infrmatin abut the prcessing f such infrmatin. Yu may ask us t update and crrect any ut-f-date r incrrect persnal infrmatin that we hld abut yu. Yu may ask us t delete the persnal infrmatin we hld abut yu. If yu wish t exercise any f these rights, then please cntact us at supprt@teletrade.eu Please nte that if yu request the erasure f yur persnal infrmatin: We may retain sme f yur persnal infrmatin as necessary fr ur legitimate business interests, such as fraud detectin and preventin and enhancing safety. 8
We may retain and use yur persnal infrmatin t the extent necessary t cmply with ur legal bligatins. Please nte that we are legally bliged t keep n recrd all and any infrmatin that pertains t the prvisin f investment services t yu and which is necessary t fulfill ur bligatins under the applicable laws fr a perid f up t 7 years after accunt clsure. Sme cpies f yur infrmatin (e.g., lg recrds) may remain in ur database, but are disassciated frm persnal identifiers. Because we maintain security measures t prtect ur data frm accidental r malicius lss and destructin, residual cpies f yur persnal infrmatin may nt be remved frm ur backup systems fr a limited perid f time. Where yu have prvided yur cnsent t the prcessing f yur persnal infrmatin by Teletrade, yu may withdraw yur cnsent at any time by sending a cmmunicatin t us specifying which exact cnsent yu are withdrawing. Please nte that the withdrawal f yur cnsent des nt affect the lawfulness f any prcessing activities based n such cnsent befre its withdrawal. Additinally, in sme jurisdictins, applicable law may give yu the right t limit the ways in which we use yur persnal infrmatin, in particular where (i) yu cntest the accuracy f yur persnal infrmatin; (ii) the prcessing is unlawful and yu ppse the erasure f yur persnal infrmatin; (iii) we n lnger need yur persnal infrmatin fr the purpses f the prcessing, but yu require the infrmatin fr the establishment, exercise r defense f legal claims. Yu have the right t cmplain t the Data Prtectin Cmmissiner s Office if yu feel that Teletrade has nt respnded t yur requests t slve a prblem. Yu can find their cntact details here: http://www.dataprtectin.gv.cy/ 11. Changes t this Plicy We may change this Plicy frm time t time fr varius reasns such as changes t reflect in law and regulatin, changes in industry practices and technlgical develpments. In case yu have a registered Client Lgin ID, yu will be ntified f any changes f this Plicy via e-mail t the e-mail address related t yur Client Lgin ID. The latest versin f this Plicy will always be available n the Sites. Any new versin f this Plicy shall take effect (i) immediately upn the date f yur receipt f the ntificatin e-mail where the changes t this Plicy relate t nnmaterial changes which d nt reduce yur rights; r (ii) n less than thirty (30) days after yur receipt f the ntificatin e-mail where the changes t this Plicy ptentially reduce yur rights; r (iii) in case yu d nt have a registered Client Lgin ID, the mment they are upladed t ur Sites. 12. Enquiries If yu have any enquiries abut this Plicy, r any questins abut the use f yur persnal infrmatin, please e-mail us (supprt@teletrade.eu) r call us (+357 22 51 44 42). 9