20230804-privacy-policy-eu-en

31 December 2013

PRIVACY

POLICY

1. Introduction

Easy Forex Trading Ltd (hereinafter referred to as ‘easyMarkets’, ‘Company’, ‘we’, ‘our’, ‘us’
as appropriate) operating under the trading name easyMarkets is a Cypriot Investment Firm
(hereinafter  referred  to  as  “CIF”)  registered  with  the  Registrar  of  Companies  and  Official
Receiver  in  Cyprus  under  registration  number  HE  203997  and  regulated  by  the  Cyprus
Securities  and  Exchange  Commission  (hereinafter  referred  to  as  “CySEC”)  under  license
number 079/07.

The Company is registered with the Office of the Commissioner for Personal Data Protection
of the Republic of Cyprus for the purposes of personal data processing. Your personal data is
kept and handled in accordance with

the Law providing for the Protection of Natural Persons

with regard to the Processing of Personal Data and for the Free Movement of such Data of
2018 (Law 125(I)/2018)

and the

Regulation (EU) 2016/679 of the European Parliament and of

the Council of 27 April 2016 on the protection of natural persons with regard to the processing
of personal data and on the free movement of such data

(the “Law”), as amended from time

to time. The Company is the data controller responsible for your personal data.

2. Scope of the Privacy Policy

The scope of this Privacy Policy is to provide you (or data subject) with information of how
easyMarkets collects and uses information though its site

www.easymarkets.com

This

Privacy  policy  does  not  apply  to websites  operated by other  organizations and  other  third
parties.  By  registering  with,  or  accessing  the  easyMarkets  website,  you  consent  to  the
collection, use and processing of your personal data.

3. Commitment

easyMarkets respects the privacy of any user that accesses its website(s). We are therefore
committed in taking all reasonable steps in safeguarding the personal data of any existing or
prospective clients, applicants and visitors.

4. Data Protection Officer

We have appointed a Data Protection Officer (“DPO”). Our DPO has a number of important
responsibilities including but not limited to:

a. monitoring easyMarkets’ compliance with the provisions of the GDPR;
b. raising awareness of data protection issues, training easyMarkets’ staff and conducting

internal audits; and

c. cooperating with the supervisory authority.

If you have any questions about this privacy policy, including any requests to exercise your
legal rights, please send us an email at:

DPO@easymarkets.com

5. Information we collect

Throughout  our  cooperation  we  collect  information  directly  from  you,  through  any
correspondence made with us by phone, e-mail or otherwise; including information which you
enter when you register to use our website, mobile app, subscribe to our service or any other
activities  carried  out  on  our  website  or  any  connected  applications.    The  information  we
collect may include but are not limited to your first and last name, email, country and city of
residence,  phone  number,  social  media  profile  details,  IP  address,  nationality,  tax
identification  number,  date  of  birth,  residential  address,  bank  details,  financial  situation,
employment  status,  trading  activity,  transaction  history,  account  balance  information
(“Personal data”). We are also required by law  to collect certain Know  Your Client (“KYC”)
documentation  in  order  to  verify  your  identity.  KYC  documents  may  include  but  are  not
limited to:

a.  Proof of identity (e.g. ID/Passport, driving license)
b.  Proof of address (e.g. Utility bill, driving license)
c.  Proof of credit card statement (e.g. Bank Statement)

We may also collect indirect information from you, which we use purely for verification,
security or purely for browsing/ functionality purposes. Such information may include your
(IP) address, browser type, operating system, mobile device ID and/or any device ID, Internet
service provider (ISP), cookies. Please also read our Cookies Policy that you can find at our

Legal Page

6. Purpose for which we will collect your personal data

We collect, use, disclose, store and process your personal data for the performance of our
services as required by law.  We use your personal data to provide you with the services you
request  through  our  Website  and  Platform  so  as  to  perform  our  contractual  obligations
related to those services.

We  also  collect  your  personal  data  for  internal  purposes  including  the  improvement  of
customer experience, promotional and marketing services (e.g. emails, social media, SMS),
customer care, training purposes and administration matters. Such data is safely stored via
physical or electronic means and procedural controls, and it is treated CONFIDENTIAL. We
only collect personal data that is adequate and relevant for the purposes of our business and
for a reasonable period of time as required by law.  We never ask for more information that
is required by law.

7. Your legal rights

You have the below rights under data protection laws in relation to your personal data:

a. Request for information and access to your personal data:

You  have  the  right  to  information  which  includes  among  others,    where  personal  data  is
stored, how the data was collected, and for what purpose.  You also have the right to access
to your personal data.   If you wish to receive a copy of the personal data we hold about you,
we will give you such copy upon receiving a written request by you, unless any relevant legal
requirement prevents  us from doing so. Please note that we may need to request specific
information from you or contact you to ask for further information to help us confirm your
identity.  This is a security measure to ensure that personal data is not disclosed to any person
who has no right to receive it.

b.  Request correction/rectification of the personal data that we hold about you:

You have the right to correct any inaccurate or incomplete data we hold about you, though
we may need to verify the accuracy of the new data you provide to us. If you require this,
then please reach out to our support team at:

support@easymarkets.com

c. Request erasure of your personal data:

You have the right to request erasure/deletion your personal data (“right to be forgotten”)
where there is no good reason for us continuing to process it. Note, however, 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 you request. As a CYSEC authorized firm, we are
under certain obligation to retain certain data

to a maximum of seven years.

d. Object to processing of your personal data:

You have the right to object to the processing of your personal data, if you feel it impacts on
your fundamental rights and freedoms.  In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which override your rights.  As a
CYSEC authorized firm, we are under certain obligations to process and retain certain data for
compliance purposes.  If you object to the processing of certain data, then we may not be able
to provide our services to you.

e. Request restriction of processing of your personal data:

You have the right to ask us to suspend the processing of your personal data in the following
scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is
unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we
no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have
objected to our use of your data but we need to verify whether we have overriding legitimate
grounds to use it. Please note that any requests in relation to the restriction of the processing
of your data means that we may not be able to perform the contract we have or are trying to
enter into with you. In this case, we may have to cancel your use of the easyMarkets Services,
but we will notify you if this is the case at the time.

f. Request the transfer of your personal data to you or to a third party.

You have the right to request the transfer of your personal data to you or to a third party.

you require this, then please reach out to our support team at:

support@easymarkets.com

g. Withdraw consent where we are relying on consent to process your personal data.

However, this will not affect the lawfulness of any processing carried out before you withdraw
your consent. If you withdraw your consent, we may not be able to provide you with our
services. We will advise you if this is the case at the time you withdraw your consent.

8. Our legal obligations

We may be required to retain and use personal data to meet our legal requirements, for data
security purposes and as we believe to be necessary or appropriate in order to: (a) comply
with our obligations under applicable law and regulations, (b) respond to requests from

courts,  law  enforcement  agencies,  regulatory  agencies,  and  other  public  and  government
authorities, (c) monitor compliance with and enforce our Platform terms and conditions; (d)
carry out anti-money laundering, sanctions or KYC checks as required by applicable laws and
regulations; or (e) protect our rights, privacy, safety, property, or those of other persons.

We  may  also  be  required  to  use  and  retain  personal  data  after  you  have  closed  your
easyMarkets account for legal, regulatory and compliance reasons, such as the prevention,
detection or investigation of a crime; loss prevention; or fraud prevention.

9. Transfers of personal data outside of EEA

The  data  we  collect  from you will  be  transferred to and  stored  at  a  destination  inside  the
European  Economic  Area  (“EEA”).  However,  in  order  to  provide  the  services  to  you,  you
acknowledge  that  it  may  be  possible  to  transfer  your  personal  data  to  someone  else  who
provides a service to us in other countries outside of the EEA which does not offer the same
level of protection as the EEA, and you consent to such transfer.

10. Disclosure of your Personal Data

We  disclose  and/or  share  your  personal  data  when  necessary  to  provide  our  services  or
conduct our business operations.  When we share personal data, we do so in accordance with
applicable data privacy laws and our internal security standards.  We do not sell personal data
or client database we collect. We do not distribute or transfer any data of our clients to any
unauthorized or non-affiliated to it, third parties.

Below are the parties with whom we may disclose and/or share personal data:

a.  Within easyMarkets group of Companies:

The Company is part of the easyMarkets group of Companies (“easyMarkets group”).  In order
to meet our contractual obligations to you, the Company is supported by easyMarkets group
employees  and  contractors.  For  the  provision  of  services,  we  may  make  personal  data
available to them if necessary.  All of our employees and contractors are required to follow
our data privacy and security policies when handling personal data.

b.  Our third-party providers:

The Company is supported by third party providers/service providers. We may disclose data
to our service providers that we do business with if necessary. In those cases, we retain

confidentiality agreements, and any data we may disclose is always on a “need to know” basis,
and solely for the provision of our services to you. Such services may include cooperation with
financial  institutions,  such  as  banks  and  payments  processing  providers,  promotional
functions,  direct  marketing  services,  software  system  and  platform  support,  cloud  hosting
services, advertising (including affiliate advertising), data analytics.

c. Regulatory disclosure:

We will also share and/or disclose personal data if we believe it is required, to third parties
for legal reasons in order to comply with legal obligations, including but not limited to law
enforcement and other public authorities.

d. Affiliate Marketing:

We have an affiliate marketing programe called forex Affiliate/easy markets partners which is
a commercial arrangement whereby third parties promote easyMarkets and its products and
services in return for a fee. We do not share your personal data with these third parties.

11. Data Security

Your security and data protection is of utmost importance to us. All information you provide
to us is stored on our secure servers, were it is protected by our comprehensive, modern, and
well-maintained data security infrastructure. We protect your information by using data
security technology that includes, but is not limited to such systems as firewalls, encryption,
access controls; physical security; physical and logical network separation; technology audit
tools; and appropriately administered and monitored internal roles and procedures.

Unfortunately, the transmission of information via the Internet is not completely secure. We
will take all steps reasonably necessary to ensure that your personal data is kept secure and
protected in accordance with our legal obligations and standards. If this is not possible, for
example because we are required by law to disclose data, we will ensure that the sharing of
the data is lawful.

12. Data Retention

We will retain your personal data for a period of time as we deem necessary for legal and/or
business purposes subject to a maximum of seven years upon the end of our business
relationship. Your personal data will be securely deleted and/or destroyed when no longer
needed.

13. Cookies

Cookies are small text files that are sent to and stored on your device, such as desktop and
laptop, smartphone, tablet/phablet, for accessing the internet, when you visit a website or a
page. Cookies allow a website to recognize a user’s device. The objective of cookies use is to
improve and make the user’s experience easier. By using

www.easymarkets.com

you agree to

our use of cookies to enhance your experience. To get more information on our Cookies Policy
visit our Legal Page.

14. Marketing

We may collect personal Information through social media sites when you interact with us on
one of our social channels, via our Apps or/and from other sources, such as public databases;
joint marketing partners; social media platforms; from people with whom you are connected
on social media platforms, as well as from other third parties.

We may send you information by SMS, push notification, email, in-app notification or contact
you by telephone or by any other means to provide you with information about our products,
services,  training  and  offers  we  think  would  be  of  interest  to  you.  If  you  receive  email
communications from us about the market or your activity on the platform and don't want to
in the future, you may opt out by clicking the unsubscribe link  situated at the end of each
email sent to you or by notifying the member of staff that contacted you and we will stop
sending you this information.  If you have any further questions, please do not hesitate to
contact us by email at

support@easymarkets.com

Also, when you are logged into your account you can manage your preferences by going to
"Notifications” tab (My EasyMarkets > My Account > My Notifications >Edit Market Alerts)
and manage your subscriptions.

15. Changes to Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on our website
and, where appropriate, notified to you by e-mail and/or when you next start the App or log
onto the Site. The new terms may be displayed on-screen and you may be required to read
and accept them to continue your use of the App or the Services.

Please note that we reserve the right to amend, revise, modify and/or change our Privacy
Policy at any time.

16. Our Communication with You

You can contact us at any time with questions or concerns. We will notify you separately
(probably, with a pop-up notice) if we process your personal data for any other purpose and,
if required, ask for your consent. You can control what and how you receive communications
from us and how we use your information.

You are entitled to request a copy of your personal data that we hold. You may also modify
your personal data at any time. If you would like to raise a complaint or comment, please
contact us by email at:

DPO@easymarkets.com

If you are not satisfied with our response or believe we are not processing your personal data
in accordance with the law, you can escalate your complaint to the data protection regulator
in your jurisdiction. The Office of the Commissioner for Personal Data Protection is at 1
Iasonos str.,1082 Nicosia. Further information is available on the Office of the Commissioner
for Personal Data Protection's website

here

Please note that we will try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you updated.

EASY FOREX TRADING LTD

ADDRESS: Griva Digeni 1, KRIEL COURT, 3035 LIMASSOL CYPRUS
TELEPHONE: +357 25 828899 I FAX: +357 25 817 183

http://www.easymarkets.com/

support@easymarkets.com

Trade Responsibly: CFDs and Options are complex instruments and come with a high risk of
losing money rapidly due to leverage. You should consider whether you understand how CFDs
and Options work and whether you can afford to take the high risk of losing your money.
Please refer to our full risk disclaimer. Easy Forex Trading Ltd (CySEC – License Number
079/07).