This Policy aims to define the process how L.F. Investment Limited collects and processes personal data of the Clients through the use of fxsimulator.purple-trading.com (hereinafter later referred to only as the “Website”), including any data the Client may provide through the Website when signing up thereto.
This Website is not intended for children and no data related to children may be collected.
1. DATA CONTROLLER
L.F. Investment Limited is the controller and responsible person/entity for Client’s personal data. It is important that the personal data the Company holds about the Client is accurate and current. The obligation to inform the Company about any changes in personal data will be on Client’s side
Full name of legal entity: L.F. Investment Limited
Title of DPO: Chief Executive Officer
Email address: firstname.lastname@example.org
Postal address: 11 Louki Akrita, 4044 Limassol, Cyprus
Telephone number: +357 25030444
The Client has the right to make a complaint at any time. He may contact the Company in case of any unclear issues or complaints on the above-mentioned address.
2. DATA COLLECTED
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).
The Company may collect, use, store and transfer different kinds of personal data about the Client which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier.
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, Client’s 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 the Client uses to access this website.
- Profile Data includes the username and password of the Client, his orders, 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 his communication preferences.
3. FXSIMULATOR ACCOUNTS
The Company will collect the following personal information about the Client in the event of opening an fxSimulator account with the Company:
- Email address;
- Phone number
This information will be held by the Company until the moment when such Client becomes a Company’s Client with real account opened. If he initiates the process of becoming a real account Client, he shall be requested to provide additional personal information and supporting documentation.
If the Client does not proceed with the opening of a real trading account with the Company, the Company will consider him as only an fxSimulator Client and shall keep only respective fxSimulator personal data of the Client.
IF THE CLIENT DOES NOT PROVIDE PERSONAL DATA
Where the Company needs to collect personal data by law, or under the terms of a trading agreement with such Client, but the Client does not provide such data after being requested so, the Company may not be able to perform the agreement with the Client (concluded or in the process of conclusion). In this case, the Company may have to cancel the agreement with the Client with the obligation to notify the Client thereabout.
HOW IS THE CLIENT’S PERSONAL DATA COLLECTED
The Company uses different methods to collect data from and about the Client, including the following:
Direct interactions. The Client may provide his personal data to the Company by filling in forms or by distant communication with the Company via post, phone, email or otherwise. This includes personal data the Client provides, if he:
- applies for the fxSimulator services by filling the registration form;
- applies for the fxSimulator services by contacting Company’s representatives, assigned for the communication with clients;
- applies for the fxSimulator services through any form of marketing tool (newsletter, landing page, etc.)
- Automated technologies or interactions. As the Client interacts with the Website, his Technical Data about his equipment, browsing actions and patterns may be collected automatically. The Company collects such personal data by using cookies, server logs and other similar technologies. Technical Data about the Client may also be requested if such Client visits other websites by employing cookies of the Company.
4. HOW THE COMPANY USES PERSONAL DATA OF THE CLIENTS
Client’s personal data with be used only in case where the law allows the Company to do so. Most commonly, we will use Client’s personal data in the following circumstances:
- Where there is a need to perform the agreement (concluded or in a process of conclusion with the Client).
- Where it is necessary for Company’s legitimate interests (or those of a third party) and if such interests and fundamental rights do not override these interests.
- Where the Company shall comply with a legal or regulatory obligation.
In general, the Company does not rely on respective consent, forming a legal basis for processing of Client’s personal data, other than in relation to sending third party direct marketing communications to you via email or text message. The Client has the right to withdraw his consent to marketing purposes at any time by contacting the Company at the following email email@example.com.
PURPOSES FOR WHICH THE COMPANY USES PERSONAL DATA OF THE CLIENTS
In a table format below, there is a description of all the ways the Company plans to use the personal data of its clients and the legal bases the Company relies on in such case. The Company has also identified what its legitimate interests are, where appropriate.
Client’s personal data may be processed for more than one lawful ground depending on the specific purpose for which we are using your data. If necessary, the Client shall contact the Company at firstname.lastname@example.org for the purpose of obtaining necessary details about the specific legal ground the Company relies on to process his personal data where more than one ground has been set out in the table below
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register the Client as a new customer||(a) Identity
|Performance of agreement with the Client.|
|To manage Company’s relationship with the Client, including:||(a) Identity
|Performance of agreement with the Client.|
(b) Asking the Client to leave a review or to take a survey
|(c) Marketing data|
|To deliver relevant website content and advertisements to the Client and to measure or understand the advertising efficiency.||(a) Identity
|Performance of a contract with the Client. Necessary for our legitimate interests (study of Client‘s behaviour and their use of fxSimulator, business growth, marketing strategy information).|
|To use data analytics to improve the Website, products/services, marketing, customer relationships and experiences.||(a) Identity
|Performance of a contract with the Client. Necessary for our legitimate interests (definition of respective Clients‘ categories, website update, business development, marketing strategy development).|
|To make suggestions and recommendations to the Client with regard to any product that may be of interest to the Client.||(a) Identity
|Necessary for our legitimate interests (business growth and development of portfolio of Clients of real accounts).|
|To administer and protect Company‘s business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|Performance of a contract with the Client. Necessary for our legitimate interests (provision of administration and IT services, network security, fraud prevenetion, business reorganisation).|
The Company provides option to the Client with regard to certain personal data uses, particularly related to marketing and advertising.
Company may use Client‘s identity, contact, technical, usage and profile data to form a view with regard to potential needs of such Client or what may be of his interest. Thus, the Company may decide on products, services and offers relevant for the Client (so for the marketing purpose).
The Client may receive marketing communications from the Company only if he has requested information from the Company or provided his details when entering the Website for the purpose of receiving information and, in each case, not opting out the receipt of marketing notifications.
Before sharing Client‘s personal data for marketing purposes with any company outside L.F. Investment Limited group of companies, the Company needs an express opt-in consent of the Client.
Third Party Sites and Services:
- Segment (Privacy)
- Wedos (Security policy information)
- Google Analytics and Google AdWords (Data Processing Amendment), Google (Ads Data Processing Terms)
- Facebook (Data Policy).
- Purple Trading s.r.o.
- Purple Technology s.r.o.
The Client shall have the right to ask the Company or third parties to stop sending any marketing messages at any time by following the opt-out links on any marketing message sent to him or by contacting the Company at any time at the following email address: email@example.com
The Client shall have the right to set his browser to refuse all or some browser cookies, or to alert the Company of any setting or access of cookies on the Website.
6. CHANGE OF PURPOSE
Personal data of the Client may be used for the purposes for which they have been collected, unless any other reason is considered and such reason is compatible with the original purpose.
In case of any unrelated purpose, the Company shall notify the Client and explain the legal basis thereof. Client‘s personal data may be processed without the knowledge or consent of such client, in compliance with the rules specified above, where required or permitted by the law.
7. DISCLOSURE OF CLIENT’S PERSONAL DATA
The Company may share Client‘s personal data with third parties for the purpose of carrying out its services related to fxSimulator properly. Security of Client‘s personal data shall be fully respected by such third parties and treated in accordance with the law. Such Client‘s personal data may not be used by third parties for their own purposes while they may be processed only for specified purposes by the Company and in accordance with Company‘s instructions.
8. DATA SECURITY
The Company is obliged to put appropriate security measures in place to prevent Client‘s personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, the Company shall limit access to Client‘s personal data to only such employees or third parties that are actively participating on the performance of subject of the License Agreement. Such employees or third parites will only process Client‘s personal data on the basis of Company‘s instructions while respecting the duty of confidentiality.
The Company shall implement procedures to deal with any suspected personal data breach and notify the Client and any applicable regulator thereabout, where legally required so.
9. DATA RETENTION
Personal data of the Client shall be retained for as long as necessary to meet the purposes for which they were collected, including the purposes of satisfying any legal, accounting, or reporting requirements.
For the purpose of determination of appropriate retention period for personal data, the Company shall consider the number, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of such personal data, the purposes for which such personal data is processed and if these purposes may be achieved through other means, and the applicable legal requirements.
10. LEGAL RIGHTS OF THE CLIENTS
Any Client shall have following rights under data protection laws in relation to his personal data:
- Request access to his personal data (commonly known as a “data subject access request”). The Client is allowed to receive a copy of personal data the Company keeps about him and to check that such data is lawfully processed.
- Request correction of Client‘s personal data. The Client may request correction of any incomplete or inaccurate data the Company keeps about him, though the Company may need to verify the accuracy of the new data the Client provides.
- Request erasure of Client‘s personal data. The Client has the right to request the Company to delete or remove personal data where there is no appropriate reason for the Company to process it. The Client may also request the Company to delete or remove his personal data where he has successfully exercised his right to object to processing (see below), where hi information may have been processed unlawfully or where the Company is required to erase his personal data to comply with local law. Nevertheless, the Company may refure to comply with Client’s request for specific legal reasons, which it shall notify the Client thereabout.
- Object to processing of Client‘s personal data where the Company relies on a legitimate interest (or those of a third party) and there is something about his particular situation making him wanting to object to processing on this ground as the Client believes it affects his fundamental rights and freedoms. The Client may also object processing of his personal data for direct marketing purposes. In some cases, the Company may demonstrate that it has compelling legitimate grounds to process Client‘s information, overriding his rights and freedoms.
- Request restriction of processing of Client‘s personal data. This allows the Client to ask the Company to suspend the processing of his personal data in the following scenarios: (a) if the Client wants the Company to establish the data’s accuracy; (b) where Company‘s use of the data is unlawful but the Client does not want the Company to erase it; (c) where the Client needs the Company to keep the data, even if no longer required by the Company, as he may need it to establish, exercise or defend legal claims; or (d) the Client has objected to Company‘s use of his data but the Company needs to verify whether it has overriding legitimate grounds to use it.
- Request the transfer of Client‘s personal data to him or to any third party. The Company will provide such personal data to the Client or respective third party of his choice in a structured, commonly used, machine-readable format. This right only applies to automated information which the Client initially provided consent for to the Company to use or where the Company used the information to perform a contract with the Client.
- Withdraw consent at any time where the Company relies on consent to process Client‘s personal data. However, this will not affect the lawfulness of any processing carried out before the Client withdraws his consent.