Privacy Policy

4.1 The Company will only use clients’ personal data in accordance with international data protection practices. In particular, the Company is registered as a Data Controller with the Office of the Commissioner for Personal Data Protection and will collect, process, maintain, store, use and handle clients’ personal information in accordance with the Processing of Personal Data (Protection of the Individual) Law of 138(1) 2001 and General Data Protection Regulation (2018) as amended from time to time (the “Law”) this Privacy Policy and the Company’s Trading Terms and Conditions.

4.2 During the online registration procedure as well as following the completion of the online registration procedure clients are required to provide personal information and to attach a series of required documents. In the event the client intends to deposit money to the Company’s client account using his payment card, in accordance with the recommendations of Payment Card Industry Security Standard Council, customer card details are protected using Transport Layer encryption – TLS 1.2.

4.3 We may collect such Personal Information from other persons including, for example, fraud prevention agencies, banks, other financial institutions, third authentication service providers and the providers of public registers and such other services that may from time to time be required for Company’s legitimate purposes.

4.4 “Personally identifiable information” (or “Personal Information”) means any information that may be used, either alone or in combination with other information, to personally identify, contact or locate any Customer of the Company (referred to as “User”).

4.5 Personal Information includes, but is not limited to:
a. First and Last name
b. ID/Passport numbers
c. Physical address
d. Date of Birth
e. Contact information such as telephone number and email address
f. Identity and Address verification documents such as passport and ID, utility bills and/or bank statements
g. Company information, company incorporation documents/certificates/details in case of a corporate account
h. Financial data such as estimated annual income and net worth, trading experience and investment knowledge including but not limited to trading data, deposits, withdrawals, and credit.
i. Payment details and bank account details

4.6 We are required by law to identify you if you are opening a new account or adding a new signatory to an existing account. Anti-money laundering laws require us to sight and record details of certain documents (i.e. photographic and non-photographic documents) in order to meet the standards, set under those laws. Identification documentation, as required under anti-money laundering legislation or other legislation relevant to the services we provide to you, includes, but not limited to (see Account Handling Procedure):
a) passport;
b) driver’s license;
c) national identity card (if applicable);
d) utility bills;
e) trust deed;
f) other information we consider necessary to our functions and activities.

4.7 Where it is necessary to do so, we also collect data regarding the following individuals:
a) trustees;
b) partners;
c) company directors and officers;
d) officers of co-operatives and associations;
e) client agents; or
f) individuals dealing with us on a “one-off” basis.

4.8 You have the option of not identifying yourself, or of using a pseudonym, when dealing with us in relation to a particular matter. However, we can only provide you with this option when it is not impracticable for us to do so and when no law requires identification.

4.9 In addition to the above, if you are an existing client of the Company and you wish to have online access to view statements and other information relating to your account, we will ask you to provide some information about yourself for security, identification and verification purposes.

7.1 The collection personal Information (not in the public domain or already possessed by us without a duty of confidentiality) which we hold is to be treated by us as confidential and will not be used for any purpose other than in connection with the provision, administration and improvement of our Services to you or the furthering of our Agreement between us, establishing and managing your Client Trading Account or a relationship between us, reviewing your ongoing needs, enhancing customer service and products, giving your ongoing information or opportunities that we believe may be relevant to you, improving our relationship, anti-money laundering and due diligence checks, for research and statistical purposes and for marketing purposes (according to the Agreement between us and as described in this Privacy Policy), as applicable.

7.2 We will use your personal information for the purposes of providing the services you have requested, for administration and customer services, for credit scoring, for marketing, for research/statistical analysis purposes and to ensure that the content, services and advertising that we offer are tailored to your needs and interests. We may keep your information for a reasonable period for these purposes. We may need to share your information with our service providers and agents for these purposes.

7.3 In assessing your application to open an account, to prevent fraud, to check your identity and to prevent money laundering, we may search the files of credit reference agencies that will record any credit searches on your file.

7.4 In order for the Company to provide, monitor and improve the quality service and security to its clients, the Company may use the clients’ personal information/data for one or more of the following purposes:
a. Verify the identity of clients;
b. To maintain clients’ personal profile;
c. Assess and improve the products and services provided to clients;
d. To such an extent as reasonably required so as to execute Orders and for purposes ancillary to the provision of the Services;
e. Company’s transmission/execution and post transaction/order services;
f. Assess and improve clients’ browsing experience;
g. Analysis of statistical data which will aid the Company to provide clients with better suited products and services in the future;
h. To pass clients’ personal information/data to third parties for marketing purposes without prior written consent;
i. To the Company’s professional advisors provided that in each case the relevant professional shall be informed about the confidential nature of such information and commit to the confidentiality herein obligations as well;
j. To other service providers who create, maintain or process databases (whether electronic or not), offer record keeping services, email transmission services, messaging services or similar services which aim to assist the Company collect, storage, process and use Client information or get in touch with the Client or improve the provision of the Services under this Agreement;
k. To a Trade Repository or similar under the Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4 July 2012 on OTC derivatives, central;
l. Counterparties (CCPs) and trade repositories (TRs) (EMIR);
m. To other service providers for statistical purposes in order to improve the Company’s marketing, in such a case the data will be provided in an aggregate form;
n. To an Affiliate of the Company or any other company in the same group of the Company;
o. To market research call centers that provide telephone or email surveys with the purpose to improve the services of the Company, in such a case only the contact details the data will be provided;
p. Inform clients of additional products, services or promotions relevant to its clients.

7.5 In regards to point (o) above and should for any reason clients do not consent to receive information of this nature, the client can inform us accordingly by contacting the Company on the contact details provided by the Company on its Trading Terms and Conditions or at the following address: AGeorgiou@XtellusEurope.com.

7.6 We may disclose personal data in order to comply with a legal or regulatory obligation.

7.7 We may contact you by mail, telephone, fax, e-mail or other electronic messaging service with offers of services or information that may be of interest to you. By providing us with your fax number, telephone numbers or email address you consent to being contacted by these methods for these purposes. If you do not wish to receive marketing information from us, you may not subscribe to our marketing services through the client’s area or if you are already subscribed you may press the “unsubscribe” button found on the bottom of our emails. For marketing emails, you can choose Unsubscribe button to stop receiving emails.

7.8 Any information, which we send to you by email, will not be encrypted. We cannot guarantee confidentiality of emails that you send to us.

7.9 You may ask us to provide you with information about our services or about services offered jointly with or on behalf of other organizations by sending us an email to AGeorgiou@XtellusEurope.com.
You have the following Rights:
a. The right to be informed
b. The right of access
c. The right to rectification
d. The right to erasure
e. The right to restrict processing
f. The right to data portability
g. The right to object
h. Rights in relation to automated decision making and profiling

7.10 Those whose Personal Data we keep, have the right at any time to obtain confirmation of the existence of the same from the Data Controller, to know the content and origin, to check its accuracy or request its integration, deleting, updating, rectification, erasure, anonymisation or blocking of Personal Data processed in violation of law, and to oppose in any case, for legitimate reasons, to their treatment.

7.11 To make a request, please contact us, verifying your identity and specifying what information you require. The Company may provide you a form to fill in, in order to process your request. We may charge an administrative fee.

7.12 Data controller and Data processor: The Company*

7.13 We may authorize another natural person, legal person, public administration or any other body, association or organization authorized to process the Personal Data in compliance with this Privacy Policy, on its behalf.

7.14 The Company does not provide any services to children, nor processes any personal data in relation to children, where ‘children’ are individuals who are under the age of eighteen (18).

12.1 Under the Agreement between us, we have the right to disclose Your Information (including recordings and documents of a confidential nature, card details) in certain circumstances. According to the Agreement between us, Your Information may be disclosed:
a) Protect the Company’s rights and/or to comply with judicial proceedings and/or court order;
b) Protect and defend the rights or property of the Company’s website;
c) Protect the safety of Company’s clients, all users of the Company’s website and/or the public.
d) Where required by law or a court order by a competent Court;
e) Where requested by the Cyprus Securities and Exchange Commission or any other regulatory authority having control or jurisdiction over the Company or the Client or their associates or in whose territory the Company has Clients;
f) To relevant authorities to investigate or prevent fraud, money laundering or other illegal activity;
g) To credit reference and fraud prevention agencies, third authentication service providers, banks and other financial institutions for credit checking, fraud prevention, anti-money laundering purposes, identification or due diligence checks of the Client. To do so they may check the details the Client supplied against any particulars on any database (public or otherwise) to which they have access. They may also use Client details in the future to assist other companies for verification purposes. A record of the search will be retained by the Company;
h) Where necessary in order for the Company to defend or exercise its legal rights to any court or tribunal or arbitrator or Ombudsman or governmental authority;
i) At the Client’s request or with the Client’s consent;
j) To successors or assignees or transferees or buyers, with ten Business Days prior Written Notice to the Client;