Before using any services offered by Aglobe Investments Ltd. and submitting any personal data, you should familiarize yourself and agree with the principles and conditions set forth in this policy. You can acknowledge the given terms voluntarily by ticking a corresponding checkbox on the initial Trader’s Room registration form.
1.1 Client - means any individual or a legal entity who has expressed a desire to use, who is using or who has used Aglobe Investments’ Ltd provided investment services until termination of Client relationship.
1.2 Client Data - any sort of information, including personal data known by Aglobe Investments Ltd regarding the Client. With legal entity Clients, Aglobe Investments Ltd processes legal entity’s representative’s, beneficiaries and other related persons personal data to the extent required by law. The various categories of Client Data are specified in section 4 of this document.
1.3 Processing of Client Data - means any action that is performed with the Client data, including personal data that is gathered, recorded, structured, safekept, changed, forwarded, deleted, archived, etc.
1.4 Data Controller - Aglobe Investments Ltd as an investment firm providing the Client investment service acts as a Data Controller with Client’s Data.
1.5 Authorised Data Processor and/or other Third party - Aglobe Investments Ltd may also use authorised external third-party processors for Client Data processing, based on concluded service agreements, which are governed by instructions from Aglobe Investments Ltd for the protection of Client related data. Aglobe Investments Ltd shall ensure that such data processors process Client Data only in accordance with instructions from Aglobe Investments Ltd and in conformity with the requirements for data protection.
2.1 Processing of Client Data at Aglobe Investments Ltd takes place in accordance with requirements set in the relevant laws that are applicable in the Republic of Seychelles from time to time.
2.2 Aglobe Investments Ltd takes reasonable steps to protect your personal information by storing it in a secure environment. In order to prevent unauthorised access or disclosure, Aglobe Investments Ltd has put in place suitable physical, electronic and managerial procedures to safeguard and secure the collected information. Aglobe Investments Ltd also takes reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
2.3 Aglobe Investments Ltd is entitled to unilaterally amend the given policy at any time by notifying the Clients not later than 14 days prior of any significant amendments via the Aglobe Investments Ltd website, email or through the Trader`s Room. In issues not regulated by this policy, Terms of Business shall apply.
2.4 Aglobe Investments Ltd will not sell or lease your personal information to third parties.
3.1 the Client has given consent to the processing of his or her personal data for one or more specific purposes;
3.2 Aglobe Investments Ltd legitimate interests are expressed in furtherance of its own operating activity in offering Clients better services and products, developing its own products, ensuring data and information security and performance of general legal obligations set forth in legal acts.
3.3 On the basis of consent for Processing of Client Data, Aglobe Investments Ltd shall ask for consent, e.g., on relevant applications and requests, and will enable the Client to provide its consent voluntarily.
4.1 Aglobe Investments Ltd has the right and the duty by virtue of its area of activity to check the accuracy of the Client data contained in the databases by periodically asking the Client to review and/or correct or confirm the accuracy of the Client data pertaining to the Client. Aglobe Investments Ltd does not collect sensitive information about the Client.
4.2 Aglobe Investments Ltd gathers Client Data mainly from the Client (e.g. applications and requests, in the course of Client interaction) and in the course of use of the services by the Client (e.g. execution of payments and transfers, forwarding of securities orders, performance of contracts etc).
4.3 Aglobe Investments Ltd also obtains and verifies Client Data from Third Parties, such as:
4.4 The following is a list of the types of Client Data and the main purposes for which Aglobe Investments Ltd processes Client Data.
|Client Data||Purpose for processing|
|1. Personal Data(e.g. name, personal identification code, date of birth, data on the identity document)||Identification of Client|
|2. Contact details(e.g. telephone, email, address, language of contact)||Client interaction
|3. Data on tax residency (e.g. country of location, taxpayer identification number, citizenship)||Gathering and reporting tax-related information|
|4. Data on area of activity (e.g. profession, education, data on employer)||Evaluating the Client’s creditworthiness for payments on the trading account|
|5. Financial data (e.g. income, obligations, liquid assets, planned amount of first deposit)||Evaluating the Client’s creditworthiness for payments on the trading account|
|6. Data on the Client’s trustworthiness and origin of assets and wealth (e.g. data on payment history, data on connections to money laundering, terrorism financing or organised crime, data on employer, transaction partners, beneficial ownership, income sources, data on business activity, related persons, whether the Client is a politically exposed person)||Compliance with due diligence requirements|
|7. Data on the Client’s expertise (e.g. the Client’s investment knowledge and experiences, educational attainment, profession, investment goal)||Evaluating the appropriateness and suitability of product, service and securities offered to the Client and assessing the Client’s expertise|
|8. Data related to securities (e.g. securities transactions and transaction orders, quantity of securities, transaction volumes, transaction value, LEI code)||Transaction reporting and monitoring with regard to characteristics of market abuse and reporting of suspicious transactions|
|9. Communication Data (communication held via electronical means, phone recording, visits to office)||Compliance with due diligence requirements
Security risk management
|10. Data on the Client’s habits, preferences and satisfaction (e.g. Client status, data on use of Services, Client’s queries and complaints, survey’s feedback)||Development of products and services|
|11. Data on the Client’s segment (e.g. demographic)||Direct marketing, organising campaigns, webinars and seminars|
|Data obtained in the course of performing obligations arising from legislation (e.g. data arising from inquiries made by investigative bodies, notaries, tax authority, courts, inquiries made by court bailiffs)||Cooperation with supervisory authorities and other public sector institutions, implementation of required measures, such as impounding accounts|
|13. Data related to participation in consumer games and campaigns (e.g. data on prizes won in investment games and other consumer games and points collected in campaigns)||Compliance with campaign terms (e.g. payouts of amounts won)
Direct marketing (e.g. sending an invitation to participants, reminders etc)
|14. Data on Client’s family and/or associated persons(such as information about the Client’s family, heirs and other related person’s (used only in cases if a Client is related to a politically exposed person or the Client has passed away). Also, whether the Client is a politically exposed person)||Compliance with due diligence requirements|
|15. Data on Website sections visited by the Client||Risk management, monitoring and investigating to counter fraud (e.g. payment fraud)|
4.5 Regards direct marketing (such as company news, information about campaigns and other similar updates to enhance Client knowledge related to the financial markets, etc.), the Client has the right to choose whether or not to receive marketing related emails to their submitted email address. Such a preference can also be changed at any time through the Trader`s Room, under the ‘Subscriptions’ panel. It’s also possible to unsubscribe from these marketing emails by clicking the link within the received e-mail.
5.1 Aglobe Investments Ltd has the right or a legal obligation to forward Customer Data to the following Third Parties:
5.2 When using third party service providers (Authorised Processors) for Processing of Client Data, Aglobe Investments Ltd shall ensure that such data processors will process Client Data only in accordance with instructions from Aglobe Investments Ltd and in conformity with the requirements set for data protection. Authorised Processors must have sufficient level of data protection that would ensure secure data transmission.
6.1 Aglobe Investments Ltd analyses data from a client´s profile mainly for the purpose of marketing its services and products based on Aglobe Investments` Ltd legitimate interest. Profile analysis is also used for assessing client related risks for the prevention of money laundering and terrorism financing. Such data processing takes place in order to fulfill its legal obligations as an investment firm.
7.1 Aglobe Investments Ltd shall not process Client Data for longer than necessary for performing the objectives of the Processing, including for complying with the duty, set forth in legal acts, to retain data and for resolving disputes arising from agreement(s) entered into with the Client or for resolving potential disputes. Aglobe Investments Ltd shall preserve Client Data, who has entered into a Client agreement for receiving the investment services, for at least seven years following the termination of the Client relationship, unless other terms for the preservation of data or documents are prescribed by law.
7.2 In general, Aglobe Investments Ltd shall retain Client’s Data until the end of the statute of limitations.
8.1 Aglobe Investments Ltd respects Clients’ rights to access and control their personal data. Aglobe Investments Ltd will respond to requests concerning personal data processing and, when applicable, give access to, correct or delete personal data. Client’s have access to review their submitted data in Trader’s Room. The Clients have the right to:
9.1 If you have any questions about Aglobe Investments` Ltd data processing principles or you are dissatisfied with how Aglobe Investments Ltd has dealt with your personal information, you may contact us for answering you questions and/or resolving your concerns. The general contact details of Aglobe Investments Ltd are available on the website: www.admiralmarkets.com/sc, selecting the ‘Contact Us’ page.
9.2 Aglobe Investments Ltd will acknowledge your complaint within 7 days. Aglobe Investments Ltd will provide you with a decision on your complaint within 30 days.
9.3 If you are dissatisfied with the response received from Aglobe Investments Ltd, you may attempt making a complaint to the the Seychelles Financial Services Authority, which can be contacted throuh email at: firstname.lastname@example.org