PRIVACY POLICY

Who are we (owner and data controller)?

FINOVA FX LTD — located at 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM.

Contact email: support@finovafx.com

We are dedicated to safeguarding your privacy and ensuring the security of any personal information we receive from you.

What is the purpose of this policy?

The purpose of this policy is to clarify the personal information we collect and how we and our affiliated companies may utilize it. Companies are considered affiliated if they are our subsidiaries or if we are subsidiaries of the same corporate entity.

We act as the controller of any personal information you provide to us, which means we determine the purposes and methods of processing that personal information.

How do we collect and store your personal information?

We collect your personal information through applications, emails, letters, telephone calls, text messages, cookies, and conversations when you register for our services and engage with them (including personal information obtained when using our learning tools, demo accounts, and trading simulators).

We may monitor or record phone calls with you and keep records of all emails and electronic communications we send or receive.

To prevent unauthorized access, we adhere to strict security protocols for storing and disclosing the personal information you have provided.

What types of personal information do we collect and process?

We may process the following types of personal information:

  • Name
  • Contact details, including email address and phone number
  • Age or date of birth
  • Gender
  • Occupation
  • Income
  • Trading knowledge and experience
  • Usernames and passwords
  • Information related to your trading account, including account history, activity, and orders
  • IP address
  • National insurance number
  • Transaction reporting reference
  • Power of attorney/agent details
  • Phone device type
  • Operating system
  • Device ID
  • Cookie ID
  • Google 360 ID
  • GUID
  • Information about your use of our services, products, and facilities (including information obtained when using our learning tools, demo accounts, and trading simulators)Bank account number
  • Sort code
  • Passport number
  • Marital status
  • Usage data.

How do we verify your identity?

To comply with money laundering regulations, we need to confirm the name and address of our clients and certain third parties. We may request physical forms of identity verification when you open your account. Alternatively, we may use a credit reference agency to verify your identity. Our search is not visible or used by lenders to assess your creditworthiness. Our search is conducted with the necessary security measures to ensure the confidentiality of the personal information obtained and prevent unauthorized access.

How do we use your personal information?

In addition to identity verification, the personal information we hold may be used for:

  • Considering your applications
  • Conducting risk assessments
  • Complying with legal and regulatory obligations
  • Fulfilling our contractual obligations with you
  • Administering our relationship with you, including resolving queries or issues
  • Establishing and managing your account
  • Reviewing your ongoing needs
  • Providing you with requested information, products, and services
  • Verifying your instructions
  • Investigating any complaints you may make
  • Providing evidence in disputes or anticipated disputes between you and us
  • Recovering amounts payable
  • Training our staff
  • Improving our customer service and products
  • Undertaking product development and analysis
  • Detecting or preventing fraud or other crimes
  • Analytics using services such as Google Ads conversion tracking, Google Analytics, Google Tag Manager, Facebook Ads conversion tracking, and Display Advertising extension for Google Analytics
  • Contacting you with marketing material via post, email, telephone, SMS, mobile push notifications, web push notifications, messengers (Viber, Telegram, Facebook Messenger, and others), or
  • other electronic messaging services
  • Handling payments using service providers such as Neteller, Skrill, and 2Checkout
  • Interacting with helpdesk platforms using service providers like Zendesk and SimpleSat
  • Managing contacts and sending messages using service providers like Mandrill, Mailchimp, and Bloomreach
  • Remarketing and behavioral targeting using services provided by Google Inc., Facebook Inc., and Twitter Inc.

When may we share your personal information?

We may share your personal information with:

  • Relevant regulatory or tax authorities
  • Third parties necessary to prevent crime, such as the police
  • Our affiliated companies
  • Third-party service providers and advisors who assist us with administrative, financial, research, or other services related to the services we provide
  • Introducing brokers and other commercial partners
  • Professional advisors and auditors for financial and regulatory audits
  • Agents, including credit reference agencies, conducting credit and identity checks, compliance regulatory reporting, and fraud prevention checks on our behalf
  • Courts, tribunals, regulatory or tax authorities, and government agencies to enforce our agreement with you or comply with legal requirements
  • Trade repositories
  • Other parties necessary to provide optimal customer service.
  • We require external organizations, not affiliated with our company, to acknowledge the confidentiality of your data, respect your right to privacy, and comply with data protection principles and this policy.

How do we share your personal information?

The information we collect is anonymous and helps us enhance your user experience with our mobile application!

We may collect and use a third-party service to understand how you interact with our app, identify bugs and crashes, provide customer support, and improve your app accessibility.

Rest assured that any anonymous data we collect does not include personal or financial information, sensitive data, or user-generated private content. Additionally, we do not transmit data related to your device’s camera, microphone, or other user inputs. All transmitted data are protected by SSL encryption.

What is the legal basis for processing personal information?

The legal basis for processing personal information depends on the purpose of processing.

If you have entered into a contract with us to receive services, we process your personal information to fulfill the contract. Failure to provide the requested personal information may result in an inability to provide some or all of the requested services.

We may also process personal information to comply with legal and regulatory obligations, including anti-money laundering, terrorism prevention, sanctions screening checks, complaints, investigations, or litigation.

We have a legitimate interest in processing your personal information for various purposes, such as providing services, managing our relationship with you, improving our products and services, conducting marketing analytics, and maintaining records.

Where required, we will clarify the specific legal basis applicable to the processing, including whether providing personal information is a statutory or contractual requirement.

Where is the processing of personal information conducted?

Data processing occurs at our operating offices and other relevant locations where the involved parties are located.

Depending on your location, data transfers may involve transferring personal information to countries other than your own. For details on the processing location of transferred personal information, you can refer to the ‘Using Your Personal Information’ section.

If any transfers occur, you can inquire with us via support@finovafx.com.

Please note that we use Transport Layer Security (TLS) encryption (also known as HTTPS) for all transmitted data. The data is sent over an encrypted TLS 1.2 connection.

How long do we retain your personal information?

We retain personal information electronically and/or in paper files while you are a customer and for at least three years after your customer relationship ends. Certain personal information must be retained for a period of seven years to comply with applicable anti-money laundering and terrorist financing legislation. This personal information includes:

  • Name, family name, patronymic name (if any)
  • Residential address
  • Age/date of birth
  • Passport details
  • Photos of your identity documents
  • Information regarding deposits to and withdrawals from your account, including currency and amounts
  • Information regarding your trading activities
  • Telephone number
  • Email address
  • Communication history with support (chats, emails, calls).
  • Additionally, the above data will be stored for the defense of legal claims during the limitation periods specified by applicable legislation.

Please rest assured that the above personal information will be encrypted and securely stored in our IT system, used solely for the specified purposes, and erased from our system after the expiration of the seven-year period. Access to the mentioned personal information will be restricted during the entire storage period.

What is a Cookie and why do we use it?

Cookies are small pieces of information stored on your computer by a website you visit to enable certain functions on the website and customize its content to your preferences. They may store data on pages where you have provided key information (e.g., when you enter a password) after being prompted and accepting storage of this information. Some pages on our site may use cookies to offer a more personalized browsing experience. Cookies are not used to determine the personal identity of visitors.

Types of cookies we use:

Session cookies: Temporary cookies deleted when you close your browser, used to retain information as you navigate our website. You can decline session cookies in your browser’s privacy settings, but it may negatively impact your browsing experience on all websites.
Analytical cookies: May include temporary and more persistent cookies used to track how you use our website and the duration of your visits. Analytical cookies do not reveal any identifying information specific to you but help us improve content delivery. You can opt out of analytical cookies via your browser’s privacy settings.
Functional cookies: Record and save your choices to provide a seamless experience across our website, such as remembering your language preference. You can opt out of functional cookies through your browser’s privacy settings.
Third-party cookies: Used by third parties, mainly social media platforms like Google+, Facebook, or YouTube, to facilitate content sharing and video presentation. You can disable these cookies in your browser’s privacy settings, but this will disable the related functions.
As previously mentioned, we use cookies to ensure optimal website functionality and tailor content to your preferences. If you have further questions, please feel free to contact us via support@finovafx.com.

How can you get more help?

If you need assistance with our Privacy Policy or have any questions about it, please contact us via support@finovafx.com.

If you are dissatisfied with any aspect of how we collect, share, or use your personal information, please let us know. You can contact us using the above details.

What are your privacy rights?

This section provides detailed information about your privacy rights in relation to your personal information.

To exercise any of the rights described below, please contact us via support@finovafx.com.

ACCESSING YOUR PERSONAL INFORMATION

When can you request access?

You have the right to:

Confirm that your personal information is being processed
Access your personal information.
You can request copies of the paper and electronic records we hold share, or use about you. To handle your request, we may require proof of identity and enough personal information to locate the requested data.

When will access not be provided?

We can only provide your personal information, not personal information about someone else. Also, if access would adversely affect another person’s rights, we are not required to provide it. Due to legal privilege, we may not be able to disclose information connected to a claim or legal proceeding.

Please clearly specify in your access request the personal information you are seeking. If it is unclear, we may contact you for further clarification.

CORRECTING YOUR PERSONAL INFORMATION

How can you correct your personal information?

You have the right to prompt rectification of inaccurate personal information concerning you. If you inform us that the personal information we hold about you is incorrect, we will review it. If we agree with you, we will correct our records. If we do not agree, we will inform you accordingly. If you wish, we can include your statement when disclosing your personal information to third parties outside our company.

You may also have the right to complete incomplete personal information, including by providing a supplementary statement, depending on the purposes of processing your personal information.

We will notify third parties with whom we shared your personal information of your rectification request. We will take reasonable steps to do this, but it may not always be possible or may involve disproportionate effort.

What are the limitations on access to and correction of your personal information?

Generally, we will show you the personal information we hold about you or correct any inaccurate personal information if you request it in writing.

Due to legal privilege, we may not be able to disclose information related to a claim or legal proceeding.

ERASING YOUR PERSONAL INFORMATION

When can you request an erasure?

You have the right to request the erasure of your personal information, preventing further processing, when:

The personal information is no longer necessary for its original purpose of collection/processing
You withdraw consent (if previously provided)
You object to processing and our legitimate interests in processing your personal information do not take priority
We have processed your personal information in breach of data protection laws
Erasure is necessary to comply with a legal obligation.
When can we refuse erasure requests?

The right to erasure does not apply when we are required to retain personal information for legal or regulatory purposes or if your personal information is processed for certain specified reasons, such as the exercise or defense of legal claims.

Furthermore, erasure may result in an inability to provide part or all of our services.

Do we have to inform other recipients of your personal information about your erasure request?

If we have shared your personal information with third parties, we must inform them of your request to erase the specified personal information. We will take reasonable steps to do this, but it may not always be possible or may involve disproportionate effort.

It is also possible that the recipient is not required or unable to erase your personal information due to one of the above exemptions.

RESTRICTING PROCESSING OF YOUR PERSONAL INFORMATION

When is the restriction available?

You have the right to restrict the processing of your personal information:

When you dispute the accuracy of your personal information, we need to verify its accuracy
When processing is unlawful, and you oppose erasure, request restriction instead
If we no longer need the personal information, but you require it to establish, exercise, or defend a legal claim
When you have objected to processing under the circumstances described in the ‘Objecting to Processing’ section, and we are considering whether your interests should take priority.
Do we have to inform other recipients of your personal information about the restriction?

If we have disclosed your personal information to relevant third parties, we must inform them about the restriction on processing your personal information so that they refrain from further processing.

We will make reasonable efforts to do this, but it may not always be possible or may involve disproportionate effort.

We will also notify you if we decide to lift the restriction on processing.

TAKING YOUR PERSONAL INFORMATION WITH YOU

When does the right to data portability apply?

The right to data portability applies only to personal information you have provided to us, processed based on your consent or for the performance of a contract, and processed by automated means.

When can we refuse data portability requests?

We may refuse your data portability request if the processing does not meet the above criteria. If the personal information concerns more than one individual, we may not be able to transfer it to you if doing so would prejudice the rights of others.

OBJECTING TO PROCESSING

You can object to processing in the following circumstances:

Legitimate interests

You have the right to object at any time, on grounds related to your particular situation, to the processing of your personal information based on legitimate interests.

If we can demonstrate compelling legitimate grounds for processing your personal information that override your interests, rights, and freedoms or if we need your personal information to establish, exercise, or defend legal claims, we may continue processing it. Otherwise, we must cease processing the relevant personal information.

Direct marketing

If you receive newsletters or other email messages from us, you can opt-out at any time by contacting us via support@finovafx.com.

LEGAL INFORMATION

This privacy statement has been prepared based on provisions of multiple legislations, including Regulation (EU) 2016/679 (General Data Protection Regulation).

KEY DEFINITIONS

Personal information (or Data)

Any information that directly, indirectly, or in connection with other information, including a personal identification number, allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through our application and/or our website (or third-party services employed by us), including IP addresses or domain names of your computer, URI addresses (Uniform Resource Identifier), time of the request, method used to submit the request to the server, file size received in response, numerical code indicating the status of the server’s answer (successful outcome, error, and other), country of origin, browser and operating system features used by you, time details per visit, path followed within the application and/or our website with reference to the sequence of pages visited, and other parameters about your device’s operating system and/or IT environment.

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