This privacy notice applies to the processing activities performed by Exotrader to the personal data of its clients, prospective clients, and website visitors.
Your privacy is of the utmost importance to us. It is our policy to safeguard the confidentiality of information and respect the privacy of individuals.
Please see below for information about how we manage personal data, and for information about your rights with respect to the processing of your personal data.
The following terms are defined as follows:
Our products and services are provided through local operating entities that are part of the Exotrader group of companies.
You are contracting with Exotrader as specified in our Terms of Service. The company you are contracting with is your Data Controller, and is responsible for the collection, use, disclosure, retention, and protection of your personal data in accordance with our global privacy standards, this Privacy Notice, as well as any applicable national laws.
Exotrader takes the security of personal data incredibly seriously. Please see here for further detail about our information security practices, and here for general security information.
We obtain information about you in a number of ways through your use of our products and services, including through any of our websites, the account opening process, webinar sign-up forms, event subscribing, news and updates subscribing and from information provided in the course of ongoing support service communications.
As part of processing your personal data for the purposes set out above, Exotrader may disclose your personal data to any members of the Exotrader company group, and to third parties. For example, Exotrader may disclose your personal data to any of our service providers and business partners, for business or other legitimate purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, debt-recovery, analytics, research or other services.
If Exotrader discloses your personal data to service providers and business partners, in order to perform the services requested by clients or to comply with our legal and regulatory obligations, such providers and partners may store your personal data within their own systems. We require them to protect the confidentiality of this personal data, and comply with all relevant privacy and data protection laws.
Our operations are supported by a network of computers, servers, other infrastructure and information technology, and third-party service providers. We and our third-party service providers and business partners store and process your personal data in the European Union, Japan, Australia, the United Kingdom, the United States of America and elsewhere in the world. Courts, law enforcement and security agencies of these jurisdictions may be able to use legal processes to access your personal data.
We may transfer your personal data outside the EEA and UK to other Exotrader group companies, service providers and business partners. Transfers outside of the EEA or the UK (as appropriate) shall be in accordance with lawful transfer mechanisms. If personal data is transferred to a country which has been found by the European Commission to have an essentially equivalent standard of data protection to the EEA, then Exotrader may rely on an ‘adequacy decision’ to transfer that personal data. See here for a list of countries with adequacy decisions. If personal data is transferred from the EEA or UK to the US, we may rely on standard contractual clauses.
Your use of digital assets may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to re-identification of transacting individuals and the revelation of personal data, especially when blockchain data is combined with other data.
As blockchains are decentralized or third-party networks which are not controlled or operated by Exotrader, we are not able to erase, modify, or alter personal data on such networks.
When personal data is no longer necessary for the purposes for which it may lawfully be processed, we will remove any details that will identify you, or we will securely destroy the relevant records. We may need to maintain records for a significant period of time after you cease being our client for legal or regulatory reasons, for example when we need to retain information to help manage a dispute or legal claim. Additionally, we are subject to certain anti-money laundering laws which may require us to retain the following for a period (e.g., 5 years) after our business relationship with you has ended:
If you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications.
We may keep your personal data for longer than 5 years if we cannot delete it for legal, regulatory, or technical reasons.
When you use our products and services or visit our websites, we may place tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used when engaging with us. We use cookies to help us recognize you as a customer, collect information about your use of our products and services, to better customize our services and content for you, and to collect information about your computer or other access devices to ensure our compliance with our U.S. Bank Secrecy Act, fraud, security, sanctions and AML obligations.