DATA PROTECTION AND PRIVACY POLICY Data Protection Act London Capital Group (Cyprus) Limited (LCG) may process information relating to you, including holding such information in a manual format or electronic database, in order to satisfy any contractual, regulatory or statutory requirements we may have. By opening a trading account with the Company, the client hereby gives its consent to such collection, processing, storage and use of personal information by the Company as explained below. Unless we receive specific written instructions to the contrary, by providing this information you agree that we may process this information in order to fulfil such obligations. Privacy Policy Introduction: Protecting the security and privacy of your personal information is important to LCG and to the way it conducts its business in compliance with laws on privacy, data protection and data security. The purpose of this policy is to outline what information LCG may collect, how it uses and safeguards that information and with whom it may share it. At LCG, we are committed to maintaining the highest standards of integrity in our business. In the course of our business, it is necessary to collect Personal Information about our potential clients. We take this activity seriously and seek to provide fair, secure and appropriate methods for the handling of Personal Information. All such activities are intended to be consistent with both generally accepted privacy ethics and standard business practices. Your Personal Information may be shared with a limited number of trusted partners and/or affiliates of LCG where such use is restricted to the management of your account. If you have any questions or comments about LCG s Data Protection and Privacy Policy, please contact our Customer Support team via the details on the Contacts page. Personally Identifiable Information Through its websites, LCG will not collect any personally identifiable information about you (e.g. your name, address, telephone number or e-mail address ("Personal Information")), unless you voluntarily choose to provide it (e.g. by registration, email enquiry, survey). If you do not want your personal information collected, please do not submit it. By submitting your Personal Information you consent to LCG using your Personal Information in the ways listed below. You also consent to LCG transferring your Personal Information outside the European Economic Area where it is necessary for LCG to fulfil its contractual, regulatory and legal obligations, according to the provisions of Processing of Personal Data (Protection of the Individual) Law of 2001. We will only transfer Personal Information to organizations outside the EEA if we have assessed that the organization we are sending the information to as having appropriate controls and safeguards in place. 1
How does LCG use your information? We will use, store, process and handle Your Personal Information (in case you are a natural person) in connection with the furthering of the Agreement between us, in accordance to the Processing of Personal Data (Protection of the Individual) Law of 2001, as amended or replaced from time to time. LCG may use your information for any one or more of the following purposes: to confirm your identity to maintain your personal profile to manage your account and keep you updated on all matters that concern your account to provide the services to you that you have requested including processing transactions to contact you when necessary or appropriate in relation to the services being provided to you to provide you with information about our products and services and provide you with information or opportunities that we believe might be relevant to you to tailor the website or other service we provide to you to your needs and interests to create anonymised statistical data If you choose not to have your Personal Information used to support LCG s customer relationship programs (especially direct-marketing or market-research), LCG will respect your choice. LCG does not now (and does not intend to in the future) sell, rent or otherwise market your Personal Information to third parties. You may opt out of receiving marketing emails at any time by selecting the 'unsubscribe' link at the top of the emails or by emailing our Customer Support team (via the details on the Contacts page) with your request. Contact Clients From time to time the Company may contact clients whether by phone or email for the purpose of administering the terms of the Agreement between us.. In addition, the Company may, on occasion, seek to contact clients, whether by phone or by email, for the purpose of informing them of unique promotional offerings provided by the Company for the client. Clients consent to the receipt of such contact when they consent to our terms and conditions of use when registering with the Company. Any person wishing to opt out of further contact with the Company at any time whatsoever is entitled to do so, simply by contacting the Company whether by phone or email and requesting that no further contact on behalf of the Company be made. Non-Personal Information Collected Automatically When you access its websites, LCG may automatically (i.e. not by registration) collect statistical information that is not personally identifiable (e.g. type of Internet browser and computer operating system used; domain name of the website from which you came; number of visits, average time spent, pages viewed). LCG may use this information and share it within the LCG group to measure the use of its website and improve its content. 2
Who may LCG disclose Personal Information to? Your Personal Information may be disclosed to: the Cyprus Securities and Exchange Commission (CySEC) and other regulatory and government bodies whom LCG is required to disclose by law; financial institutions and other similar organizations that LCG deals with in the course of its business; service providers and specialist advisers that provide services to LCG; any third parties where this is necessary to process a transaction or provide services which you have requested; introducing brokers or similar brokers who have been contracted to provide us with administrative, financial, insurance, research or other services; credit providers, courts, tribunals and regulatory authorities as agreed or authorized by law; credit reporting or reference agencies; anyone authorized by you (such as your financial adviser, broker, solicitor or accountant). Please note LCG will never sell or provide your Personal Information to third parties for marketing purposes. In addition, the Company may engage third parties to help carry out certain internal functions such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to its business. Use of the shared information is strictly limited to the performance of the above and is not permitted for any other purpose. Generally, we require any third party service provider that we share Personal Information with, undertake to respect any individual s right to privacy and comply with the Data Protection Principles. These third-party service providers may keep a record of any searches performed on our behalf and may use the search details to assist other companies in performing their searches. Third parties are not covered by this privacy policy. In cases where clients have been introduced by a Business Introducer, such Business Introducer may have access to clients information. Hence, clients hereby consent to the sharing of information with such Business Introducer. Third Party Sites The LCG web site contains links to other web sites. Please be notified that LCG cannot be held responsible for the privacy practices of other web sites. We encourage all visitors to be aware and read the privacy statements of each and every web site that collects personally identifiable information. Retention of records We will not keep your information for any longer than is required. In many cases, information must be kept for considerable periods of time. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under Applicable Regulations, we will keep records 3
containing Client personal data, trading information, account opening documents, communications and anything else which relates to the Client for at least five years after termination of the Agreement between us. In any event, we will keep your information for the duration of applicable Limitation of Actions Laws as a minimum. Security LCG takes precautions to ensure the security of your personal information and strives to keep it accurate. LCG carefully protects your personal information from loss, destruction, falsification, manipulation, and unauthorized access or unauthorized disclosure and has developed and will maintain security procedures to safeguard Personal Information against loss, theft, copying, and unauthorized disclosure, use or modification. Access to Personal Information is restricted to employees and authorized service providers who need it to perform their work. While we will use all reasonable efforts to safeguard your information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data transferred from you, or to you via the internet. Access to your Personal Information held by us Under the Processing of Personal Data (Protection of the Individual) Law of 2001, as amended or replaced from time to time, you as a natural person have the right to obtain a copy of any personal information which we hold about you and to advise us of any perceived inaccuracy. To make a request, please contact us, verifying your identity and specifying what information you require. We may charge an administrative fee. You may contact us supportteam@lcg.com Restriction of responsibility The Company is not responsible for the privacy policies or the content of sites to which [Company s website] links and has no control of the use or protection of information provided by the clients or collected by those sites. Whenever a client elects to link to a co-branded web site or to a linked web site, the client may be asked to provide registration or other personal information. Please note that such information is recorded Cookies Cookies are small pieces of data sent from a website and stored in a user s web browser whilst the user is browsing that website. How we use Cookies on our Site and what Information we collect. Like most websites, LCG uses cookies to improve your experience on our websites as the data from cookies enables us to determine the type of browser and settings you are using, where you have been on our website, when you return to the website, where you came from and to ensure your information is secure. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. If you choose to opt out of cookies you may 4
still use our site, but your ability to use some areas will be limited. We would strongly recommend that you allow cookies on our website to ensure you have the best possible experience. Turning off cookies may result in reduced performance of our website and trading platform, however if you would still like to opt out of cookies, you can do this through your website browser. Our customer support team would be happy to talk you through this process if you require assistance. For more information about the types of cookies LCG uses please see our Cookie policy. Use of Web Beacons Some of our Web pages may contain electronic images known as Web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign. Privacy Statement Changes LCG may change this privacy statement at any time. In the event that the Company materially changes this Policy including how it collects, processes or uses clients personal information, the revised Privacy Policy will be uploaded in the Company s website. In this respect, you hereby agree to accept posting of a revised Privacy Policy electronically on the website as the actual notice of the Company to its clients. Any dispute over the Company s Privacy Policy is subject to this notice and the Client Agreement. You are advised to read this statement each and every time you access the site so that you are satisfied with the privacy conditions under which you provide LCG with your personal information. Trade Responsibly: Contracts for Difference (CFD) trading carries a high level of risk to your capital and can result in losses that exceed your initial deposit. CFD trading may not be suitable for everyone, so please ensure that you fully understand the risks involved. Before deciding to trade, you need to ensure that you understand the risks involved considering your investment objectives and level of experience. Past performance of CFDs is not a reliable indicator of future results. Most CFDs have no set maturity date - CFD positions typically mature on the date you choose to close the relevant existing open position. You should seek independent financial advice, if you feel it is necessary or appropriate. Please read carefully the relevant Risk Disclosure, available here Legal Documentation London Capital Group (CYPRUS) Limited (LCG CY) is a company registered in Cyprus under registered number: 356430. LCG CY is authorised and regulated by the Cyprus Securities and Exchange Commission (License Number:341/17). The registered address for LCG CY is: 205 Arch. Makarios Avenue III, Victory House, 5th Floor, 3030 Limassol. 5