Privacy Policy
Introduction
Privacy Policy
This Privacy Policy is a part of our Service Agreement and is
incorporated therein by references.
We encourage you to read the Privacy Policy carefully and use it to make
informed decisions. By using our Services, you agree to the terms of this
Privacy Policy and your continued use of the Services constitutes your
ongoing agreement to this Privacy Policy including its updates.
Data usage
We may collect, use, store and transfer different kinds of personal data
about you and for different purposes. For your use, we made the table with
data categories, purposes of their use, and lawful bases for processing.
| Data type | Examples of information we may collect | Purposes of processing | Lawful bases for processing |
| Identity Data |
First name, last name, and patronymic (if available), date of
birth, gender, passport, ID, driver’s license number, or photo.
|
Account management, fraud prevention, security, compliance with AML,
CTF, and other applicable laws and regulations, advertising, and
personalization of user experience.
| 1. Necessary to perform our contract with you. 2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (to provide effective
and personalized customer services to you and to update you in
relation to our services that are available to you, to perform web
analytics and direct marketing).
|
| Contact Data | Billing address, email address, and telephone numbers. |
Account management, application functionality, fraud prevention,
security, compliance with AML, CTF, and other applicable laws and
regulations, developer communications, advertising, and
personalization of user experience.
| 1. Necessary to perform our contract with you. 2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (to provide effective
and personalized customer services to you and to update you in
relation to our services that are available to you, to maintain
application functionality).
|
| Profile Data |
Your account details, User ID, username, and password, account
photo, your country’s national flag icon, your number in the
leaderboard, text showing your own position in the leaderboard,
status, which shows that you are online now, your experience points
and winning amount your interests, preferences, feedback, and/or
information received through your interaction with us within the
course of providing our services and survey responses, e.g. in-app
messages.
|
Account management, application functionality, analytics,
developer communications, advertising, including promotional
activities, and internal events; personalization of user
experience, fraud prevention, security, compliance with AML, CTF,
and other applicable laws and regulations.
|
1. Necessary to perform our contract with you, to provide
additional services to you, e.g. Social Signals Service.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (take reasonable steps
to confirm that you do not use any ways to manipulate our platform
& for running our business, provision of administration and IT
services, network security, to prevent fraud; to provide effective
and personalized customer services to you and to update you in
relation to our services that are available to you, to perform web
analytics and direct marketing, to maintain application
functionality).
|
| Technical Data |
Internet protocol (IP) address, your login data, browser type and
version, time zone setting and location, browser plug-in type and
versions, operating system and platform, and other technologies on
the devices you use to access the Website or application and use of
cookies stored on your device, other identifiers that relate to your
device (IMEI, MAC address, advertising identifier, etc.).
|
Fraud prevention, security, compliance with AML, CTF, and other
applicable laws and regulations, app functionality and development,
advertising, analytics, and personalization of our services.
| 1. Necessary to perform our contract with you. 2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (take reasonable steps to confirm
that you do not use any ways to manipulate our platform & for running
our business, provision of administration and IT services, network security,
to prevent fraud; to provide effective and personalized customer services
to you and to update you in relation to our services that are available
to you, to perform web analytics and direct marketing, to maintain application
functionality).
|
| Usage Data |
Information about how you use the Website, applications, products,
and services, registration date, account category, trading cluster,
number of complaints, number of requests files, and IP history, your
application activity (app interactions, your installed apps),
application information and performance (crash logs, diagnostics,
other app performance data),
|
Fraud prevention, security, compliance with AML, CTF, and other
applicable laws and regulations, mobile apps and website
functionality and development, personalization of our services,
analytics, and advertising.
| 1. Necessary to perform our contract with you.
2. Necessary for our legitimate interests (to provide effective and personalized
customer services to you and to update you in relation to our services
that are available to you, to perform web analytics and direct marketing,
and to maintain application functionality).
|
| Financial Data |
Bank account and tax identification number (including but not
limited to social security number, income tax identification number,
and national insurance number).
|
Account management, provision of services, fraud prevention,
security, compliance with AML, CTF, and other applicable laws, and
regulation, and provision of services.
| 1. Necessary to perform our contract with you. 2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (reasonable steps to confirm
that you do not use any ways to manipulate our platform & for running
our business, provision of administration and IT services, network security,
to prevent fraud).
|
| Usage Data |
Information about how you use the Website, products, and services,
registration date, account category, trading cluster, number of
complaints, number of request files, and IP history.
|
Fraud prevention, security, compliance with AML, CTF, and other
applicable laws and regulations, mobile Apps and website
functionality and development, and personalization of our
services.
| 1. Necessary to perform our contract with you.
2. Necessary for our legitimate interests (to provide effective
and personalized customer services to you and to update you in
relation to our services that are available to you.
|
| Transaction Data & Purchase history |
Details about the transactions performed by you, details about
payments, withdrawals, exchanges, trading and purchase history,
profit, balance, deposited and withdrawal amount methods, and any
other details in relation to the services you have made use of
through our Website and applications; ROI metric (percentage of
successful trades calculated for the last 7 days); asset, direction,
and duration of the trade for users to copy it.
|
Account management, fraud prevention, security, compliance with AML,
CTF, and other applicable laws and regulations, and personalization
of user experience.
|
1. Necessary to perform our contract with you, to provide
additional services to you, e.g. Social Signals Service.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (take reasonable steps to confirm
that you do not use any ways to manipulate our platform & for running
our business, provision of administration and IT services, network security,
to prevent fraud).
|
| Payment Data |
Details of the number of payment wallets and/or information of your
bank card, including information of the issuing bank, card number,
cardholder name, card expiration date, payment system, card
validation code (CVV2 / CVC2), and photos of both sides of the bank
card.
|
Fraud prevention, security, and compliance with AML, CTF, and other
applicable laws and regulations, provision of services, account
management, and personalization of user experience.
| 1. Necessary to perform our contract with you. 2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (to provide effective and personalized
customer services to you and to update you in relation to our services
that are available to you).
|
| Economic Profile Data |
Details on occupation, the purpose of investment, annual income,
net wealth, the expected annual amount of investment, and sources
of funds.
|
Fraud prevention, security, and compliance with AML, CTF, and
other applicable laws and regulations, account management.
| 1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
|
| KYC Data |
"Know your customer" data: identity document information, including
copies of recently dated utility bills, identity card, passport,
and/or driver’s license.
|
Fraud prevention, security, and compliance with AML, CTF, and other
applicable laws and regulations, account management.
| 1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
|
| Special Categories of Data/ ‘Sensitive’ Data |
Details about your annual income, biometric data, and/or criminal
convictions, and offenses.
|
Fraud prevention, security, and compliance with AML, CTF, and
other applicable laws and regulations.
| 1. Necessary to perform our contract with you. 2. Necessary to comply with our legal obligations. 3. Consent. |
| Conformity Data |
Details about your education, employment status, trading experience,
and self-assessment test.
|
Fraud prevention, security, and compliance with AML, CTF, and
other applicable laws and regulations, account management.
| 1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
|
| Marketing and Communication Data |
Your preferences in receiving marketing from us and your
communication preferences.
|
Fraud prevention, security, compliance with AML, CTF, and other
applicable laws and regulations, marketing and product analytics,
personalization of our services, promotional activities and
internal events, and provision of services.
| 1. Necessary to perform our contract with you. 2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (to provide effective and personalized
customer services to you and to update you in relation to our services
that are available to you).
|
| Location Data |
Details on your actual location when interacting with our Website
(for example, a set of parameters that determine the regional
settings of your interface, namely residency country, time zone,
and the interface language).
NB: It is not relevant for iOS and Android applications. |
Account management, fraud prevention, security, compliance with AML,
CTF, and other applicable laws and regulations, developer
communications, and personalization of our services.
| 1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
|
| Audio and Video Data |
Full audio or video recordings of calls that you receive from us
or make to us.
NB: It is not relevant for iOS and Android applications.
|
Account management, fraud prevention, security, and compliance with
AML, CTF, and other applicable laws and regulations, developer
communications, promotional activities and events, and provision of
client support services.
| 1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligation.
|
We process the aforementioned data in compliance with the applicable laws
and regulations as amended from time to time in order to:
(i) Be able to perform our contractual obligations towards the Clients
and offer them the best possible service.
(ii) Provide our Services efficiently.
(iii) Comply with our legal obligations, including, inter alia, fraud
prevention, anti-money laundering, and terrorist financing laws, regulations,
and recommendations of FATF.
(iv) Protect our legitimate interests and your vital interests.
Personal data is processed based on the following legal bases:
1. Compliance with applicable laws and regulations.
2. Performance of contractual obligations towards the Clients.
3. Safeguarding our legitimate interests and your interests and fundamental
rights do not override those interests.
4. On the basis of the Client’s consent.
Please note that applicable laws and regulations require us to store some
categories of data after termination of the Service Agreement or deletion of
your account. More details are provided in the account deletion section
hereof.
Leaderboards
You hereby acknowledge and agree to become part of the network and share
your trading strategies and results. You authorise us to disclose your
personal data (your name, experience points and winning amount, etc.) for
the leaderboards on the platform. You authorize us to produce signals
resulting from your trades, disclose generalised information about them, and
you agree that other users will be able to copy your successful trades if
you are included in the leaderboard on the platform.
In accordance with the principles of data minimisation and purpose
limitation the processing of personal data for this purpose is limited only
to the following:
•
Profile data: name (User ID, if there is no name), your country’s national flag
icon, photo (optional), your number in the leaderboard, text showing your own
position in the leaderboard (you); status, which shows that you are online now,
your experience points and winning amount;
•
Transaction data: ROI metric (percentage of successful trades calculated for
the last 7 days); asset, direction and duration of your trade for users to copy
it.
Please note that the amount of your trades is never publicly disclosed. Only
the ROI metric, which is based on the total percentage of trades (successful
and unsuccessful) from which the percentage of successful trades is
deducted, is crucial for inclusion in the leaderboard.
The processing covers the following activities: collection, recording,
organisation, structuring, storage, adaptation or alteration, retrieval,
use, disclosure, transfer (including cross-border transfer, where
necessary), alignment or combination, restriction, erasure and destruction.
You have the right to change your privacy settings at any time and make your
trading activity fully private by clicking "Settings" > "Privacy".
Cookies and other tracking technologies
We and our trusted partners use cookies and other technologies in our
related services, including when you visit our site or access our Services.
A "cookie" is a small piece of information that a website assigns to your
device while you are viewing a website. Cookies are very helpful and can be
used for various different purposes. These purposes include allowing you to
navigate between pages efficiently, enable automatic activation of certain
features, remembering your preferences, and making the interaction between
you and our Services quicker and easier. Cookies are also used to help
ensure that the advertisements you see are relevant to you and your
interests and to compile statistical data on your use of our Services.
Our website uses the following types of cookies:
a) "Session cookies" are stored only temporarily during a browsing session
in order to allow normal use of the system and are deleted from your device when
the browser is closed.
b) "Persistent cookies" are read-only by our website, saved on your
computer for a fixed period, and are not deleted when the browser is closed.
Such cookies are used where we need to know who you are for repeat visits, for
example, to allow us to store your preferences for the next sign-in.
c) "Third-party cookies" are set by other online services who run content
on the page you are viewing, for example by third-party analytics companies who
monitor and analyze our web access.
Cookies do not contain any information that personally identifies you, but
Personal Information that we store about you may be linked, by us, to the
information stored in and obtained from cookies. You may remove the cookies
by following the instructions of your device preferences; however, if you
choose to disable cookies, some features of our Service may not operate
properly and your online experience may be limited.
With whom we share the information we collect
We do not rent, sell, or share your Personal and/or Corporate Information
with third parties except as described in this Privacy Policy.
We may transfer or disclose Personal Information to our
subsidiaries, and other
affiliated companies. In addition, your Personal
Information may be disclosed to other trusted
third-party service providers or
partners for the purpose of:
(i) Authenticating your identity and verifying your account details.
(ii) Storing or processing Personal Information on our behalf (e.g.
cloud computing service providers).
(iii) Assisting us with our business operations, providing our
Services, and improving them.
(iv) Performing research, technical diagnostics, and analytics with
regard to the Services.
(v) Communicating promotional and informational materials, in accordance
with our marketing policy (see below under "
Marketing").
We may disclose personal information or any information you submitted via
the Services if we have a good faith belief that disclosure of such
information is helpful or reasonably necessary to:
(i) Comply with any applicable law, regulation, legal process, or governmental
request.
(ii) Enforce our policies (including our Agreement), including investigations
of potential violations thereof.
(iii) Investigate, detect, prevent, or take action regarding illegal
activities or other wrongdoing, suspected fraud, or security issues.
(iv) Establish or exercise our rights to defend against legal
claims.
(v) Prevent harm to the rights, property, or safety of us, our users,
yourself, or any third party.
(vi) For the legitimate purposes below:
- To serve your advertisements when you use our Services.
- To perform research or conduct anonymous analytics in order to improve
and customize our Services to your needs and interests.
- To support and troubleshoot our Services and respond to your queries.
- To investigate violations and enforce our policies, as required by
law, regulation, or other governmental authority, or to comply with a subpoena
or similar legal process, or respond to a government request.
- To monitor transactions for the purposes of preventing fraud, money
laundering, and cheating.
- For enforcement agencies and/or in case we find it necessary in order
to enforce intellectual property or other legal rights.
Any third party with whom we may share user data will provide the same or
equal protection of user data as stated in this privacy policy.
Third-party collection of information
Our policy only addresses the use and disclosure of information we collect
from you. To the extent that you disclose your information to other parties
via our Services (e.g. by clicking on a link to another website or
application) or via other sites or applications, different rules may apply
to their use or disclosure of the information you disclose to them.
It is important to note that such third-party services may have their own
privacy policies and we advise you to read them carefully. The inclusion of
a link to a third-party website, application, or service is not a
recommendation of such a website or service. Third-party sites may contain
information or service that is illegal, unreasonable, or that some people
may find inappropriate or offensive. Before using third-party sites,
applications or services, we recommend you to read and understand those
sites' and services' terms and conditions, warranty, and privacy policies
and to ensure you agree to their terms. You acknowledge that we are not
responsible for the products, services, or descriptions of those products or
services that you receive from third-party sites or applications or to the
content or privacy practices of those sites and that this Privacy Policy
does not apply to any such third party products and services. You are
knowingly and voluntarily assuming all risks of using third-party sites or
applications to purchase products and services. You agree that we shall have
no liability whatsoever with respect to such third-party sites,
applications, or services and your usage of them.
We also use a tool called "Google Analytics" to collect information about
your use of the Services. Google Analytics collects information such as how
often users access the Services, what pages they visit when they do so, etc.
We use the information we get from Google Analytics only to improve our
Services. Google Analytics collects the IP address assigned to you on the
date you visit sites, rather than your name or other identifying
information. We do not combine the information collected through the use of
Google Analytics with personally identifiable information. Google’s ability
to use and share information collected by Google Analytics about your visits
to this site is restricted by the Google Analytics Terms of Use and the
Google Privacy Policy.
Advertisements
We may use advertising technology to serve advertisements (including
targeted ads) when you use our Services. We may also use third parties and
share with them Non-personal Information to assist us in evaluating the
success of our advertising campaigns and help us retarget our users.
You may opt-out of many third-party ad networks, including those operated by
members of the Network Advertising Initiative ("
NAI") and the Digital Advertising Alliance ("
DAA"). For more information regarding this practice by NAI
members and DAA members, and your choices regarding having this information
used by these companies, including how to opt-out of third-party ad networks
operated by NAI and DAA members, please visit their respective websites:
www.networkadvertising.org/optout_nonppii.asp and www.aboutads.info/choices.
Personal data deletion and rectification requests
You have the right to obtain from us the rectification of inaccurate
personal data, and therefore you may, at any time, request to change and
update your personal data by emailing us at
[email protected]
You can also request that we will correct errors or that we will delete your
personal data (except for your transaction history and other data that we
are required to keep under applicable laws) by emailing us at
[email protected]
The deletion or rectification requests can be sent to us in a free form (in
the body of a letter, scan, etc.) to
[email protected].com with your full name and contact information for a quicker processing
of your request. If we are not satisfied you are who you claim to be, we
reserve the right to refuse to grant your requests.
Please note that personal data is deleted by default when we no longer have
a legitimate purpose for the continued processing or storage of personal
data, or when personal data is no longer required to be stored in accordance
with applicable legal requirements.
Unless you instruct us otherwise, we retain the information we collect for
as long as needed to provide the Services and to comply with our legal
obligations, resolve disputes and enforce our agreements. We may rectify,
replenish or remove incomplete or inaccurate information, at any time and at
our own discretion.
Safeguarding and transferring your information
We take great care in implementing and maintaining the security of the
Services we offer, and your information. We employ industry-standard
procedures and policies to ensure the safety of our users' information and
prevent unauthorized use of any such information. Although we take all
reasonable steps to safeguard information, we cannot be responsible for the
acts of those who gain unauthorized access or abuse our Services, and we
make no warranty, express, implied, or otherwise, that we will prevent such
access.
If you feel that your privacy was treated not in accordance with our policy,
or if any person attempted to abuse our Services or acted in an
inappropriate manner, please contact us directly at
[email protected].
Marketing
We may use your Personal Information, such as your name, email address,
telephone number, etc. ourselves or
by using our third-party subcontractors for the purpose of providing
you
with promotional materials, concerning our Services, as well as products,
services, websites, and applications
which relate to
our business partners and affiliates (collectively: "
Marketing Affiliates"), which we believe may interest you.
We may also share and disclose Personal Information with our
Marketing Affiliates for the purpose of providing you with different
marketing offers we or our
Marketing Affiliates believe are relevant for you.
Out of respect to your right to privacy, we provide you with such marketing
materials with the means to decline receiving further marketing offers from
us or from our Marketing Affiliates. In addition, at any time, you may
request to
unsubscribe and discontinue receiving marketing offers
by sending a blank message with the word "remove" to
[email protected].
If you unsubscribe we will remove your email address from our marketing
distribution lists and from any future lists we may share with our Marketing
Affiliates. However, you may need to separately unsubscribe from marketing
offers sent by our Marketing Affiliates. Please note that even if you
unsubscribe from our marketing mailing list, we may continue to send you
service-related updates and notifications.
You hereby acknowledge and agree that by downloading, installing, or
accessing our Services, we may share your Personal Information with our
trusted partners and Marketing Affiliates for the purpose of direct
marketing.
Communication with you via WhatsApp
By checking the box, you consent to the transfer of your personal data for
communicating via WhatsApp. This service is used by us for the purpose of
sending you messages related to the provision of a service and marketing
messages.
At any time, you may request to unsubscribe and discontinue receiving
messages from us via WhatsApp by sending a blank message with the word
"opt-out WhatsApp" to
[email protected]. Please note that if you opt-out of receiving messages via WhatsApp, we
will not be able to send you both marketing materials and informational
messages via this service.
Corporate transaction
We may share Information, including Personal Information, in the event of a
corporate transaction (e.g. sale of a substantial part of our business,
merger, database migration, consolidation, or asset sale of an asset or
transfer in the operation thereof) of the Company. In the event of the
above, the acquiring company or transferee will assume the rights and
obligations as described in this Privacy Policy.
Account deletion
Any Client may delete its Client account by means of the user interface
within the mobile Apps on Android and iOS or by means of making a client
support request. Provided that applicable laws and regulations prohibit us
from deletion of personal data, the Client hereby acknowledges that in case
of the account deletion the Company will store necessary personal data, as
specified in the data usage part hereof, in order to comply with applicable
laws and regulations and prevent fraudulent actions and platform
manipulations and other dishonest actions for the term specified in the
applicable laws, regulations, and recommendations. The Company will take all
reasonable actions in order to secure data minimization and anonymization.
The Company will cease using the Client’s personal data for any other
purposes that are not specified in the present abstract, including
advertising and marketing purposes, upon account deletion.
Updates or amendments to the Privacy Policy
We may revise this Privacy Policy from time to time, at our sole discretion,
and the most current version will always be posted on the website. We
encourage you to review this Privacy Policy regularly for any changes.
Registration and Authorisation
Information about the company:
Bron Liquidity Services LLC,
Address: First Floor, First St. Vincent Bank Ltd Building, James Street,
Kingstown, St. Vincent & the Grenadines
How to Contact Us
If you have any general questions about the Services or the information that
we collect about you and how we use them, please contact us at
[email protected]