Privacy Policy

INTRODUCTION

This Privacy Policy (“Policy”) explains the privacy practices employed by AXSE Brokerage LTD. (the “Company”) in providing the Service (as they defined in the services agreement) to its customers and other service providers (“you” or “Client”,) and shall be read in the light of the legal agreements and policies agreement provided by Company.

This privacy police also regulates situations which occur before any contractual relationship between the Company and you is established, taking into consideration that company processes personal data of those natural persons communicating and cooperating on the basis of promotional, training, educative purposes (“non-client”). Non-client status may have also natural persons who have strived for becoming a client, however for various reasons they have not or the Company rejected to accept them (negative market target, incomplete registration, missing KYC documents etc.)

As suggested above, this privacy also apply to processing personal data of all specific Company’s service providers such as introducing brokers, strategy providers, marketing services providers etc. if provided by natural persons and/or companies structure, in which case we process personal data of its directors, shareholders and/or employees if necessary.

1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how the Company collects and processes your personal data through your use of its website, including any data you may provide through this its website and/or other affiliated website when you sign up or otherwise register. These websites are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

AXSE Brokerage LTD. is the controller and responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

CONTACT DETAILS

Fullnameoflegalentity: AXSE Brokerage LTD.

Emailaddress: dpo@purple-trading.sc (herein as “Email”)

Postaladdress: Suite 3, Global Village, Jivan’s Complex, Mont Fleuri, Mahé, Seychelles

Telephonenumber: +441 446 509 157

You have the right to make a complaint at any time to Data Protection Commissioner. We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner so please contact us in the first instance.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing

from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

DEMO/TRAINING ACCOUNTS

We will collect the following personal information from you when you are opening a demo/training account with the Company Demo/training account opening is available via multiple websites and/or mobile apps from various platform providers:

i. Full name;

ii. Email address;

iii. Contact details (i.e. telephone numbers, address, hometown, IP address);

This is formation will be held by the Company until you become active Company’s Client, which case you shall be requested to provide additional personal information and supporting documentation.

During this period, you may be addressed with organizational and commercial messages and/or calls corresponding to the scope of demo/training account services. Regarding commercial messages, you are always entitled to reject such marketing communication simply by (a) opting- out button in the newsletter body, (b) using our contact form, or c) contacting us at the following Email.

If you do not proceed with the opening of a Trading Account with the Company and the demo/training account is considered to become dormant, the Company will proceed with erasure of your personal data as applicable.

EDUCATIVE, PROMOTIONAL AND INQUIRY WEBSITES

We will collect the following personal information from you when you register to various websites containing educative or promotional offers and invitation opportunities from the Company and/or its outsourcing or otherwise cooperating partners (e.g. tied agent):

i. full name;

ii. email address;

iii. contact details (i.e. telephone numbers, address, hometown, IP address);

This information will be held by the Company until you become active Company’s Client, in which case you will be requested to provide additional personal information and supporting documentation.

During this period, you may be addressed with organizational and commercial messages and/or calls corresponding within the scope of original registration website. Regarding commercial messages, you are always entitled to reject such marketing communication simply by (a) opting- out button in the newsletter body, (b) using our contact form, or c) contacting us at the Email.

If you do not proceed with the opening of a Trading Account with the Company or demo/training account, the Company will proceed with erasure of your personal data as applicable.

This period might be prolonged by you granting us your consent to process personal data (if applicable on the website).

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• create an account on our website;

• subscribe to our service or publications;

• request marketing to be sent to you;

• subscribe to receive trainings, webinars, seminars, e-books or trading tools;

• enter a competition, promotion or survey; or

• give us some feedback.

Introducing Brokers and other affiliates: We may be provided with your personal data though Company’s Introducing Brokers and/or other affiliates. In this case you acknowledge that the introducing party may disclose or make available to the Company personal data for the purposes of the services provided by the Company. Both the Company and the Introducing Broker are Controllers of your data for the purpose of providing their services. The Company and the Introducing Broker are acting in common and not jointly in respect of your personal data.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.]

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as:

• Data from the following parties:

(a) analytics providers such as Google based outside the EU;

(b) advertising networks based outside and within the EU.

(c) Other public sources providing information about your potential status as a politically exposed person or the emergence of a sanction list that we use to detect misuse, particularly fraud.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

• Where your freely given, specific, informed and unambiguous consent has been granted (if applicable).

In general, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. We also rely on your consent should you choose to prolong period to receive marketing in situations specified herein. You have the right to withdraw consent to marketing at any time by contacting us at the Email.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us at Email if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new
customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order
including:
(a) Manage payments, fees and
charges
(b) Collect and recover money
owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to recover debts due to us)
To manage our relationship with
you which will include:
(a) Notifying you about changes
to our terms or privacy policy
(b) Asking you to leave a review
or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal
obligation
(c) Necessary for our legitimate interests
(to keep our records updated and to study
how customers use our
products/services
To administer and protect our
business and this website
(including troubleshooting, data
analysis, testing, system
maintenance, support, reporting
and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests
(for running our business, provision of
administration and IT services, network
security, to prevent fraud and in the
context of a business reorganization or
group restructuring exercise)
(b) Necessary to comply with a legal
obligation
To deliver relevant website
content and advertisements to
you and measure or understand
the effectiveness of the
advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our legitimate interests (to
study how customers use our
products/services, to develop them, to
grow our business and to inform our
marketing strategy)
To use data analytics to improve
our website, products/services,
marketing, customer relationships
and experiences
(a) Identity
(b) Contact
(c) Technical
Necessary for our legitimate interests (to
define types of customers for our
products and services, to keep our
website updated and relevant, to develop
our business and to inform our marketing
strategy)
To make suggestions and
recommendations to you about
goods or services that may be of
interest to you, either by
ourselves or via our Tied Agents
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to
develop our products/services and grow
our business)
Educative, promotional and
inquiry purposes (e.g. E-books,
webinars, seminars, inquiries
pages etc.)
(a) Identity
(b) Contact
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our legitimate interests. From the business point of view, it is essential and beneficial for you and the
related financial industry to overall keep our clients and all investors aware of newest and upcoming trends regarding
the world of trading.
Completion of interrupted
registration process
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests, while non-client unable or temporarily
unwilling to complete registration process. It is our legitimate interest to
contact such non-client to properly distinguish non-clients genuine needs and wants.
Negative target market(a) Identity
(b) Contact
(c) Technical
(b) if Necessary to comply with a legal obligation. Regulatory acts require implementation of negative target market criteria while evaluating Clients, consequently. Company being obliged to evaluate new clients to prevent negative target market camouflage attempts.
(c) Necessary for our legitimate interests (to able to defend the company status, its interests if necessary or convenient obliged to provide such data to public
authorities)
Proper performance of
a contractual obligation between
Company and its (service)
providers
(a) Identity
(b) Contact
(d) Usage
(e) Marketing and
Communications
(f) Technical
(a) Performance of a contract with counterparty
(b) if Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to able to defend the company status, its interests if necessary or convenient obliged to provide such data to public authorities)
Asserting legal claims and
defense in legal disputes,
prevention and investigation of
criminal offenses creditors or
insolvency administrators
requesting foreclosures
(a) Identity
(b) Contact
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our legitimate interests (to able to defend the company status, its interests if necessary or convenient obliged to provide such data to public
authorities)
Taking pictures and/or video
records during seminars,
presentations and other
(non)public invitation events
(a) Identity (pictures,
video)
Necessary for our legitimate interests (to able to defend the company status, its interests if necessary or convenient obliged to provide such data to public
authorities)

Notes to legitimate interest (article 6 (1) f GDPR):
If necessary (and legitimately), we process your data beyond the actual performance of the contract for the protection of legitimate interest of us or third parties.

Legitimacy is considered to match these criteria:
• Identification of legitimate interest (legitimate interest is well analyzed and identified as the most propriate)
• Carrying out of necessity test (processing of the data is necessary for fulfilling specified purpose)
• Carrying out of balancing test (the legitimate interest does not, in any way, override individual’s interests, rights or freedoms and respect also proportional test so you might expect to be contacted by us).

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

If you do not grant us your consent but you are our Client, we are entitled to send you a commercial newsletter (or give you telemarketing calls) under the conditions of directive 2002/58/EC of the European Parliament and of the Council. In any case, you are entitled to reject such marketing communication simply by (a) opting-out button in the newsletter body, (b) using our contact form, or c) contacting us at the Email.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered our website for the purpose of receiving information and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside AXSE Brokerage LTD. group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or] by Contacting us at any time at the Email.

Third party acting as a controller shall provide you with its own policy.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the Email.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with third parties (including Introducing Brokers, Tied Agents, Affiliates, etc) for the purpose of carrying out our services but should this be the case we check the issue.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Our service providers and vicarious agents may also receive data for these purposes if they maintain business confidentiality. These companies deliver IT services, logistics, printing services, legal, accounting, telecommunications and consulting as well as sales and marketing.

With regard to the transfer of data to recipients outside of our company, it should first be noted that as an investment service provider we commit ourselves to secrecy about all customer-related facts and valuations from which we become aware. In principle, we may only disclose information about you if required by statutory provisions, if you have given your consent, or if we are otherwise authorized to provide information. Under these conditions, in the case of a legal or regulatory obligation, recipients of personal data may be public bodies and institutions (e.g. regulatory authorities, tax authorities, law enforcement authorities).

Other data recipients may be those for whom you have given us your consent to submit the data or to whom we may delegate personal information due to legitimate interests.

6. INTERNATIONAL TRANSFERS

We might need on certain occasions for the purposes of carrying out our services to transfer your personal data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

• Where we use certain service providers, we may use specific contracts approved by the

European Commission which give personal data the same protection it has in Europe.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please Contact us at Email if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for regulatory purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If the processing of your personal data requires consent (such as marketing or other purposes stated herein), the data retention period may differ according its very purpose. If not stated otherwise, your personal data are processed for the period of 5 years or until you withdraw it.

Processing of personal data of service providers defined above takes five years after they cease being service providers.

Processing of personal data of non-clients registered on educative, promotional and inquiry websites may take up to 1 year without granting additional consent from registration or until rejection of such marketing.

Preservation of evidence for other purposes within the statutory limitation period.

If you fail to finish the registration process and/or fail to provide us with necessary documents (ID, POR etc.) we might strive to contact you and seek correction of the registration process. During this period processing of your personal data is bind to this very purpose and after reasonable time, we shall erase your data. This process may take up to 6 months.

Anonymous, not personally tagged pictures from seminars, conferences and other public

presentations might be processed for up to 5 years.

Personal data contained in email, chats and other means of distant communication might be processed according to the related and relevant purpose specified herein. Processing period might be up to 5 years.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to

verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that 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 your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you 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.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at Email.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

CHILDREN’S PRIVACY

We do not knowingly collect any information from anyone under 15 years of age. Our websites, products and services are all directed to people who are at least 15 years old or older. If you are under 15, do not use or provide any information on these websites or on or through any of its features / register on the websites, make any purchases through the websites or provide any information about yourself to us, including your name, address, telephone number or email address. If we learn that we have collected or received personal data from a child under 15, we will delete that information.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We 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.

COOKIESPOLICY

INFORMATION ABOUT OUR USE OF COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

Some cookies are absolutely necessary to enable you to move around our website and use its features. Without these cookies, essential security features cannot be activated and services you have asked for cannot be provided.

We use the following cookies

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a credit card or make use of e-billing services.

• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps

us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognize you when you return to our website.

This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.