INTERTRADER PRIVACY NOTICE

InterTrader takes your privacy seriously where we deal with your personal information. This means information that identifies you personally such as your name, credit card information, photo and contact details or data that can be linked with such information in order to identify you directly or indirectly (“information”).

This Privacy Notice (the “Privacy Notice”) sets out the basis on which any of your information will be collected, stored and used by us and reflects our commitment to maintain the confidentiality of your information and to provide all our customers with the best possible service.

References to “InterTrader”, “us”, “we“, “our” in this Notice mean InterTrader Limited which is owned and controlled by GVC Holdings PLC with registered address at Suite 6, Atlantic Suites, Europort Avenue, Gibraltar.

You have the right to object to us using, sharing or carrying out any activity with your personal information (in certain circumstances) including using your personal information for direct marketing (i.e. receiving emails from us notifying you about other products which we think will be of interest to you or being contacted with varying potential opportunities). Contact us at any time with the details provided in the contact section below for more details and to exercise this right where applicable.

1. WHAT PERSONAL INFORMATION DOES INTERTRADER COLLECT?

We collect and process your personal information in the following ways:

Information you give us directly

  • You give us information about yourself when you register for an account with us or for our risk-free demo. Information including contact details, age, gender, address details, financial details such as your income/savings, details of your trading experience and knowledge and payment details such as credit and debit card information.
  • You give us information about yourself when you register for any of our webinars. Information including your name and contact details.
  • You give us information about you when you like, post or otherwise interact with our social media pages such as Facebook, Twitter and Google+. This is generally contents of your public profile.
  • You give us information about you via completing our surveys or entering our contests from time to time. Participation in these surveys or contests is completely voluntary, and, therefore, you have the choice of whether or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as zip or postal code or age).
  • You may choose to provide additional information to us when you contact us or otherwise interact with us, including via e-mail, letter, phone or chat function and through your use of our services.

We keep records of communications when you contact us or otherwise interact with us, including via e-mail, letter, online, telephone or live chat function on our platforms;

Information you provide about another person

  • You give us information about another person where you opt into our special offers which may involve referrals for promotional purposes.

Information we collect automatically

  • When you interact with our services, our servers keep an activity log unique to you that collects certain administrative and traffic information including source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used.

2. HOW DOES INTERTRADER USE MY PERSONAL INFORMATION?

We may use your information for the following purposes:

To provide a requested service or carry out a contract with you

  • To collect payment, deliver our services to you and to process your online transactions and fulfil your orders.
  • To provide you with customer support and service messages, including messages requesting your feedback on our services and notifying you about changes to our platforms, services or changes to our terms, conditions and policies
  • To enforce any contract entered into between you and us for the provision of our services.
  • To conduct security reviews at any time to validate your identity, age, the registration information provided by you and to verify your use of our services and your financial transactions for potential breach of our General Terms and Conditions and of applicable law. Security reviews may include for example, ordering a credit report and/or otherwise verifying the information you provide against third-party databases.
  • To process any of your online transactions and payments (including disclosing your personal information to third party payment processors, ESPs, and other financial institutions as necessary).

In accordance with your preferences  

  • To contact you, including by email, SMS and telephone to provide you with information regarding our products, services and promotions. We will only do this in line with your marketing preferences. You can opt-out of this at any time.
  • To share your contact details, including name, email address, contact telephone number and account status with selected media partners and affiliates for the purposes of them being able to offer their own marketing services to you. We only do this where we have your consent and in line with your marketing preferences. You can opt-out of this at any time.
  • To enter you into surveys or promotions you have agreed to.
  • We place cookies and use similar technologies in accordance with our Cookies Notice for more information please refers to our Cookie Notice [Hyperlink].
  • By accepting any contest prize or winnings from Us, you consent to use of your name and likeness for advertising and promotional purposes without additional compensation, except where prohibited by law.
  • On other occasions where we ask you for your permission, we will use your personal information for the purpose which we explain at that time.

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. you can opt-out of this at any time by updating you marketing preference.

Where we have a legitimate Interest

  • To provide customer support services.
  • To investigate and address enquiries, questions and complaints and respond to any feedback.
  • To develop and improve our platforms to enhance your customer experience and personalise our platforms and services for you;
  • To improve the quality of the services we provide to customers.
  • Customer telephone and chat conversations will be recorded to allow us to improve the quality of our customer service and our products, train staff and to record of what is said in the event of a subsequent complaint.
  • To assist your participation in promotions, market research and events and information where you have indicated or we have inferred and interest in our products.
  • We monitor use of our platforms and online services, and use your personal information to help us improve and protect our content, services and platforms, both online and offline.
  • We monitor customer accounts to prevent the use of unfair practices in our
  • To ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.
  • To have our product services team contact you were you have indicated an interest in our products.
  • We may be required to share your data with trusted third parties who provide us with services relevant to our provision our services, including customer support, information security, payments, marketing, data analysis, research and surveys.
  • We will use personal information in connection with legal claims, and for compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
  • We use your personal information in order to build up a profile of your demographics, likely behaviours and preferences. This is used to inform the decisions we make in relation to the services, content and promotions we offer. We also report on the different contribution to our commercial performance from different customer profiles. We create profiles through manual or automated processes, including from third-party providers.

Where we have a legal obligation

  • To protect, investigate and deter against fraudulent, unauthorised or illegal activity. Including to undertake necessary security and identify verification checks.
  • In response to requests by government or law enforcement authorities conducting an investigation.
  • When required by the Gibraltar Financial Services Commission for regulatory purposes. For example, by recording customer telephone and chat conversations.

3. DOES INTERTRADER SHARE MY PERSONAL INFORMATION?

We share your personal information in the following circumstances:

  • We share with other companies in the GVC Group, which includes GVC Holdings PLC and its direct and indirect subsidiary companies for internal reasons, primarily for business and operational purposes in line with this privacy notice;
  • We share your personal information where we engage the services of trusted third-party suppliers to provide technical support and maintain your account with us. Such third parties include but not limited to providers of platforms hosting, maintenance, call centre operation, marketing, data analysis, research and surveys.
  • We share your personal information with third-party electronic payment processors and/or financial institutions to process financial transactions when you use our live trading services.
  • We share your personal information with trusted third-party suppliers of information verification services for the purposes of validating the personal information you provide to us in the course of using our services.
  • We may share the information that you provide to us if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or in order to enforce our terms of use and any other agreement; or to protect the rights, property, safety, or security of InterTrader, third parties, visitors to our platforms or the public.
  • Where you are found to have attempted to defraud us, our other group companies, or any other user of our services in any way including but not limited to payment fraud, or if we suspect you of fraudulent payment, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering), We reserve the right to share this information (together with your identity) with other Group , banks, credit card companies, and appropriate agencies.
  • As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal information will be disclosed to such entity.  Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.

We take steps to ensure that our arrangements with third-party suppliers (including online vendors) protect your privacy. We do not sell, rent or exchange your personal information with any third party for commercial reasons beyond the essential requirement for debit card validation when depositing or withdrawing funds, credit agencies should you wish to open a credit account with us and fraud prevention agencies.

4. HOW LONG DOES INTERTRADER KEEP MY PERSONAL INFORMATION?

Information that we collect will be retained only for as long as is necessary to fulfil the purposes outlined above in this Privacy Notice (this will generally be for the duration of time where you utilise our services) or to comply with our legal obligations. We may retain your information further for a period of time specifically required by applicable regulations or laws, such as retaining the information for tax and accounting and financial services regulations record keeping obligations.

When determining the relevant retention periods for your personal information, we will take into account factors including:

  • our contractual obligations and rights in relation to the information involved;
  • legal obligation(s) under applicable law to retain data for a certain period of time;
  • statute of limitations under applicable law(s);
  • (potential) disputes; and
  • guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

5. DOES INTERTRADER MAKE AUTOMATED DECISIONS ABOUT ME?

We may use automated decision making (i.e. decisions taken without human intervention), including profiling, to; create a description of your demographics, past behaviours, likely future behaviours and preferences.

This helps us;

  • to provide you the personally targeted content and offers through our platforms, and through our marketing communications;
  • to provide you differential services to customers related to payments and withdrawals, customer service and other operational services; and
  • to comply with legal and regulatory regulations, fraud or anti-money laundry and responsible trading .

If you disagree with the outcome of an automated decision please contact Us using the details in the Rights section and we will review the decision.

6. DOES INTERTRADER TRANSFER MY PERSONAL INFORMATION ABROAD?

We store your personal information on our servers based in Austria. This is within the European Union.

As with any multinational organisation, we are often required to transfer data internationally. Accordingly, data about you may be transferred globally (if your data is collected within the European Economic Area, this means that your data may be transferred outside of it).

Where your personal information is transferred to a country or territory outside the European Economic Area, and where this is to a country that is not subject to an adequacy decision approved by the EU Commission, We will take steps with the aim of ensuring that your privacy information continue to be protected. For example, by using third party’s Processor Binding Corporate Rules, Intra-group privacy agreements, EU Commission approved standard contractual clauses or verifying that third parties are certified under an approved certification mechanism according to international privacy rules.

7. HOW DOES INTERTRADER KEEP MY PERSONAL INFORMATION SECURE?

We understand the importance of information security and the techniques needed to secure information. We store all of the personal information we receive directly from you in a password-protected database residing within our secure network behind active state-of-the-art firewall software. Our services support SSL Version 3 with 128-bit encryption and TLS 1.2 with 256 bit encryption. We take steps to ensure all our subsidiaries, agents, affiliates and suppliers also employ adequate levels of security.

8. WHAT ARE MY PRIVACY RIGHTS?

By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the data protection regulator in your country. You can exercise any of these rights by contacting us through our contact information below.

  • The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you about other products which we think will be of interest to you or being contacted with varying potential opportunities).
  • The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Notice.
  • The right of access. You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
  • The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold.
  • The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information that we hold.
  • The right to restrict processing. You have rights to ‘block’ or supress further use of your information. When processing is restricted, we can still store your information, but will not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future.
  • The right to data portability. You have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however and there are exceptions.
  • The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator. See contact section above.
  • The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your information at any time.

9. CHANGES TO OUR PRIVACY NOTICE

We may periodically make changes to this Privacy Notice and will notify you of these changes where required by law to do so.  We recommend that you revisit this Privacy Notice regularly.

10. WHO TO CONTACT

If you have any questions, or wish to exercise any of your rights, please contact us at compliance@intertrader.com

If your country has a data protection authority, you have a right to contact it with any questions or concerns. If we cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.

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