1.1 To serve the сompany's clients Worldwide FXspace Fin Services LTD (further theCompany) collects personal data of clients, potential clients and employees.
The reasons of the above due to the fact that FXspace Worldwide Fin Services LTD wants toprovide a high level of protection of clients privacy as it is the most important fact of gainingand maintaining trust between a Company and its employees, suppliers and clients.
Guarantee to provide a high level of protection of personal data by adherence to certainorganizational and technical measures. Therefore, the Company has implemented severalinternal and external data protection policies, which are mandatory for observance byemployees of Worldwide FXspace Fin Services LTD.
Moreover, the obligations of the Company includes documenting, testing and monitoringinternal compliance with data protection policies and relevant statutory requirements in thefield of data protection, which includes the GDPR (General regulation in the field of dataprotection).
1.2. “Personal information” is any information that may be related to an identified oridentifiable natural person. For a general understanding, the identified natural person is aperson that can be known, directly or indirectly, in particular by ID: name, residence, phone number, age, gender. Identified persons could be individuals such as clients, employees, jobapplicants, suppliers, business partners and others. Moreover, the document refers todifferent categories of personal data and confidential information, which includes: indicatorsof health status, account number, identification number, residence data, online identifier andone or more factors specific to the physical, physiological, genetic, mental, economic,cultural or social identity of such individual.
1.3 Information about the companies or business enterprises is not personal data, however,note that contact information of such companies or business enterprises, such as name,title, address, work email, work telephone number, and other are considered to be personaldata.
1.4 FXspae Worldwide Fin Services LTD collects personal information only for legitimatebusiness purposes, which include establishing and maintaining relationships with clients andsuppliers, the requisitions for acquisition, employment and management of all aspects ofemployment, exchange of information, fulfilment of legal obligations and requirements,execution of contracts, providing services to clients and more.
1.5 Personal data will:
- be processed legally, properly and transparently towards the data subject;
- be collected for the indicated explicit and legal purposes and will not subsequently beprocessed for any other purposes that do not correspond to those;
- be consistent with the purposes of the processing, be relevant to them and be usedonly to the extent that is necessary for them;
- be accurate and, if necessary, relevant;
- be deleted or corrected by all possible measures and within a reasonable time if theyare incorrect regarding the purposes of the processing;
- be stored in a form that ensures the identification of data subjects only for the periodrequired for the purposes for which such personal data is processed;
- be processed in a manner that ensures the safety of personal data, includingprotection from unauthorised or unlawful processing and against accidental loss,destruction or damage, using appropriate technical and organizational measures.
1.6 FXspace Worldwide Fin Services LTD is responsible for compliance with the abovepoints.
2. The legal basis for the processing of personal data.
2.1 Legal grounds on which the principle of the processing of personal data of FXspaceWorldwide Fin Services LTD based are:
- legal obligation or claims;
- fulfilment of the terms of the contract to which the data subject is a party;
- the consent of the data subject for one or more specific purposes;
- the legitimate interests pursued by the Company.
2.2 The Agreement.
2.2.1Collction, registration and further processing of personal data of clients, suppliers,business partners and employees are based on the consent of the identified individuals tothe processing of personal data for one or more specific purposes. In turn, FXspaceWorldwide Fin Services LTD must be able to confirm that the data subject has given consentto the processing of such personal data.
2.2.2 Consent to the processing of personal data by the identified individuals must bespecific, unequivocal and free-will after obtaining the necessary clarifications. Therefore, theperson shall promptly provide consent to the processing of personal data through adeclaration or explicit confirmation actions.
2.2.3 A request from the Company for an agreement from the data subject should beprovided clearly and understandably for everyone using a simple literate language.
2.2.4 The client’s concern should be expressed in a structured way in order to process thecategories of personal data by the Company.
2.2.5 The person has the right to refuse to provide personal data at any time. Following therefusal, the Company shall stop collecting and processing any personal data, provided thatthe Company is not obliged or entitled to do it legally.
2.3 Fulfilment of contract terms;
2.3.1 Collection and processing of personal data to execute the contract terms by the party,which is the data subject, or to perform actions on request of the data subject prior to thesigning of the contract are legal. This statement applies to all contractual obligations andagreements signed by FXspace Worldwide Fin Services LTD, including the pre-contract,regardless of the outcome of negotiations to sign the contract.
2.4 Fulfillment of legal obligations by the Company and the Client.
2.4.1 The obligations of FXspace Worldwide Fin Services LTD include the implementation ofvarious legal obligations, which are based on the requirements and legislation of theEuropean Union or its member countries. Similar legal circumstances that are relevant to theCompany, may be a legal basis for processing the client’s personal data.
2.4.2 Legal agreements include the obligation of collecting, recording and (or) provision ofcertain types of information about employees, clients, etc. Similar legal requirements are thelegal basis for the processing of personal data. Please note that all provisions whichprovided FXspace Worldwide Fin Services LTD for processing specific personal data, alsoestablish requirements for storage, disclosure and deletion of personal data.
2.5 The company interests.
2.5.1 All the data will be processed in the case of the legitimate interests pursued FXspaceWorldwide Fin Services LTD, such interests or fundamental rights have a pre-emptive legalaction concerning the rights of the data subject. During decision-making concerning theprocessing of data, the Company will first make sure that the legal interests have a preemptive legal action with the rights and freedoms of individuals and that the treatment willnot cause unlawful damage.
3. The principle of processing and transmission of personal data.
3.1 FXspace Worldwide Fin Services LTD is the main controller of personal data processing
3.1.1 When the data subject signs agreement with Worldwide FXspace Fin Services LTD,the Company begins to be considered a controlling organisation is processing personal data in full. Such provisions allow the Company to take certain decisions on how are processingpersonal data of the person.
3.2 Cooperation with the data processors companies
3.2.1 External data processors are those companies that are processing personal data onbehalf of FXspace Worldwide Fin Services LTD and under the instructions of FXspaceWorldwide Fin Services LTD. For example, the control of the Company over the accountingsystems staff, third-party suppliers of information technologies, etc. If the Company for theprocessing of personal data has attracted the companies-handlers FXspace Worldwide FinServices LTD requires that such companies ensure the same high level of confidentiality asFXspace Worldwide Fin Services LTD provided. If this condition is not guaranteed, theCompany is obliged to select a different data processor.
3.3 Consent to the processing of data
3.3.1 Before transferring personal data FXspace Worldwide Fin Services LTD is obliged toconclude a written data processing agreement with the processor. The agreement allows thecontrol of the FXspace Worldwide Fin Services LTD concerning the processing of personaldata carried out outside the Company and for which the Company is responsible.
3.3.2 If the handler or cobramatic data geographically located outside the EU/EEA theconditions of paragraph 3.4.4 below will be used.
3.4 Regulations on the disclosure of personal data.
3.4.1 Before disclosing personal information to trusted individuals, FXspace Worldwide FinServices LTD verifies whether the recipient is bound cooperation agreements. Please notethat the company has the right to bring personal information within the system FXspaceWorldwide Fin Services LTD provided that the disclosure is justified by a legitimate businesspurpose.
3.4.2 FXspace Worldwide Fin Services LTD is obliged to ensure the recipient has alegitimate purpose for obtaining personal data and to require the transfer of personal data islimited and kept to the minimum necessary.
3.4.3 The Company must consider all risks associated with the transfer of personal data toindividuals, data subjects or entities outside the structure of FXspace Worldwide FinServices LTD. If there is a legal purpose of data transmission, transmission data is allowedto disclose to third parties, who act as private regulatory organizations that process personaldata.
3.4.4 In the situation when the recipient is outside the EU/EEA in a country which does notprovide a suitable level of data protection, the transmission of information is permitted onlysubject to the conclusion of the agreement on the transfer of data between FXspaceWorldwide Fin Services LTD and the third-party. Please note that the agreement on thetransfer of data shall be based on the Standard contractual clauses of the EU.
4. Rights of data subjects.
4.1 Obligations concerning the information.
4.1.1 When FXspace Worldwide Fin Services LTD collects and records personal data, theCompany is obliged to inform such persons of :
- the purposes of the processing for which the personal data are intended, as well asthe legal basis for the processing;
- the affected categories of personal data;
- legitimate interests pursued by FXspace Worldwide Fin Services LTD, if theprocessing is based on the balance of interests;
- about the recipients or categories of recipients of personal data if any exists;
- if applicable, when FXspace Worldwide Fin Services LTD intends to transfer personaldata to a third country and about the legal grounds for such transfer;
- the period during which personal data will be stored, or if it is not possible, thecriterion used to determine this period;
- the right to request from FXspace Worldwide Fin Services LTD access personal dataor correction or deletion thereof, to limit processing in respect of the data subject orto contest treatment and the right to data transfer;
- in cases where the processing is based on the consent of the data subject about theright to withdraw consent at any time, without affecting the lawfulness of processingbased on consent before withdrawal thereof;
- the right to complain to the FXspace Worldwide Fin Services LTD through the properprocedure or the Supervisory body;
- whether providing personal data is a statutory or contractual requirement orrequirement of the contract, and whether the data subject obliged to provide personaldata and about the possible consequences of refusal to provide such;
- the presence of automatic decision-making process, including profiling, and toprovide meaningful information about the logic used, as well as the importance andpossible consequences of such processing for the data subject.
4.2 Access Control
4.2.1 FXspace Worldwide Fin Services LTD processes personal data of any person,including employees, staff, outside vendors, potential clients, business partners and otherswho have the right to request access to their personal data, which processes and storesFXspace Worldwide Fin Services LTD.
4.2.2 Data subject has a right of access to personal data and right to know the reasons ofdata processing following the criteria, provided that FXspace Worldwide Fin Services LTDhas access to storage and processing of personal data of the subject.
4.3 FXspace Worldwide Fin Services LTD agrees to fix the exact personal data of thesubject on demand and without undue delay.
4.4 The data subject is entitled to demand from FXspace Worldwide Fin Services LTD fullremoval of personal data. In turn, the Company undertakes to delete the personal datawithout undue delay, if not obliged to keep any information within a specified period of timeaccording to legal requirements (meaning requirements of the financial supervision or taxauthorities).
4.5 If the request applies, the data subject has the right to demand from FXspace WorldwideFin Services LTD to limit the processing of personal data.
4.6 Subject has the right to obtain a registered personal data that will be executed in the slotmachine format and presented in a common and structured way.
4.7 Considering the specific personal situation, the data subject has the right at any time toappeal against the processing of personal data in respect of such entity, if the processing isbased on the balance of interests, including profiling.
4.8 Any requests that are received by the Company from data subjects concerning theimplementation of the rights described in this paragraph, the Company shall respondpromptly, but no later than 30 days from the date of receipt of the request. The appeal will beimmediately forwarded to the Service Center FXspace Worldwide Fin Services LTD.Specialist Company which is responsible for the protection of data of a specific subject is obliged to assist the Service Centre in processing the request for the observance of thedeadline for response.
5. Undertaken methods to protect your data.
5.1 The Company undertakes to develop new products, services, technical solutions, etc sothat they were safe to use and compatible with the principles of the special data protectionand data protection by default.
5.1.1 Under special methods of data protection it is understood that during the developmentof new services or products, special attention should be paid to data protection.
- FXspace Worldwide Fin Services LTD on its part undertakes to adopt technical level,the implementation cost and the nature, scope, context and purposes of theprocessing, as well as risks of different probability and criticality concerning the rightsand freedoms of individuals, causing the procession;
- FXspace Worldwide Fin Services LTD undertakes at the time of the determination ofmethods of processing and during the actual processing to apply appropriatetechnical and organisational measures, such as the transformation in an anonymousform, which are intended to implement an efficient way of data protection principlessuch as data minimisation, and integration of the necessary precautions in theprocessing of data in order to comply with data protection and protection of the rightsof data subjects.
5.1.2 Protection of data privacy requires the implementation of innovative techniques of dataminimization by default.
- FXspace Worldwide Fin Services LTD is obliged to apply adequate technical andorganisational measures in order to process by default only such personal data thatis required for each specific purpose of processing.
- Such a minimisation requirement refers to the volume of collected personal data, thestage of processing, storage time and the availability thereof.
- Such measures urge to ensure that access to personal data by default is possibleonly after careful consideration.
6. The stages of the processing of personal data
6.1 FXspace Worldwide Fin Services LTD acts as the controlling entity processing personaldata. The duties of the Company is to maintain complete confidentiality during the recordingprocessing. The records should record the following information:
- the name and contact details;
- the purpose of the processing;
- description of categories of data subjects and the categories of personal data;
- recipients who have been or would be disclosed personal data, including recipients inthird countries or international organisations;
- if applicable, information about the transmission of personal data to third countries,including an indication of the third country, and if it applies to this case, the data inthe appropriate precautions;
- if applicable, the envisaged time limits for the deletion of different categories of data;
- if applicable, general description of the used technical and organisational securitymeasures.
6.1.1 The obligations FXspace Worldwide Fin Services LTD includes the provision of datarecords on request of the relevant authorities in the field of data protection.
7. Liquidation of personal data.
7.1 FXspace Worldwide Fin Services LTD undertakes to eliminate personal data, providedthat a legitimate aim will disappear and continue processing or storage of personal data isnot provided at the legislative level.
7.2 The preservation policy and data sharing FXspace Worldwide Fin Services LTD provideda detailed description of the retention periods in respect of different categories of personaldata.
7.3 Upon completion of the cooperation with FXspace Worldwide Fin Services LTD, clientsor potential clients of the Company have the right to require complete removal andanonymization of personal data from their account in FXspace Worldwide Fin Services LTD.
7.4 Before cooperation FXspace Worldwide Fin Services LTD will conduct analysis andevaluation of the data protection rights of their clients (potential clients) with therequirements of other relevant regulations. Please note that when you register your personaldata in systems FXspace Worldwide Fin Services LTD, any action regulated by legal acts onfinancial transactions, accounting standards, standards to protect clients, etc.
7.5 FXspace Worldwide Fin Services LTD warns that personal data will be deleted if theircontinued storage is not necessarily legal grounds. The standard term for removal of clientinformation is the current year plus five years after the end of the relationship with the client. 7.6 System FXspace Worldwide Fin Services LTD provides that personal data of potentialclients will be deleted or anonymised on their request within a short time, however, theprocedure can take up to one month.
7.7 The Data of those clients who have caused the losses of the Company, can be stored fora longer time in order to protect FXspace Worldwide Fin Services LTD from further losses orto meet legitimate financial requirements.
7.8 Above indicates that at the end of any period of cooperation with the Company, FXspaceWorldwide Fin Services LTD permanently deletes or anonymizes all personal data.
8. Possible risks.
8.1 If the processing of personal data by FXspace Worldwide Fin Services LTD exposes ahigh level of risk to those individuals whose personal data are processed, should assess theimpact on privacy (DPIA).
8.1.1 The assessment of impacts on privacy suggests that FXspace Worldwide Fin ServicesLTD considers the scope, context, character, purpose of the procession, risks of varyingdegrees of probability and criticality in relation to the rights and freedoms of natural persons,and will apply appropriate technical and organisational measures for carrying out processingaccording to the requirements of data protection and will be able to demonstrate such.
8.2 Technical and organizational measures of FXspace Worldwide Fin Services LTD shouldbe reviewed and updated not less than once in six months.
8.2.1 As part of a demonstration of compliance with the relevant technical and organizationalmeasures necessary to comply with the rules of conduct or with an approved certificationschemes both legal parties.
- to assess creditworthiness;
- to provide clients and potential clients information about the products FXspaceWorldwide Fin Services LTD and the services that may be of interest to them;
- to assist in identifying potential cases of financial crime.
10. International requirements
10.1 On its part FXspace Worldwide Fin Services LTD undertakes to respect the Generalrules on data protection and the data protection laws at the level of individual countries.
10.2 If the national law of a particular country requires a higher level of protection forpersonal data than FXspace Worldwide Fin Services LTD can provide, the Companyundertakes to comply with these requirements. If the policy or recommendations of FXspaceWorldwide Fin Services LTD more stringent than local legislation, it is necessary to complywith the policy or recommendations of the Company.
11. Contact details.
11.1 If the client or potential client has any questions regarding the content of this policy, he/she should contact a specialist FXspace Worldwide Fin Services LTD, which is responsiblefor protecting data at [email protected].