Privacy Policy of Macorecut Capital Markets Limited

It is the stated policy of Macorecut Capital Markets Limited (hereater referred to as “Macorecut Capital Markets Ltd”, “Macorecut Markets”, ‘us’, ‘we’ and ‘our’) that Macorecut Capital Markets Limited will act in accordance with current best practce with regard to the processing of personal data.

Your privacy is very important to us and we make it our priority to safeguard and secure any and all confidental informaton relatng to individuals.

Macorecut Capital Markets Limited understands the importance of maintaining the privacy of your personal informaton. Macorecut Capital Markets Limited as a company would like to assure you of our commitment to keeping it private.

PRIVACY PROTECTION

Macorecut Capital Markets Limited has appointed a Data Protecton Officer to ensure that our Company manages/processes your personal informaton in compliance with the applicable data protecton laws and regulatons and in accordance with this Privacy Policy.

In relaton to your personal data, you agree that we use and rely on the data you provided us, and we and our group companies can store and process them both in physically and/or electronically.

It is your responsibility to make sure that your password is only known to you and not disclosed to anyone else. Your registered informaton is securely stored with us, and only authorized staff have access to this informaton. Please also note that transfer of informaton via the internet is not always entrely secure, but we have taken significant precautons to assure that your personal data is being protected.

PERSONAL INFORMATION WE COLLECT

If you decide to apply to open an account with Macorecut Capital Markets Limited, there is certain informaton that we will require from you in order to do so. Macorecut Capital Markets Limited obtains most of the informaton directly from you through applicaton or other forms, and from maintaining records of informaton provided in the course of ongoing customer service.

Macorecut Capital Markets Limited may also collect informaton about your use of the website, such as pages visited, frequency and duraton and visit and trading actvites.

The informaton that we may collect from you includes the following:

  1. Full Name
  2. Residental Address
  3. Contact Details (e.g., telephone number, email address, etc.)
  4. Date of Birth, Place of Birth, Gender, Citzenship, Country of Residence
  5. Profession and Employment Details
  6. Authentcaton Data (e.g., signature)
  7. Locaton Data
  8. Verificaton informaton, which includes informaton necessary to verify your identty such as a passport or driver’s license.

Macorecut Capital Markets Limited will use informaton collected from you to provide the informaton and services requested by you and to improve the quality of our service. Unless you are informed otherwise, the personal informaton Macorecut Capital Markets Limited holds is used for establishing and managing your account, reviewing your ongoing needs, enhancing customer service and products, by giving ongoing informaton or opportunites that may be relevant to you.

PROCESSING OF YOUR PERSONAL INFORMATION

We may process your personal data on the following bases and for the following purposes:

  1. PERORMANCE OF CONTRACT

    2. We process personal data in order to provide our services and products, as well as informaton regarding our products and services based on the contractual relatonship with our clients (i.e. so as to perform our contractual obligatons). In additon, processing of personal data takes place to be able to complete our client on-boarding/acceptance procedures. In view of the above, we need to verify your identty in order to accept you as our client and we will need to use those details in order to effectvely manage your trading account with us. This may include third partes carrying out credit or identty checks on our behalf. The use of your personal informaton is necessary for us to know who you are as we have a legal obligaton to comply with ‘Know Your Customer’ and customer due diligence’ regulatory obligatons.

  2. . COMPLIANCE WITH A LEGAL OBLIGATION

    3. In view of the above, we need to verify your identty in order to accept you as our client and we will need to use those details in order to effectvely manage your trading account with us. This may include third partes carrying out credit or identty checks on our behalf. The use of your personal informaton is necessary for us to know who you are as we have a legal obligaton to comply with ‘Know Your Customer’ and customer due diligence’ regulatory obligatons.

  3. .FOR THE PURPOSES OF SAFEGUARDING LEGITIMATE INTERESTS

    4. We process personal data so as to safeguard the legitmate interests pursued by us or by a third party. A legitmate interest is when we have a business or commercial reason to use your informaton. Examples of such processing actvites include the following:

    1. Initatng legal claim and preparing our defence in litgaton procedures.
    2. Risk management.
    3. Measures to manage business and for further developing and services
    4. Measures to ensure IT and system security, preventng potental crime, asset security, admitance controls and ant-trespassing measures

  4. YOU HAVE PROVIDED YOUR CONSENT

    5. Our storage and use of your personal data is based on your consent (other than for the reasons described or implied in this policy when your consent is not required). You may revoke consent at any tme; however, any processing of personal data prior to the receipt of your revocaton will not be affected.

  5. TO PROVIDE YOU WITH PRODUCTS AND SERVICES, INFORMATION

    6. Once you successfully open a trading account with us, or subscribe to an update, we will need to use your personal informaton to perform our services and comply with our obligatons to you. It is also in our legitmate interests to try to ensure that we are providing the best products and services so we may periodically review your needs based on our assessment of your personal informaton to try to ensure that you are getng the benefit of the best possible products and services from us.

  6. TO INVESTIGATE OR SETTLE ENQUIRIES OR DISPUTES

    7. We may need to use personal informaton collected from you to investgate issues or to setle disputes with you because it is in our legitmate interests to ensure that issues and disputes get investgated and resolved in a tmely and efficient manner.

  7. TO COMPLY WITH APPLICABLE LAWS, COURT ORDERS, OTHER JUDICIAL PROCESS, OR THE REQUIREMENTS OF ANY APPLICABLE REGULATORY AUTHORITIES

    8. We may need to use your personal informaton to comply with any applicable laws and regulatons, court orders or other judicial process, or the requirements of any applicable regulatory authority. We do this not only to comply with our legal obligatons but because it may also be in our legitmate interest to do so

  8. DATA ANALYSIS

    9. Our web pages and emails may contain web beacons or pixel tags or any other similar type of data analysis tools that allow us to track receipt of correspondence and count the number of users that have visited our webpage or opened our correspondence. We may aggregate your personal informaton (such as trading history) with the personal informaton of our other clients on an anonymous basis. If your personal informaton is not in an anonymized form, it is in our legitmate interest to contnually evaluate that personal informaton to ensure that the products and services we provide are relevant to the market.

  9. MARKETING PURPOSES

    10. We may use your personal informaton to send you marketng communicatons by email, phone, SMS or other methods (such as social media channels) to ensure that you are kept up to date with our latest products and services. We will not disclose your informaton to any outside partes that may allow them to directly market to you.

  10. INTERNAL BUSINESS PURPOSES AND RECORD KEEPING

    11. We may use your personal informaton for internal business and research or record keeping purposes. Such processing is in our own legitmate interests and is required in order to comply with our legal obligatons. This may include any communicatons that we have with you in relaton to the services and products we provide to you. We will also keep records to ensure that you comply with your contractual obligatons pursuant to the agreement governing our relatonship with you.

  11. LEGAL NOTIFICATIONS

    12. Oten the law requires us to advise you of certain changes to products or services or laws. We may need to inform you of changes to the terms or the features of our products or services. We need to process your personal informaton to send you these legal notficatons. You will contnue to receive this informaton from us even if you choose not to receive direct marketng informaton from us.

  12. PHYSICAL SECURITY

    13. If you enter any of our premises, we may record your image on our CCTV for security reasons. We may also take your details to keep a record of who has entered our premises on any given day. It is in our legitmate interest to do this to maintain a safe and secure working environment.

DISCLOSURE OF YOUR PERSONAL INFORMATION

The Company will not disclose any of its clients’ confidental informaton to a third party, except:

  1. to the extent that it is required to do so pursuant to any applicable laws, rules or regulatons;
  2. if there is a duty to disclose;
  3. if our legitmate business interests require disclosure; or
  4. at your request or with your consent or to Persons described in this policy. The Company will endeavour to make such disclosures on a ‘need to-know’ basis, unless otherwise instructed by a regulatory authority. Under such circumstances, the Company will notfy the third party regarding the confidental nature of any such informaton.

As part of using your personal data for the purposes set out above, the Company may disclose your personal informaton to the following:

  1. Any companies under Macorecut CAPITAL MARKETS LIMITED, meaning any of our ultmate holding companies and their respectve subsidiaries may receive such informaton;
  2. . Our associates and service providers, for business purposes, including third partes such as business service providers and specialist advisers who have been contracted to provide us with administratve, financial, legal, tax, compliance, insurance, research or other services;
  3. Business introducers with whom we have a mutual business relatonship;
  4. . Business partes, credit providers, courts, tribunals and regulatory authorites as agreed or authorized by law;
  5. Anyone authorized by you.

If the Company discloses your personal informaton to business partes, such as card or other payment processing companies or banks, in order to perform the services requested by clients, such third partes may store your informaton in order to comply with their legal and other obligatons.

Clients accept and consent that the Company may, from tme to tme, analyse the data collected while visitng our website(s) or by other means, such as questonnaires, for statstcal purposes in order to improve the Company’s business actvites

TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA

We may transfer your personal informaton outside the European Economic Area (EEA) to other Macorecut CAPITAL MARKETS LIMITED companies as well as service providers (i.e., processors) who are engaged on our behalf. To the extent we transfer your informaton outside the EEA, we will ensure that the transfer is lawful and that processors in third countries are obliged to comply with the European data protecton laws or other countries’ laws which are comparable and to provide appropriate safeguards in relaton to the transfer of your data in accordance with GDPR Artcle 46.

By submitng your personal data, you consent to your personal informaton being processed by staff of Macorecut CAPITAL MARKETS LIMITED operatng outside the EEA who work for us. Such staff may be, among others, engaged in the fulfilment of your requests, the processing of your payment details and the provision of support services. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

YOUR COLLECTED INFORMATION

Tracking systems used on the Company’s website(s) may collect your personal data in order to optmize the services provided to clients/potental clients. The website collects informaton in the following ways:

  1. DEVICE INFORMATION

    2. By recognizing your device used to access and use the Company’s website(s), we can provide you with the most appropriate version of our website(s).

  2. LOG INFORMATION

    3. Logging certain behaviours on the site enables the company to track user acton and therefore troubleshoot any issues that may occur.

  3. LOCATION INFORMATION

    4. Using your IP address helps us localize our website content, which we provide to you based on your country, and improve your user experience on our site(s). For further details about our cookie policy and how our cookies work, read our Privacy Policy.

HOW WE OBTAIN YOUR CONSENT

If our use of your personal informaton requires your consent, such consent will be provided in accordance with the express writen terms which govern our business relatonship (which are available on our website(s), as amended from tme tme), or any other contract we may have entered into with you or as set out in our communicaton with you from tme to tme.

If we rely on your consent as our legal basis for holding and processing your personal informaton, you have the right to withdraw that consent at any tme by contactng us using the contact details set out in this Privacy Policy.

STORAGE OF YOUR PERSONAL INFORMATION AND RETENTION PERIOD

In relaton to your personal informaton, we will hold this for as long as we have a business relatonship with you, in a combinaton of secure computer storage facilites and paper-based files and other records and we take the necessary measures to protect the personal informaton we hold from misuse, loss, unauthorized access, modificaton or disclosure.

When we consider that personal informaton is no longer necessary for the purpose for which it was collected, we will remove any details that will identfy you or we will securely destroy the records. However, we may need to maintain records for a significant period of tme (ater you cease being our client). For example, we are subject to certain antmony laundering laws which require us to retain the following, for a period of 5 years ater our business relatonship with you has ended:

A copy of the documents we used in order to comply with our customer due diligence obligatons; Supportng evidence and records of transactons with you and your relatonship with us Also, the personal informaton we hold in the form of a recorded communicaton, by telephone, electronically, in person or otherwise, will be held in line with local regulatory requirements (i.e., 5 years ater our business relatonship with you has ended or longer if you have legitmate interests (such as handling a dispute with you). If you have opted out of receiving marketng communicatons, we will hold your details on our suppression list so that we know you do not want to receive these communicatons.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION AND ACCESS

You have the right to request what informaton we process, along with a copy of that personal informaton within thirty (30) days from the date of your request. If you require additonal copies, we may need to charge an administraton fee.

RECTIFICATION

We will take all reasonable steps to make sure that your personal informaton remains accurate, complete and up-to-date. If the personal informaton we hold about you is inaccurate or incomplete, you are enttled to have it rectfied. If we have disclosed your personal informaton to others, we will let them know about the rectficaton where possible. You may inform us at any tme that your personal details have changed by emailing us at info@Macorecutmarkets.com. The Company will change your personal informaton in accordance with your instructons. To proceed with such requests, in some cases we may need supportng documents from you as proof, i.e., personal informaton that we are required to keep for regulatory or other legal purposes.

ERASURE

You can ask us to delete or remove your personal informaton in certain circumstances such as if we no longer need it or you withdraw your consent (if applicable) provided that we have no legal obligaton to retain that data. Such requests will be subject to any retenton limits we are required to comply with in accordance with applicable laws and regulatons. If we have disclosed your personal informaton to others, we will let them know about the erasure where possible.

PROCESSING RESTRICTIONS

You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as if you contest the accuracy of that personal informaton or object to us processing it. It will not stop us from storing your personal informaton. We will inform you before we decide not to agree with any requested restricton. If we have disclosed your personal informaton to others, we will inform you about the restricton if possible.

DATA PORTABILITY

Under the General Data Protecton Regulaton (679/2016), you have the right, in certain circumstances, to obtain personal informaton you have provided us with (in a structured, commonly used and machine-readable format) and to re-use it elsewhere or ask us to transfer this to a third party of your choice.

OBJECTION

You can ask us to stop processing your personal informaton, and we will do so, if we are:

  1. Relying on our own or someone else’s legitmate interests to process your personal informaton except if we can demonstrate compelling legal grounds for the processing;
  2. Processing your personal informaton for direct marketng;
  3. Processing your personal informaton for research unless we reasonably believe such processing is necessary or prudent for the performance of a task carried out in the public interest (such as by a regulatory or enforcement agency).

LEGAL DISCLAIMER

The Company may disclose your personally identfiable informaton as required by rules and regulatons and if the Company believes that disclosure is necessary to protect our rights or to comply with other proceedings, court order, legal process served or pursuant to governmental, intergovernmental or other regulatory bodies. The Company is not liable for misuse or loss of personal informaton or otherwise on the Company’s website(s) that the Company does not have access to or control over. The Company will not be liable for unlawful or unauthorized use of your personal informaton due to misuse or misplacement of your passwords, negligent or malicious interventon or otherwise by you or due to your acts or omissions or a person authorized by you (whether or to that authorizaton is permited by the terms of our legal relatonship with you).

Macorecut CAPITAL MARKETS LIMITED Card Acceptance

All credit/debit cards details and personally identfiable informaton will NOT be stored, sold, shared, rented or leased to any third partes.