The privacy policy is the cornerstone of the relationship between the … company and the client because it, in addition to the rest of the legal documents, forms the basic constitution in dealing between the company and the customer. As soon as you visit the company’s website or any of its pages, you agree to the principles, conditions and policies in it.

Based on the regulations and laws governing trading, passing through the company’s internal systems and according to the code of conduct for securities dealers, the company obliges its employees to respect the confidentiality and privacy of the customer’s information and it imposes restrictions and penalties on any employee who may violate this privacy.

In order to provide the customer with the appropriate services, the company collects some personal information that the customer provides upon registration and when the customer browses the company’s website. It also complies with the General Data Protection Regulation 2016/679 (EU) and its amendments when collecting data of the residents of the European Economic Area, including any information provided to us by phone or through official forms on our website or by any other means through which the client’s personal information is obtained.

Scope and Legal Basis of this Privacy Policy

The privacy policy defines the method for collecting, using, sharing, analyzing and / or processing personal information for clients who want to deal with the company and the visitors and browsers of the company’s website.

The company takes into consideration the confidentiality of the information of its customers and those browsing its website within the previously mentioned internal systems of the company and data protection systems. The company is committed to protecting customers’ personal data as described above.

Personal Information

For the purposes of opening accounts, it is necessary to identify the applicant for trading and the applicant for opening the account by listing the following basic data:

• Full name and residence address.
• Income information and sources, wealth, bank account information and financial statements.
• Contact addresses including mobile and fixed phone numbers, e-mail, personal pages, etc.
• History and location of clients, nationality and citizenship.
• Gender.
• The balance of business accounts and financial details such as bank accounts, loans, funds, etc.
• The general jobs occupied by the client, if any, and the details of the profession.
• Internet protocol (IP) address and information about the communication device (computer, mobile phone, …)
• Previous trading experience.
• Customer’s official documents and cookies.
• Tax residence.
• The location of the communication device used.
• Any other personal data that the company may deem necessary.

However, the authorization of such data does not preclude the company from obtaining intersecting information from trading partners, subcontractors or any party that the company sees.

Minors Information

The company does not allow minors to enjoy its services and make deals through its website. Therefore, the company is not interested in collecting any information that is found to be related to minors or from minors.

The company encourages its customers who have a real reason to believe that a minor has shared the company with information like the mentioned in this document to contact the company by e-mail.

Business Conduct

The company maintains records of customers’ business conduct with the aim of developing and improving the service and measuring customer behavior and desires in respect of the following:

• Customer preference for limited types of deals and products.
• Products traded by the customer.
• Customer’s transactions and investments.
• Investment amounts and the currency of deposits and withdrawals.

The Company’s Goals of Collecting Personal Information

The company doesn’t collect personal data in vain or primarily for advertising purposes, but data is collected and processed for the following reasons:

1. Protecting the interests of the project:

Processing data is necessary to protect the legitimate interests of the business, the company, and any third party that has engaged in a deal with the customer within the company.

2. Marketing

The data is used after being processed and approved by the client for the purposes of marketing and making deals successful.

3. Judicial commitments and legal obligations

The company is able to fulfill any of its legal or judicial obligations towards the official authorities through data analysis and verification of customer procedures and data, especially with regard to anti-money laundering and combating the crime of terrorism, etc.

Data Sharing Extent

Customer data and information are confidential and will not be disclosed to a third party except in the following cases:

1. According to a judicial decision when required under laws, regulations or international conventions.
2. When the legitimate interest of the company or its contracting parties so requires.
3. When there is an official authorization by the client or his heirs to do so.

Data Use

The company uses the data after processing it for marketing purposes by communicating via specific means of communication (mobile phone, telephone, e-mail, social media, etc…) in order to provide the customer with developments, offers, advertisements and other information related to the company’s services and investment opportunities.

The company also uses such data after processing for statistical, exploratory and promotional purposes as well; thus the company can allocate customer preference files to strengthen and improve communication and interaction methods.

The company doesn’t overlook the importance of this data in addressing and resolving any complaints, dissatisfaction requests, or any special inquiries received from the customer.

However, dealing with and analyzing the data according to the previous basis doesn’t mean in any way waiving the confidentiality of such data in accordance with the rules, principles, protocols and international agreements that have been previously explained.

Additional Customer Rights

In addition to the above-mentioned general rights for all the dealers with the company, company customers enjoy the following additional rights within the company’s technical and commercial capabilities:

• The right to data portability: customer has the right to request the transfer of the information we have to any other company.
• Right to restrict data processing: The customer has the right to request to limit the processing of his personal data.
• The right to data erasure: After the customer’s business with the company has ended, and the period specified by the company has passed, and there have been no complaints, dealings or rights, the customer may request that his data be deleted from the company’s records. The company may study this request and issue its decision as it deems appropriate.
• The right to be informed: The customer has the right to request a copy of any personal data that the company maintains.
• The right to rectification: The customer has the right to request any amendment or correction of any personal data received by the company.

However, it must be clear that the requests and rights mentioned are studied by the company. And they are handled according to the company’s systems and its time and technical capability.

The company also ensures high levels of protection and confidentiality according to the customer’s need when transferring personal information outside the European Economic Area. It also considers compliance with the European Data Protection Regulation (EU) 2016/679 and any relevant charters, including the codes of conduct for dealers and securities traffickers.

The company will also maintain the same principles when transferring customer data to a third party outside the European system. One of the most prominent aspects to be adopted in ensuring protection; the contractual clauses approved in the Privacy Shield of the European Union and the United States of America and the Company rules and Regulations.

Data Retention Period

After the end of the investment relationship, the company will retain customer’s data, whether on paper or electronic, or through any means determined by the company for a period of five years starts from the date of the last transaction, unless there is a complaint or request submitted by the customer or others related to any service. Then the period starts from the end of the last day to appeal the response received on the complaint.

However, the company, exceptionally, can reduce the aforementioned period to any period it considers appropriate if it deems necessary.

Limitation of legal liability

It is understood that the company doesn’t bear any liability or responsibility for the privacy policy of any other company, partner or third person not affiliated with it. The company doesn’t have control over how others use customer data.

The company also does not bear responsibility or liability for any information provided by the customer to any linked websites that are not managed by the company, since this data is subject to the privacy rules and principles established by the third-party systems.

Policy Review:

The company has the right to review this statement many times whenever needed without notifying the clients, either before or during the deals, and at any time the company finds necessary.