Privacy Policy

• full name
• residential address
• contact details (e.g. telephone number, email address, etc.)
• date of birth, place of birth, gender, citizenship
• information about your income and wealth, including details about your source of funds, assets and liabilities, bank account information, trading statements, financial statements
• trading account balances, trading activity, your inquiries and our responses
• profession and employment details
• authentication data (e.g. signature)
• location data
• trading performance, knowledge and experience
• verification information, which includes information necessary to verify your identity such as a passport or driver’s license (examples also include background information we receive about you from public records or from other entities not affiliated with us). Furthermore, we may collect other identifiable information, such as identification numbers and/or passport/tax registration numbers
• any other information customarily used to identify you and about your trading experience which is relevant to us providing our services to you.

We obtain this information in a number of ways through your use of our services, including through any of our websites, apps, the account opening applications, our demo account forms or customer service communications. We may also collect this information about you from third parties such your payment providers and through publicly available sources. We also keep records of your trading behavior, including records regarding the following:

• products you trade with us and their performance
• historical data about the trades and investments you have made, including the amount invested
• your preference for certain types of products and services

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

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

• initiating legal claims and preparing our defense in litigation procedures
• risk management
• measures to manage business and for further developing products and services
• measures to ensure IT and system security, preventing potential crime, asset security, admittance controls and anti-trespassing measures
• sharing your personal data within MultiBank Group for the purpose of updating/verifying your personal data in accordance with the relevant anti-money laundering compliance framework

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 time; however, any processing of personal data prior to the receipt of your revocation will not be affected.

Once you successfully open a trading account with us, or subscribe to an update, we will need to use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate 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 information to try to ensure that you are getting the benefit of the best possible products and services from us.

We may need to use personal information collected from you to investigate issues or to settle disputes with you because it is in our legitimate interests to ensure that issues and disputes get investigated and resolved in a timely and efficient manner.

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

Our webpages 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 information (such as trading history) with the personal information of our other clients on an anonymous basis. If your personal information is not in an anonymized form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.

We may use your personal information to send you marketing communications 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 information to any outside parties that may allow them to directly market to you.

We may use your personal information for internal business and research or record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the services and products we provide to you. We will also keep records to ensure that you comply with your contractual obligations pursuant to the agreement governing our relationship with you.

Often 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 information to send you these legal notifications. You will continue to receive this information from us even if you choose not to receive direct marketing information from us.

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 legitimate interest to do this to maintain a safe and secure working environment.

• any companies under MultiBank Group, meaning any of our ultimate holding companies and their respective subsidiaries may receive such information;
• our associates and service providers, for business purposes, including third parties such as business service providers and specialist advisers who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, research or other services;
• business introducers with whom we have a mutual business relationship;
• business parties, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;
• anyone authorised by you.

If the Company discloses your personal information to business parties, such as card or other payment processing companies or banks, in order to perform the services requested by clients, such third parties may store your information in order to comply with their legal and other obligations.
Clients accept and consent that the Company may, from time to time, analyze the data collected while visiting our website(s) or by other means, such as questionnaires, for statistical purposes in order to improve the Company’s business activities.

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

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).

Logging certain behaviors on the site enables the company to track user action and therefore troubleshoot any issues that may occur.

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).

Cookies are text files with a small amount of data sent from our website(s) to your browser and stored on your computer’s hard drive. Cookies help us improve the performance of our website(s) and our website visitors’ experience, track your referrer (if any) and improve our future advertising campaigns.

Cookies are small pieces of data sent from our website(s) to your browser and stored on your computer’s hard drive when using our site(s), and they may include a unique identification number. The purpose of collecting this information is to provide you with a more relevant and effective experience on our website(s), including the presentation of our web pages according to your needs or preferences.
Cookies are frequently used on many websites on the internet, and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser. You may not be able to access some parts of our website(s) if you choose to disable the cookie acceptance in your browser, particularly in your MyMultiBank account panel and other secure parts of our website(s). We therefore recommend you to enable cookie acceptance in order to benefit from all our online services.
Furthermore, we use cookies for re-marketing features in order to allow us to reach out to users who have previously visited our website(s) and have shown an interest in our products and services. Periodically, we may use third party vendors to display our ads over the internet to you, based on your previous use of our website(s). You can opt out this particular use of cookies at any time by visiting Google’s Ads Settings page and the DoubleClick opt-out page or as they later update those facilities.
The Company uses session ID cookies and persistent cookies. A session ID cookie expires after a set amount of time or when the browser window is closed. A persistent cookie remains on your hard drive for an extended time period. You can remove persistent cookies by following directions provided in your web browser's ‘Help’ file.
For further details about our cookie policy and how our cookies work, read our Cookies Policy.

• a copy of the documents we used in order to comply with our customer due diligence obligations;
• supporting evidence and records of transactions with you and your relationship with us

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

We will take all reasonable steps to make sure that your personal information remains accurate, complete and up-to-date. If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your personal information to others, we will let them know about the rectification where possible. You may inform us at any time that your personal details have changed by e-mailing us at [email protected]. The Company will change your personal information in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof, i.e. personal information that we are required to keep for regulatory or other legal purposes.

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

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 information or object to us processing it. It will not stop us from storing your personal information. We will inform you before we decide not to agree with any requested restriction. If we have disclosed your personal information to others, we will inform about the restriction if possible.

Under the General Data Protection Regulation (679/2016), you have the right, in certain circumstances, to obtain personal information 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.

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

• relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
• processing your personal information for direct marketing;
• processing your personal information 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).

If you do not want us to use your personal information, you must inform the Company by sending an email to [email protected] . If you decide to do so, we may not be able to continue to provide information, services and/or products requested by you and we will have no liability to you in this respect.

The Company may disclose your personally identifiable information as required by rules and regulations 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 information 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 information due to misuse or misplacement of your passwords, negligent or malicious intervention or otherwise by you or due to your acts or omissions or a person authorized by you (whether or to that authorization is permitted by the terms of our legal relationship with you).

If you have any questions or concerns regarding this Privacy Policy, please e-mail us at [email protected].