- INTRODUCTION
The Site is owned and operated by ZENON CONSULTANTING LTD (to be referred to as “the Company”, “us”, “we”).
This Privacy policy (hereinafter referred to as “the Privacy Policy“) together with our Terms of Service sets out the basis on which any Personal Information we collect from you (“you”, “your”, or “customer”), or that you provide to us, will be processed by us.
Please read the Privacy Policy carefully to understand what data we collect, how that data is used and the ways it can be shared by us. If you do not wish for your Personal Information to be used in the ways described within this Privacy Policy then you should not access or use the Site or use the services, functions, or features offered from time to time on the Site (“Services”). By using our website, you hereby consent to our Privacy Policy and agree to its Terms and Conditions.
“Personal Information”, we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifier.
2. CHILDREN’S INFORMATION
We do not knowingly collect personal information from Children under 18 years old. If we learn that we have inadvertently gathered personal information from a Child, we will take legally permissible measures to remove that information from our records.
If you are a parent or guardian of a Child, and you become aware that a Child has provided personal information to us, please contact us immediately and we will o our best efforts to promptly remove such information from our records.
DATA CONTROLLER
The data controller of your data is ZENON CONSULTANTING LTD which is limited liability company registered under Limited Liability Companies Act, Chapter 151 of Saint Vincent, and the Grenadines, with registration number ……………………, whose registered office is …………………….
3. INFORMATION WE MAY COLLECT ABOUT YOU
As part of our business, we collect personal data from customers and potential customers that include the following:
- name, surname and contact details
- date of birth and gender
- information about your income and wealth including details about your assets and liabilities, account balances, trading statements, tax and financial statements.
- profession and employment details
- location data
- knowledge and experience in trading, risk tolerance and risk profile
- IP address, device specifications and other information relating to your trading experience.
- Bank account, e-wallets and credit card details.
- details of your visits to our Website or our apps including, but not limited to, traffic data, location data, weblogs and other communication data.
If the Company requests you to provide personal data and you fail to do so, the Company may not be in a position to provide a service and/or enter into an agreement with you, in which case it will inform you accordingly. The abovementioned data are collected by the Company when you are going to open a trading account with the Company. It is required by the AML Law (the Prevention and Suppression of Money laundering and Terrorist Financing Law as amended from time to time) and AML Directive that the Company collects the necessary data for verifying your identity, constructing your economic profile, monitoring your account and verifying the source of funds (when it is necessary). Additionally, we use this data to set up and administer your trading account, provide technical and customer support.
If you are a corporate client, we are required to collect additional information such as corporate documents of address, shareholders, directors, officers including additional personal information on the Shareholders and Directors. We have the right to ask any additional information we deem necessary to be compliant with our legal and regulatory requirements.
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 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.
4. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY
Each time you use the Services, we may automatically collect the following information, which may be considered to be Personal Information when combined with other information about you:
technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
information about your visit, including the dates and times you use the Site length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
5. LAWFUL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
We will process your personal information for the following purposes:
- establish and maintain a responsible commercial relationship with you;
- Understand your needs and your eligibility for products and services.
- inform you about trading and financing features.
- provide information to you about developments and new products, including changes and enhancements to the Site.
- develop, enhance, and market products and services, and provide products and services to you;
- process billing and collection of any fees;
- conduct surveys and get feedback from you;
- deliver products and services to you;
- as we believe reasonably necessary, advisable or appropriate to comply with our legal or regulatory obligations and to respond to legal, regulatory, arbitration or government process or requests for information issued by government authorities or other third parties or to protect your, our, or others’ rights.
6. COOKIES
Similar to other websites, our Sites utilize browser cookies (small text files stored on a user’s web browser when you visit a website), web beacons and similar tracking technologies (collectively, “Cookies”) to collect and store certain information when you use, access, or interact with our services.
Cookies are small pieces of information. When you visit a website, the website sends the cookie to your computer. Your computer stores it in a file located inside your web browser. We may obtain information about you by accessing cookies sent by our website. Cookies help us to verify your identity and detect the Country you are currently visiting from, checking browser type and device, and to track which site the user was referred from.
Types of cookies
We might use different types of cookies that each of them keeps track of different activities.
Functional cookies: We use functional cookies to analyse how visitors and clients use our website, as well as track and improve our website’s performance and function. This allows us to provide a high-quality customer experience by quickly identifying and fixing any issues that may arise. For example, we might use cookies to keep track of which website pages are most popular and which method of linking between website pages is most effective.
Session cookies: Another use of cookies is to store your login sessions, meaning that when you log in to your account to deposit funds, a “session cookie” is set so that the website remembers that you have already logged in. If the website did not set this cookie, you will be asked for your login details on each new page as your progress through the funding process.
Analytical cookies: The information provided by analytical cookies allows us to analyse patterns of visitor and client behaviour and we use that information to enhance the overall experience or identify areas of the website which may require maintenance. The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address), and it is only used for statistical purposes. Behavioural cookies are similar to analytical and remember that you have visited the website and use that information to provide you with content which is tailored to your interests.
Performance Cookies: Cookies provided by Google Analytics, these enable us to provide a better service based on how our users navigate our website.
7. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We do not collect any special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
8. INFORMATION FROM THIRD PARTIES
We may receive information about you from other sources, including third parties that help us update, expand, and analyze our records; prevent or detect fraud; process payments; or analyze your use of our Services.
Our Services may also include integrated content or links to content provided by third parties (such as live chat, social media content, plug-ins and applications). Additional third parties may include our affiliated entities.
9. YOUR RIGTHS
Please note that these rights do not apply in all circumstances. You are entitled to:
- request access to your personal data (commonly known as a “data subject access request”);
- request correction of the personal data that we hold about you;
- request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental right and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- request restriction of processing of your personal data.
- request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used machine-readable format.
- withdraw consent at any time where we are relying on consent to process your personal data.
10. INFORMATION, COMPLAINTS AND CONTACT
If you have any further questions regarding the data the Company collects, or how we use it, or you want to make a complaint then please feel free to contact us by email at: …………………….
11. AMENDMENTS TO THE POLICY
This Privacy Policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at the sole discretion of the Company. When we make changes to this Privacy Policy, we will notify all users on our website, and make the amended Privacy Policy available on our website. We encourage you to review this Privacy Policy from time to time to stay informed. For significant material changes in the Policy or, where required by the applicable Laws, we may seek your consent.
