- By personal data, we refer to data that may be used to identify you as a person. Personal data include your name, your address, your telephone number, your email address, your age, your gender, a part of your credit card number. Anonymous information, which we are not in a position to relate to you, does not qualify as personal data.
- TeleTrade is the personal data controller for the data gathered from you, and will be responsible for the processing of your personal data and will act as data controller for the purposes of the Decree issued by the Minister of Finance of Cyprus for the implementation of the Multilateral Agreement on the Automatic Exchange of Financial Account Information signed by the Cyprus Government on October 29, 2014, on the basis of the Common Reporting Standard developed by the OECD (the “CRS Decree”), the Administrative Cooperation in the Field of Taxation (Amending) Law of 2016 (ACFT Law) and the General Data Protection Regulation (EU) 2016/679 (GDPR).
- We may collect personal data as well as other information when you use the following services:
- Our websites, including www.teletrade.eu, my.teletrade.eu, teletrade-dj.it, teletrade-dj.lv/ru, teletrade-dj.cz, teletrade-dj.ro, teletrade-dj.pl, teletrade.hu, teletrade.pt, teletrade-dj.lt, teletrade-dj.gr and any other Teletrade sites on which this Policy is posted (the "Sites").
- Your creation and use of a Teletrade Client Login ID when completing the registration process at my.teletrade.eu (a “Client ID”).
- Your creation and use of a Teletrade trading account (an "Account"). For more information on Accounts and how to create an Account please see our Legal Documentation.
- Your use of any of our other products and services (including support services) which may be accessible via a third party platform, web application or social networking service (together the "Ancillary Services"). In this Policy we refer to the Sites, the Client Login ID, the Account and the Ancillary Services together as the "Services".
By accepting this Policy, you signify your consent to the collection and other processing of your personal data in accordance with and for the purposes set out in this Policy
2. Who we are
We ("TeleTrade", "we", "our" and "us") are:
Teletrade-DJ International Consulting Ltd,
4th floor, Strovolos,
We respect your right to privacy and will only process personal data and other information you provide to us or we collect about you in accordance with applicable privacy and personal data protection laws.
3. Information we may collect from you
When you use the Services we may collect the following categories of data:
- When you sign up for our marketing communications, register your general interest in our products and services at our web-sites, or register a Client Login Page, we collect and process the following "Client Data":
- Your first name and last name, e-mail address and phone number.
- When you open a Trading Account, we collect and process the following "Trading Account Data":
- Your first name and last name, your gender, date and place of birth, country of citizenship, residential address, e-mail address, telephone number,
- Client Login ID, password, financial background and prior trading experience required in order to carry out the appropriateness test as per the applicable regulatory framework
- Employment history & source of funds information required to accept your funds deposits in accordance with AML legislation.
- Furthermore your jurisdiction(s) of residence, tax identification number, and, in relation to the account(s), the account number, the account balance or value as of the end of the relevant calendar year or other appropriate reporting period, as well as any income generated in the account(s) held with TeleTrade, are gathered and processed pursuant to the CRS Decrees, the ACFT Law and the GDPR.
- When you deposit funds to your trading account, we collect and process the following "Payment Information" that is necessary for the adequate performance of the contract between you and TeleTrade and to allow for the effective compliance with AML legal obligations by Teletrade:
- A part of your credit card number, and information about your credit card issuer.
- Financial information necessary to process your orders with respect to Teletrade Services with the relevant payment merchant, which will only be submitted directly to the payment merchant under secure protocols. This Information may include the amount of any payment transactions, the payment instrument used, date and time, payment amount, payment instrument expiration date, electronic wallet email address, IBAN information for bank transfers, your address and other related transaction details. When you use the Services, we may collect and process the following "Tracking Data":
- Location information associated with your IP address when you visit our Sites
- Information relating to your use of our Services including, but not limited to, information about when and how you use the Services and data traffic
- Log files and statistics in relation to actions taken on our Sites
- Technical information about any device that you use when you visit the Sites such as your IP address and the browser you are using.
- A cookie is a small file of letters and numbers that a website places on your computer or device when you visit a website. You are given the opportunity to consent to using of cookies or refuse from them as you enter our Sites. If you have opted out, we only use the strictly necessary cookies (as described below) and store one permanent ‘compliance’ cookie which tells us that you want to opt out of use of any other cookies. For more information about cookies, we recommend that you visit http://www.allaboutcookies.org/
The cookies that are used on the Sites fall into the categories described below. These descriptions can help you determine if and how you would like to interact with our Sites and other online services:
- Strictly necessary cookies.
These cookies are essential in order to enable you to navigate the Sites and use certain features. Without these strictly necessary cookies, the online services provided by the Sites cannot be provided. It is therefore not possible for you to opt out of use of these cookies. In addition, the coding language the Sites are written in uses session cookies and their use cannot be avoided. These are deleted each time you close your browser. These cookies do not store any information about the visitor once the browser is closed.
- Performance cookies.
Our performance cookies collect anonymous information about how you use the Sites and their features. For instance, our performance cookies collect information about which pages on the Sites are visited most often, which advertisements you view or interact with on the Sites or other websites on which our advertisements appear and if you receive any error messages.
- Analytics cookies.
The Sites use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help us analyse how users use the Sites. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States. In case of activation of the IP anonymisation, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent by us to and shortened by Google servers in the USA. On behalf of us, Google will use this information for the purpose of evaluating your use of the Sites, compiling reports on website activity for us and providing other services relating to website activity and internet usage to us. Google will not associate your IP address with any other data held by Google. The Sites may use other similar analytics cookies. These cookies are used to collect information about how visitors use the Sites. The information is collected anonymously, and used to report on the number of visitors to the Sites, where the visitors have come from, and the pages they have visited. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout. Further information can be found under https://www.google.com/analytics/terms/gb.html (Google Analytics Terms of Service & Privacy). Please note that on the Sites, Google Analytics code is supplemented by "gat._anonymizeIp();" to ensure an anonymized collection of IP addresses (so called IPmasking). Also, you can prevent Google Analytics to collect such data on behalf of Teletrade by clicking on the following link: https://tools.google.com/dlpage/gaoptout
- Functionality cookies.
Functionality cookies are used to remember choices you make (such as language preference, country location, or other online settings) and collect anonymous information.
5. How we use your information
We may use the information that you provide to us or that we collect about you for the following purposes:
- Provision of services. Client Data, Trading Account Data and Tracking Data may be collected and processed by us to provide you with the Services that you request from us and to perform the respective Operative Agreement (e.g. Client Agreement, Terms & Conditions) accepted by you. Data collected for that purpose will only be kept as long as necessary to provide the requested Services.
- Compliance with applicable legislation and regulatory framework. Any data collected may be processed by us to detect, investigate and prevent activities that may be illegal, that may violate the Operative Agreement and also to comply with the requests for information of the competent regulatory or lawful authorities. Such data will be kept for a minimum duration of 5 years after the Account closure in accordance with the current applicable laws.
- Creation of additional promotion and advertising:
- We may use the e-mail address registered to your Client Login ID to provide you with information about products and services related to our Services, if you agree to this service at the time your Client Login ID is created. You may also opt-out from use of your e-mail address for this purpose at any time, by sending an e-mail from the e-mail address registered to your Client Login ID to firstname.lastname@example.org stating that you do not wish to receive such information. Alternatively, you may opt out by following the unsubscribe instructions at the bottom of each e-mail you receive from us.
- We may use Tracking Data to monitor, improve, or modify the Services and our operations.
- We may use the e-mail address and/or phone number that you registered with us via contact forms at our web sites, to provide you with information about our products, services and promotions, if you agreed to receive this kind of information while registering with us. You may also opt-out from use of your e-mail address for this purpose at any time, by sending an e-mail from the e-mail that was registered with us to email@example.com stating that you do not wish to receive such information. Alternatively, you may opt out by following the unsubscribe instructions at the bottom of each e-mail you receive from us.
6. Sharing your information
We will not share your personal data with anyone else unless in the following limited circumstances:
- To the extent that we are required to do so by applicable law, by a governmental/regulatory body or by a law enforcement agency, or for crime prevention purposes.
- In order to provide the Services to you, Teletrade is legally required to pass on your personal data to the relevant tax authorities of the Republic of Cyprus, and they may also be exchanged with tax authorities in another country or in other countries where You, the Client may be a tax resident in accordance with the CRS decree, and the ACFT Law.
- In order to provide the Services to you in accordance with the Law L. 87(I)/2017 regarding the provision of Investment services, the exercise of investment activities and the operation of regulated markets (the Investment Services Law) Teletrade is legally required to report to the Cyprus Securities and Exchange Commission (“CySEC”), information about your transactions in financial instruments the underlying of which are traded on regulated markets. Such information includes your personal details, such as first name, last name, country of citizenship, date of birth and other personal identification data.
We recognize that we have a special obligation to protect personal information obtained from children. We will not knowingly collect personal information from any child, or process such information, without parental consent. For the purpose of this Policy, a child means any individual who is under the age of 18 (or the minimum legal age to consent to the collection and processing of personal information where this is different under applicable law).
Teletrade has implemented all reasonable technical, administrative and physical security measures to protect the security of your personal information and all client data including the placing of financial transactions and/ or orders. The whole network communication in the context of sharing financial and/ or personal information is protected by the use of a password and followed by encryption.
All received information that the client provides is stored on secure servers and only authorized staff have access to this information. We take reasonable precautions to prevent the loss, misuse or alteration of your personal information. Our employees, contractors and agents may be given access to your personal information which we collect, but their use shall be limited to the performance of their duties in relation to facilitating your use of the Services. Our employees, contractors and agents who have access to your personal information are required to keep that information confidential and are not permitted to use it for any purposes other than those listed above or to deal with requests which you submit to us.
9. Third party sites & services
If you link, connect, or login to your TeleTrade client login ID via a third party service (e.g. Google, Facebook etc), the third party service site may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service. If you have chosen to connect your TeleTrade personal page to a third-party application, you can change your settings and remove permission for the app by changing your Client Login ID (Personal Page) setting at any time. You are responsible for keeping your personal information with such third party applications up-to-date and secure so as to ensure the integrity of your TeleTrade Client Login Page.
10. Your rights
In addition to your opt-out right under section 5.3., you may exercise the following rights at any time:
- You may ask us to provide you with copies of the personal information that we hold about you, or with information about the processing of such information.
- You may ask us to update and correct any out-of-date or incorrect personal information that we hold about you.
- You may ask us to delete the personal information we hold about you.
If you wish to exercise any of these rights, then please contact us at firstname.lastname@example.org
Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. Please note that we are legally obliged to keep on record all and any information that pertains to the provision of investment services to you and which is necessary to fulfill our obligations under the applicable laws for a period of up to 7 years after account closure.
- Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- Because we maintain security measures to protect our data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Where you have provided your consent to the processing of your personal information by Teletrade, you may withdraw your consent at any time by sending a communication to us specifying which exact consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims.
You have the right to complain to the Data Protection Commissioner’s Office if you feel that Teletrade has not responded to your requests to solve a problem. You can find their contact details here: http://www.dataprotection.gov.cy/
11. Changes to this Policy
We may change this Policy from time to time for various reasons such as changes to reflect in law and regulation, changes in industry practices and technological developments. In case you have a registered Client Login ID, you will be notified of any changes of this Policy via e-mail to the e-mail address related to your Client Login ID. The latest version of this Policy will always be available on the Sites. Any new version of this Policy shall take effect (i) immediately upon the date of your receipt of the notification e-mail where the changes to this Policy relate to nonmaterial changes which do not reduce your rights; or (ii) no less than thirty (30) days after your receipt of the notification e-mail where the changes to this Policy potentially reduce your rights; or (iii) in case you do not have a registered Client Login ID, the moment they are uploaded to our Sites.
If you have any enquiries about this Policy, or any questions about the use of your personal information, please e-mail us (email@example.com) or call us (+357 22 51 44 42).