Privacy Policy

Last updated: 1 November 2023

This Privacy Policy, together with the User Agreement and its other essential parts, governs our collection, processing and use of Your Personal Data. As used in this Privacy Policy, “Xtrade”, “we”, “us” or “our” refers to Xtrade LTD, a company duly incorporated and validly existing under the laws of Saint Vincent and the Grenadines with the registration number 26557 BC 2021, having its registered office at Suite 305, Griffith Centre, Kingstown, Saint Vincent and the Grenadines.

Xtrade is a data controller under this Privacy Policy, which sets out the manner in which the company, as a data controller, may use Your Personal Data.

We and our affiliates and related parties undertake to exert maximum efforts in order to protect Your privacy. We use the information collected about you to fulfil our contractual obligations and improve customer service.
Please read this document carefully in order to understand our approach and policy regarding Your Personal Data and how we will use Your Personal Data.

1. WHAT DATA WE COLLECT ABOUT YOU

We may collect and process the following data about You:

Information You give to us

You provide us with the information about Yourself by filling in the relevant forms on the Trading Platform or by providing us such information by phone, email, during a video conference or in any other manner. This information includes Personal Data indicated by You whilst registering on the Trading Platform to open an Account and verifying the identity of the Account holder or Persons authorised to use it. Such information may also include the payment instruments used by You, Your activity on the Trading Platform while using the Account, such as searching for a Financial Instrument, using any of the Services provided by us, during participation in the draws, promotions or surveys, or when You communicate with us.
For example, the data that You provide to us, may include Your:

  • Last name and first name
  • Photos and videos that You may send to us for AML/CTF and KYC verification purposes
  • Residential address and citizenship
  • Gender
  • Copies of passport, driver’s license or any other government-issued ID
  • Copy of tax residency
  • Phone number and email address
  • Login information and nickname for accessing the Trading Platform
  • Bank details, including account number and payment details, and OFAC (Office of Foreign Assets Control) information
  • Date and place of birth
  • Education
  • Work experience and place of work
  • PEP (politically exposed person) status
  • Sources of funds and level of income
  • Information on the status of Your accounts opened with banks and/or payment systems
  • Inquiries and chat history with the customer support service
  • Trading balances and Account activity
  • Location and log data information that is generated resulting from Your use of the Trading Platform
  • Other personal information that may be required by our AML/CTF and KYC compliance obligations.

We do not collect nor process sensitive personal data of the Customers, such as race or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, health, sex life or sexual orientation information.

Information we collect about You

With regard to each of Your visits to the Trading Platform and use of our Services, we can collect the following information about You (including automatic collection):

  • Technical information, including the internet protocol (IP) address used to connect Your computer to the internet, Your Account login information, Your browser type and its version, time zone setting, browser plug-in types and versions, operating system and platform.
  • Information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Trading Platform (including date and time), products and Services You viewed or searched for, page response times, download errors, length of visits, page interaction information (such as scrolling, clicks, and mouse-overs), and methods You used to browse away from the page and any phone number You used to call our customer service.
  • Information about geolocation: we may collect information about real-time location based on information from Your device at any time while You download or use our Services; we may use this information to optimise Your experience.
  • Financial data and information on Your use of the Services and the Trading Platform, including  parameters of the executed Transactions, profits and losses earned commissions paid, deposits and withdrawals of funds.

Information we receive from the other sources

We may receive information about You if You use any of the other sites we operate or the other services we provide. We also work closely with the third parties (including, for example, business partners, sub-contractors, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about You from them. Such information may include:

  1. Information about the financial institutions through which You carry out deposits and withdrawals of funds
  2. Confirmations of the information You provided to us by the credit agencies
  3. The business partners that You collaborate with may provide us the information about Your finances, or name and address.

Your Personal Data, such as Your email and login that You provide to us whilst registering on the Trading Platform, is stored by us regardless of whether You finished the registration process or not. The same applies to Your Personal Data provided in the course of  AML/CTF and KYC verification processes.

2. USE OF COOKIE FILES

Cookies are typically stored on Your computer’s hard drive, which assigns a unique identification to Your computer. We also may use cookies stored in emails to help us confirm Your receipt of, and response to. We also may use service provider(s) who will place cookies on the hard drive of Your computer and will receive information that we select about the way our users and visitors navigate on our site, what products are browsed, and general transaction information.
Information collected from cookies is used by us to evaluate the effectiveness of our platform, analyze trends, and see what difficulties our visitors may experience in accessing the platform. We need this information to improve the quality of our service.
You are agreeing that we may use a browser feature known as a “cookie” for the purposes set above.

3. WHY WE USE YOUR PERSONAL DATA

We are going to use Your Personal Data for the following purposes:

Provision of our Services

  • To fulfill the obligations provided by any contracts concluded with You, as well as to give you the information, products, and Services that You requested
  • To ensure the security of our Trading Platform, our Services and Your Account
  • For administration of our Trading Platforms and for internal operations, including troubleshooting, data analysis, testing, statistical data collection, and conducting surveys
  • To give You access to the interactive features of the Trading Platform in case You wish to use them
  • To support, respond to, and resolve Your complaints and issues related to the use of our Services and the capabilities of our Trading Platform.

Informing You about our products and Services

  • To notify You about our other products and Services, similar to those that You have already received, or information that You searched for
  • To notify You about changes related to our products and Services.

Helping us improve our products and Services

  • To improve our Trading Platform and to make sure that our content is most appropriate for the operating system of Your computer or mobile device
  • To evaluate and understand the effectiveness of the promotional materials that we provide to You and other Customers, as well as to give you important advertising information
  • To ensure the most effective presentation of the content of our Trading Platform to You and Your use it from Your computer or mobile device.

Safeguarding vested interests

  • For risk management
  • For security and control of our IT systems, and crime prevention
  • For measuring the use of our Services and products for their further development
  • For internal business and research purposes, i.e. communication with You regarding our products and Services
  • For anonymized data analysis via web beacons and pixel tags to ensure our products and Services are relevant for the market we operate in.

Assuring legal procedures

  • To respond to law enforcement requests
  • To initiate and respond to legal claims
  • To investigate or settle disputes with You.

Complying with legal regulations

  • To verify and check the identity of the Customers who want to open and operate Accounts with us in order to prevent fraud, deception and other illegal activities
  • To comply with AML/CTF and KYC requirements as well as other applicable laws and regulations
  • To notify our Customers, e.g. of changes to policies and rules of our Trading Platform.

Marketing and third parties

  • To provide You by us, or by third parties appointed by us, with information about products or services that You, in our opinion, might be interested in. If You are an existing Customer, we will contact You via electronic means of communication (email or SMS) to inform You about products or services similar to those in a previous sale or negotiations to sell them to You. If You are a new Customer and since we allow certain third parties to use Your Personal Data, we (or they) will contact You only electronically and only upon Your consent. If You do not want us to use Your Personal Data in this way or transfer it to third parties for marketing purposes, please tick the appropriate box in the form in which we collect Your Personal Data.

4. DISCLOSURE OF YOUR PERSONAL DATA

We may share Your personal information with any of our subsidiaries, affiliates, our ultimate holding company and its subsidiaries.
We may share Your information with selected third parties including:

  • Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or You
  • Advertisers and networks that require specific data to select and serve relevant adverts to You and others. We do not disclose information about identifiable individuals to our advertisers. Still, we may provide them with the aggregate information about our Customers (for example, we may inform them that 500 females aged under 30 have clicked on their advertisement on any given day); we may also use such aggregate information to help advertisers reach the target audience (for example, women living in a particular region). 
  • Analytics and search engine providers that assist us in the improvement and optimization of our Trading Platform.

We may also disclose Your Personal Data to third parties in the following cases:

  • If we sell or buy any business or assets. Personal Data of the Customers may be disclosed to a potential buyer or seller
  • If we or all of our assets are purchased by a third party, the Personal Data of the Customers will be transferred to the acquirer
  • If we are required to disclose or transfer the Customer Personal Data in accordance with any applicable laws or to implement a decision of the court, requests of judicial and law enforcement authorities, or we are compelled to force Customers to comply with the terms and conditions of the agreements concluded with us
  • In case it is necessary to protect our own rights and property, to guarantee the safety of our company, our Customers or others. This includes the exchange of information with companies and organisations to prevent fraud and reduce the likelihood of default.

5. SECURITY AND STORAGE OF PERSONAL DATA

We have implemented security measures to ensure the confidentiality of Your Personal Data and to protect it from loss, misuse, alteration or destruction. Only authorised personnel of Xtrade have access to Your Personal Data, and these personnel are required to treat the information as confidential. Security measures in place will, from time to time, be reviewed in line with the legal and technical developments.

When storing or otherwise processing Your Personal Data by third parties, we guarantee that we will notify such third parties of our obligations under this Privacy Policy and will enter with them into relations that will impose obligations for them regarding Your Personal Data, provided that they at least have a level of protection as specified in this Privacy Policy. Such third parties, among other things, can process your requests, and payment details and provide technical support. By giving us Your Personal Data, You consent to the transfer, storage and processing of Your Personal Data. In our turn, we will take all necessary measures to ensure that Your Personal Data is processed in compliance with the security rules and in accordance with the provisions of this Privacy Policy.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect Your Personal Data, we cannot guarantee the security of Your Personal Data transmitted to our Trading Platform. In this regard, You are solely responsible for possible failures in the transfer of Your Personal Data to the Trading Platform. Once we have received Your Personal Data, we will use strict procedures and all necessary technical and security measures to prevent unauthorised access to Your Personal Data.

6. BASIS FOR PERSONAL DATA PROCESSING

We collect and process Your Personal Data only when we have a legitimate reason for such processing. Legal grounds include consent (in cases where You provide it), a contract (in cases where processing is necessary to fulfil the terms and conditions of contracts between You and us), compliance with a legal obligation (in cases where we are required to request/receive and process as well as to store Your Personal Data in order to comply with the requirements of applicable laws, for example the laws related to anti-money laundering and counter-terrorist financing), to use legitimate interest (for example, when processing is necessary to protect You or us from certain threats: fraud, security threats, etc.), for the proper level of conduct of our business (the quality of the services provided, identification of needs, preparation of reports), conclusion and implementation of corporate transactions (sale of participant interests/shares, mergers, acquisitions, etc.).

In cases where the basis for Personal Data processing is Your consent, You have the right to withdraw it at any time.

7. YOUR RIGHTS

By contacting us You can use the following rights:

  • The right to delete Your Personal Data (all or part thereof, considering, however, our regulatory requirements to retain Your personal data as set forth in clause 9 of this Privacy Policy)
  • The right to change or correct Your Personal Data, in particular when it is incorrectly stated
  • The right to object or restrict processing of Your Personal Data
  • The right to access Your Personal Data and/or copy of Your Personal Data, which You have provided to us, in a machine-readable format.

In addition, You have the right to prohibit the use of Your Personal Data for marketing purposes. Before requesting Your Personal Data, we usually inform You that we are going to use Your Personal Data or disclose it to third parties for promotional purposes. You can use the right to prohibit the processing of Your Personal Data for promotional purposes by putting a tick in the relevant field of the questionnaire. You can also exercise this right by contacting us at any time.

Please note that the exercise of some of Your rights as described in this Privacy Policy, in some cases may limit, complicate or completely exclude the possibility of further cooperation with us.

Our Trading Platform may contain active links from/to the websites of partner organisations, advertisers and affiliated companies. If You are following an active link, please note that other websites have their own privacy policies, and we are not responsible for the provisions of these policies. Please review the privacy policies of these websites before sharing Your Personal Data with them.

8. ACCESS TO PERSONAL DATA

General Data Protection Regulation gives You the right to access the information we hold about You. Your right of access can be exercised in accordance with the General Data Protection Regulation. Subject to Your written request sent to the email [email protected], we will provide You with the data we hold about You. In case Your request is manifestly unfounded or excessive or You request further copies of Your Personal Data following a request, we may charge You a fee of $10 (ten US Dollars).

9. RETENTION OF PERSONAL DATA

Making sure Your Personal Data is safe and secure is of the highest priority to us. We use secure storage facilities ensuring safeguarding of the personal Data You share with us at all stages of interaction with our Trading Platform, products and Services. All appropriate measures to secure Your Personal Data from potential hacks, loss or misuse are implemented by our security team.

We will hold Your Personal Data only for the duration of You using our products and Services via Your Account, having regard to the purposes described in this Privacy Policy as well as legal and regulatory provisions that we comply with. In accordance with our record-keeping obligations, we will retain Your Account information and Your Personal Data for at least a period of 7 (seven) years from the moment You cease to use our Services or the moment of the end of Your client relationship with us unless otherwise required by legal or regulatory reasons.

We may access Your Personal Data or retain it for a more extended period if it is subject to the official request or a legal obligation, an investigation by the government bodies or an investigation into a possible breach of our User Agreement and its essential parts, or in other cases to prevent potential harm based on our reasonable considerations.

If you cancel Your subscription to our email newsletter, we will hold Your email on an inactive email list.

10. CHANGES TO THIS PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to You by email. Please check back frequently to see any updates or changes to this Privacy Policy.

11. CONTACT

In accordance with the General Data Protection Regulation, You can contact us if you have any questions, complaints or concerns regarding our Privacy Policy or the way or purpose for which we handle Your Personal Data. For that purpose, please contact our Data Protection Officer at [email protected], and we will try to assist You promptly.

You can also reach us by post mail at Xtrade LTD, Suite 305, Griffith Centre, Kingstown, Saint Vincent and the Grenadines.

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