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Privacy Policy

1. Introduction

1.1. DY TRADE LIMITED (referred to as the ‘Company’) provides you with this ‘Privacy Policy’ (the Policy) to help you understand the risks that might arise when trading Contracts for Difference (CFDs). However, you need to bear in mind that the Policy does not contain all the risks and aspects involved in trading CFDs. The Client should carefully read the Policy in conjunction with the 'Client Agreement', the ‘Order Execution Policy’ and the documentation/information available to you through our Website.

1.2. This Policy outlines the Company’s responsibility to manage the protection of privacy and the safekeeping of client’s personal and financial information. Your privacy is Company’s highest priority and applies to all users of the Company’s website, whether you are former, present or potential client of the Company.

1.3. The Company follows different principles in accordance with global protection acts in order to achieve client privacy and data protection. By subscribing to and/or using the Service, the Client expresses his consent to the terms of this Policy. If the Client hereby gives its consent to such collection, processing, storage and use of personal information by the Company as explained below.

1.4. In addition, as a recipient of our Service, the Client commits to provide appropriate notice of its privacy practices to, and obtain the necessary permissions and consent from any User whose Personal Information is collected, received, used and/or disclosed (collectively, “Process(ed)”) by the Company

2. Safeguarding the confidentiality of your personal information and protecting your privacy

2.1. The Company respects the privacy of any users who access its website(s), and it is therefore committed to taking all reasonable steps to safeguard any existing or prospective clients, applicants and website visitors.

2.2. The Company keeps any clients’/potential clients’ personal data in accordance with the applicable data protection laws and regulations.

2.3. We have the necessary and appropriate technical and organisational measures and procedures in place to ensure that your information remains secured at all times. We regularly train and raise awareness to all of our employees on the importance of maintaining, safeguarding and respecting your personal information and privacy. We regard breaches of individuals’ privacy very seriously and will impose appropriate disciplinary measures, including dismissal where necessary. The personal information you provide us with when registering yourself as a user of the Company’s website(s) and/or of its services, is classified as registered information, which is protected in several different ways. You can access your registered information after logging into the Client Area by entering a username and a password that you select. It is your responsibility to make sure that your password is only known to you and not disclosed to anyone else. Registered information is securely stored in a safe location and only authorized personnel have access to it via a username and password. All personal information is transferred to the Company over a secure SSL connection and thus all necessary measures are taken to prevent unauthorized parties from viewing any such information. Personal information provided to the Company that does not classify as registered information is also kept in a safe place and accessible by authorized personnel only via a username and a password.

2.4. Transmission of information via the internet is not always completely secure, but the Company endeavors to protect your personal information by taking serious precautions. Once we have received your personal information, we will apply procedures and security features to try to prevent unauthorized access.

3. Personal information we collect

3.1. In order to open an account with us, you must first complete and submit an application form to us by completing the required information. By completing this form, you are requested to disclose personal information in order to enable the Company to assess your application and comply with the relevant rules and regulations. The information you provide may also be used by the Company to inform you regarding its services

3.2. We obtain this information in a number of ways through your use of our services including through any of our websites, apps, account opening applications, our demo sign up forms, webinar sign up forms, subscribing to news updates and from information provided in the course of ongoing customer service communications. We may also collect this information about you from third parties such as through publicly available sources. We also keep records of your trading behavior, including records regarding the following:

a. Products you trade with us and their performance

b. Historical data about the trades and investments you have made including the amount invested

c. Your preference for certain types of products and services

We may ask for other personal information voluntarily from time to time (for example, through market research or surveys).

3.3. We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our business relationship with you. These recordings will be our sole property and will constitute evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or any other further notice.

Further, if you visit any of our offices or premises, we may have CCTV which will record your image.

4. Processing of personal information and purposes

4.1. We may process your personal information on the following basis and for the following purposes:

a. Performance of contractual obligations: we process personal information in order to provide our services and products, as well as information regarding our products and services based on the contractual relationship with our clients (i.e. so as to perform our contractual obligations). In addition, processing of personal data takes place to be able to complete our client on-boarding/acceptance procedures.: we process personal information in order to provide our services and products, as well as information regarding our products and services based on the contractual relationship with our clients (i.e. so as to perform our contractual obligations). In addition, processing of personal data takes place to be able to complete our client on-boarding/acceptance procedures.

In view of the above, we need to verify your identity in order to accept you as our client and we will need to use those details in order to effectively manage your trading account with us to ensure that you are getting the best possible service from us. This may include third parties carrying out credit or identity checks on our behalf. The use of your personal information is necessary for us to know who you are as we have a legal obligation to comply with certain Know Your Customer and Customer Due Diligence requirements.

b. Compliance with a legal obligation: there are a number of legal obligations emanating from the relevant laws and supervisory authorities to which we are subject as well as statutory obligations (e.g. the Anti-Money Laundering Laws, Financial Services Laws, Corporation Laws, Privacy Laws and Tax Laws). Such obligations and requirements impose on us necessary personal data processing activities for credit-checks, identity verification, compliance with court orders, tax law or other reporting obligations and anti-money laundering controls. These obligations apply at various times, including client onboarding, payments and systemic checks for risk management.

c. Safeguarding legitimate interests: we process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. Despite that, it must not unfairly go against what is right and best for you. Examples of such processing activities include the following:

- Initiating legal claims and preparing our defense in litigation procedures

- Means and processes we undertake to provide for the Company’s IT and system security, preventing potential crime, asset security, admittance controls and anti-trespassing measures

- Setting up CCTV systems (e.g. at our premises for security purposes)

- Measures to manage business and for further developing products and services

d. You have provided your consent: our storage and use of personal data is based on your consent (other than for the reasons described or implied in this policy when your consent is not required). You may revoke consent at any time; however, any processing of personal data prior to the receipt of your revocation will not be affected.

e. To assess the appropriateness of our services/products for the Clients

f. To provide you with products and services, or information about our products and services and to review your ongoing needs: once you successfully open a trading account with us, or subscribe to an update or webinar, we will need to use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to ensure that we are providing the best products and services so we may periodically review your needs to ensure that you are getting the benefit of the best possible products and services from us.

g. To help us improve our products and services, including customer services, and develop and market new products and services: we may from time to time use personal information provided to you through your use of the services and/or through client surveys to help us improve our products and services. It is in our legitimate interests to use your personal information in this way to try to ensure the highest standards when providing you with our products and services and to continue to be a market leader in the financial services industry.

h. To form a profile about you: we may from time to time use personal information provided to you through your use of the services and/or through client surveys to help us improve our products and services. It is in our legitimate interests to use your personal information in this way to try to ensure the highest standards when providing you with our products and services and to continue to be a market leader in the financial services industry.

i. To investigate or settle enquiries or disputes: we may need to use personal information collected from you to investigate issues and/or settle disputes with you as it is in our legitimate interests to ensure that issues and/or disputes get investigated and resolved in a timely and efficient manner.

j. To comply with applicable laws, court orders, other judicial processes, or the requirements of any applicable regulatory authorities: we may need to use your personal information to comply with any applicable laws and regulations, court order or other judicial process, or the requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.

k. To send you surveys: from time to time, we may send you surveys as part of our customer feedback process. It is in our legitimate interest to ask for such feedback to try to ensure that we provide our services and products at the highest standards. However, we may, from time to time, also ask you to participate in other surveys and if you agree to participate in other surveys we rely on your consent to use the personal information we collect as part of such surveys. All responses to any survey we send out whether for customer feedback or otherwise will be aggregated and depersonalized before survey results are shared with any third parties

5. Disclosure of your personal information

5.1. The Company shall not disclose any of its clients’ confidential information to a third party, except:

a. To the extent that it is required to do so pursuant to any applicable laws, rules and/or regulations

b. If there is a duty to the public to disclose

c. If our legitimate business interests require disclosure

d. At your request or with your consent or to persons described in this Policy

5.2. The Company will endeavor to make such disclosures on a ‘need to know’ basis, unless otherwise instructed by a regulatory authority. Under such circumstances, the Company will notify the third party regarding the confidential nature of any such authority.

5.3. As part of using your personal data for the purposes set out above, the Company may disclose your personal information to the following:

a. Our Associates, for business purposes, including certain third parties such as service providers and specialist advisers who have been contracted to provide us with administrative, financial, legal, insurance, research or other services

b. Business introducers with whom we have a mutual business relationship

c. Business parties, credit providers, courts, tribunals and regulatory authorities as agreed or authorized by Law

d. Payment service providers (PSPs) and/or banking institutions in relation to issues raised regarding deposits/withdrawals to/from trading account(s) held with the Company and/or for the purpose of commencing an investigation regarding such matters (e.g. third party deposits)

e. Anyone authorized by you

5.4. If the Company discloses your personal information to business parties, such as card processing companies or banks, in order to perform the services requested by clients, such third parties may store your information in order to comply with their legal and other obligations.

5.5. Generally, we require that organizations outside the Company who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all relevant data protection laws and this Privacy Policy. Third party service providers such as credit referencing agencies (if and when applicable) may keep record of any searches performed on our behalf and may use the search details to assist other companies in performing their searches. Please note that the use of your personal information by external third parties who act as data controllers of your personal information is not covered by this Privacy Policy and is not subject to our privacy standards and procedures.

5.6. Clients accept and consent that the Company may, from time to time, analyze the data collected while visiting our website(s) or by other means, such as questionnaires, for statistical purposes in order to improve the Company’s business activities.

6. Legal disclaimer

6.1. The Company may disclose your personally identifiable information as required by rules and regulations and when the Company believes that disclosure is necessary to protect our rights and/or to comply with any proceedings, court order, legal process served or pursuant to governmental, intergovernmental or other regulatory bodies. The Company shall not be liable for misuse or loss of personal information or otherwise on the Company’s website(s) that the Company does not have access to or control over. The Company will not be liable for unlawful or unauthorized use of your personal information due to misuse or misplacement of your passwords, negligent or malicious intervention and/or otherwise by you or due to your acts or omissions or a person authorized by you (whether that authorisation is permitted by the terms of our legal relationship with you or not).

7. Changes in this privacy policy

7.1. Our Privacy Policy is reviewed from time to time to take into account new laws and technologies, changes to our operations and practices, and to ensure that it remains appropriate to the changing environment.

7.2. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

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