Privacy Policy

Comert Comertex spool. s.r.o and its associated entities (hereinafter referred to as the “Company”) are responsible for protecting the privacy, personal and financial information of customers. By opening a trading account with the Company, the client gives his consent to the collection, processing, storage and use of personal information by the Company in accordance with the specified below.

COLLECTION OF PERSONAL INFORMATION

The collection of personal data of clients is carried out by the Company when opening a trading account, this is necessary to perform financial transactions, protect assets and confidentiality of data, as well as to provide high-quality services. When registering on the Company’s website, the client must fill out a form and a questionnaire, where personal information of the following nature is indicated:

1. contact information that allowing to quickly establish communication with the client (name, e-mail, mobile phone number, place of residence, postal code, date of birth, education, profession, information about assets and capital);
2. information confirming the identity of the client (a complete list of documents will be available to the client after registration in the personal account settings);
3. information about account activity, which is necessary to protect client funds.
4. To make the use of the website as correct and comfortable as possible, the Company may request indirect customer data – IP address, browser type, name of the Internet provider, etc.

The company can request personal information of the client in several ways:

1. through the official website or mobile application;
2. during the registration of a trading or demo account;
3. when applying for participation in promotions;
4. when subscribing to the newsletter;
5. when contacting technical support.
6. In the course of its operational activities, the company may receive information about the client from open source or third parties, including but not limited to data from payment service providers, results of marketing activities (research, surveys) from marketing service providers.

The Company can record communication in any form (e-mail correspondence, phone calls, etc.) with the client, which took place in the course of the business relationship, and store the recorded information in order to confirm the mutual cooperation of the client and the Company, as well as improve the quality of service. During phone recording, there is no alarm or other notifications.

By collecting information about its customers, the Company:

1. Fulfills the requirements of legislation, by-laws, acts of judicial and law enforcement agencies, organizational and administrative documents of regulatory bodies. Comert Comertex spool. s.r.o is a company fully compliant with anti-money laundering legislation, financial services and privacy standards, corporate and tax laws. The regulatory authorities strictly monitor the Company’s compliance with legal requirements, which means that the Company is obliged to process personal information of customers for credit checks, identity verification, processing financial transactions, compliance with court orders, tax accounting and internal financial control requirements, and other obligations related to public service reporting and money laundering control.
2. Protects its own rights and legitimate interests. The company uses personal data of clients for commercial and operational purposes, such as drafting claims and other legal documents, protecting rights and legitimate interests in court, corporate governance, information security and payment protection, development of services and products.
3. Conducts investigations and resolution of disputes.
4. Seeks to improve the quality of products and services, including customer service, development and implementation of new services and products.
5. Operates with the permission of the client. The client voluntarily allows the Company to use and store personal information, while having the right to withdraw the given consent at any time. Until revocation, the Company has the right to store and process customer information.
6. Analyzes information, evaluates the quality and feasibility of services and product lines offered to customers, delivers information about them, taking into account the current needs of the client. The stickers and tags contained on the official resource or in the e-mail list notify of the correspondence received by the client, the number of users of the official website, etc.
7. Conducts surveys and marketing activities. By answering questions, the client helps to improve the quality of service. Survey results are depersonalized. Personal data of clients is also used for marketing communications via e-mail or phone. You can unsubscribe from the newsletter by writing to the email address [email protected] or by clicking on the link to exclude from the mailing list on any newsletter of the company;
8. Notifies customers of changes in services, product lines or legislation.

Personal data of clients, in accordance with a legal agreement, may also be provided in a limited volume for verification purposes in the event of significant changes in the structure of the Company’s corporate governance (for example, in the event of a change of owner or a change in the ownership structure, merge or acquisition). In such cases, a non-disclosure agreement (NDA) must be concluded with persons accessing the relevant data sets for verification purposes before gaining access to such information. Among other things, NDA permits access to personal data and their processing only for the purposes and during the period of verification, and also prohibits the storage of personal data after the end of the check.

RIGHTS OF CLIENTS RELATED TO PERSONAL INFORMATION

The client providing the Company with personal information has the following rights:

1. get access to personal information on demand;
2. make changes to personal information at the request sent to the Company;
3. request the deletion of personal information (when required by law, the Company may refuse to delete information, the client will be notified of this additionally);
4. refuse to process personal information aimed at direct marketing if the client considers this has signs of infringement of his rights and freedoms (in this case, the entire volume of the service or a significant part of it will not be available);
5. request a suspension of data processing in order to establish their veracity, expediency or legality of their use;
6. send a request for the transfer of personal information to third parties (the Company provides them structurized and in electronic form);
7. revoke consent to the processing of personal information at any time.

The client can send any of the above requests to the technical service email [email protected]. The company replies to letters of this type within several calendar days. If it takes a longer time to resolve the issue, the client will be notified of this additionally.

PERIOD OF USE OF PERSONAL DATA

The company protects the confidentiality of its clients’ personal data, regardless of how they were obtained:

1. provided by the client in person;
2. received via email;
3. received over the Internet;
4. provided on any digital storage device.

During the entire time that a business relationship is maintained between the Company and the client, personal information is also retained. The company is committed to ensuring the security of digital vaults, paper files and other records at all times. The company takes all necessary measures to protect the personal information that it possesses from illegal and unauthorized use, loss, editing, disclosure or theft.

If the Company has achieved all the goals in relation to the client and no longer needs personal information, it deletes the information completely and no longer identifies the person as a client. An exception is made in cases of investigative procedures against a client in connection with fraud or money laundering. In these cases, the law requires the Company to store customer information for at least 5 years even after the termination of cooperation.

Personal information and data on transactions are stored for more than 5 years from the moment of suspension of cooperation with the client to ensure the ability to use it in court proceedings and in other cases specified in law. When a customer submits a request to opt out of marketing research, information about him is stored in a separate list.

PROTECTION OF PERSONAL INFORMATION

Personal information provided by a client to the Company is confidential and can only be disseminated within the Company or among its affiliates, it is not subject to disclosure to a third party, except in situations provided by law. If information about a client is requested by a judicial, law enforcement, supervisory or regulatory body in cases provided by law, it will be provided on a need-to-know basis, and the third party will be informed about the confidentiality of the information received.

To ensure the security of the personal data of the client and the user of the official resource of the Company, rules and technical methods were developed and implemented to protect information. Any operation carried out by a client within the official website is completely safe. To protect the site, a server certificate is used, which confirms the reliability of the Company. In addition, a special encryption system is used during data transmission – Secure Sockets Layer (SSL).

Access to the client’s office requires a username and password. These data are the property of the client, therefore the Company is not responsible for how the client uses them and manages accounts. If the client detects unauthorized use of his trading account or notices suspicious activity with it, the client has to inform the technical service of the Company.

AFFILIATES AND PARTNERS

The company may exchange information with affiliates if such information is reasonably necessary for such an affiliate to provide products or services under the terms of the contract. The company may exchange information with partners, affiliates and associated companies in order to offer additional similar products and services that meet the needs of customers and that are delivered in a manner that is useful and relevant only where customers have authorized the company to do so. Affiliates are (including but not limited to):

Comert Comertex spool. s.r.o partner companies providing financial and technical services;

software developers of communication systems, applications and trading terminals used by customers;

service providers and consultants on the basis of an agreement for the provision of administrative, informational, analytical, financial, marketing and other services;

brokerage companies and their branches that cooperate with the Company or conduct joint operating activities;

payment service providers and banking institutions involved in the processing of customer financial transactions;

auditors and contractors providing the Company with information and consulting services in various areas of financial and economic activities (in this case, a non-disclosure agreement must be concluded with such persons).

An affiliate can receive the client’s personal data in a strictly limited amount, which is sufficient for this person to fulfill its contractual obligations to the Company. Personal data, insofar as it is not relevant for the provision of the service, is not provided to affiliated persons.

An affiliated supplier has the right to use the personal data of the Company’s clients solely for the purpose of ensuring the proper performance of services or the supply of goods under an agreement with the Company. The use of personal data for any other purpose by affiliated suppliers is strictly prohibited.

Each affiliate who gains access to the personal information of the Company’s clients, before obtaining such access, must confirm full compliance with the legal requirements and the compliance of its infrastructure with basic information security standards (the level of information protection on the side of the affiliated person must not be lower than that implemented in the Company).

The company does not provide personal data of its customers to third parties, including affiliates who have failed to confirm the appropriate level of information security.

UNAFFILIATED THIRD PARTIES

The company does not sell, license or rent any customer’s personal information to third parties.

The Company does not provide personal data of clients to legal entities and individuals that are not affiliated with the Company, are not its partners and are not associated with the Company by contractual relationship.

An exception is the cases of providing information to judicial, law enforcement, controlling, regulatory and other bodies and institutions provided for by law and referred to in this Policy.

The client’s personal information can be provided to any person authorized by the client.

USE OF COOKIES

The Company uses cookies to protect customers’ trading operations and to improve the performance of the official Comert Comertex spool. s.r.o website. They do not contain personal or confidential information. Cookies are small text fragments sent by the Company from its Internet resource to the client’s browser. Cookies are stored in the client’s browser and allow the Company to recognize it by a unique identifier.

When visiting the official website of the Company, several cookies may be placed in the client’s browser, intended for the following purposes:

1. activation of options on the site;
2. optimal performance of analytical operations;
3. identification of customer preferences;
4. informing the user of advertising information and information about promotions, remarketing.

Depending on the functions performed, cookies can be of the following types:

1. Basic – designed to authenticate clients and prevent fraudulent activities with the account;
2. Strictly Obligatory – manage site navigation, use of options, access to protected segments and restricted areas;
3. Performance – analyze the client’s user experience on the site, determine preferences, reduce the overall load on the internal infrastructure, maintain the high-quality work of the site when implementing new functions;
4. Functional – remember the principle of logging into the system even after editing information, adapt the site and help expand the functionality for clients.

Cookies can be used by third-party partners of the Company to provide advertising materials in accordance with the client’s preferences. With their help, the user experience on sites or services is analyzed. The collected data is used by advertisers and ad networks in order to subsequently deliver ads and measure their effectiveness.

Depending on the life cycle, cookies can be of 2 types – session and persistent. Session cookies are stored on the client’s computer until the user session with Company’s website is completed. Persistent cookies remain on the device until completely deleted or until expiration.

In addition to its own, the Company uses cookies from third parties – partners to generate and analyze statistics, as well as provide advertising materials.

Please note that the forced deletion of some cookies may cause the client to inaccessibility of a number of functions on the website, in the personal account or in the trading terminal, some pages may not be displayed correctly.

REGULATORY DISCLOSURE

According to the legislative requirements, the Company is obliged to disclose personal data to judicial, law enforcement, controlling or regulatory authorities strictly in cases provided for by law. At the same time, the Company:

– thoroughly checks the grounds for disclosing the specified information and their sufficiency (in the absence of grounds or insufficient substantiation, information is not provided);

– strictly monitors that information is provided on the need-to-know basis and in amount provided for in the relevant legislative or organizational and administrative act (provision of the entire amount of personal data to the requestor by default is not practiced).

In case of disclosure of personal data, the Company must inform the third party about the confidential nature of the information.

CUSTOMER CONTACT

The Company may contact clients by phone or e-mail in order to provide them with additional information about the Company, trading in financial markets, and exclusive offers. When registering on the site, accepting the terms and conditions for using the platform, the client agrees to receive the specified information. The client can refuse to receive it at any time by contacting the support service.

LIMITATION OF LIABILITY

The company is not responsible for the content of sites linked to Comert Comertex spool. s.r.o and is not directly controlling the use or protection of information provided by customers or collected by these sites. When a customer clicks a link to a co-branded or related site, the customer may be asked to go through a separate registration and provide personal information. Please note that such information is captured by a third party, and the use of such information will be managed in accordance the third party’s privacy policy.

PRIVACY POLICY UPDATES

This Privacy Policy is reviewed by the Company at least once a calendar year. If necessary, the Privacy Policy will be amended at the next revision. The updated version of the Policy comes into force immediately after its publication on the Company’s website.