NOVATTI TRADING FX PTY LTD PRIVACY POLICY – UK/EU

1. WE RESPECT YOUR PRIVACY

• Novatti Trading FX Pty Ltd (ACN 645 493 161) (“Novatti”, “we”, “us”) respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. In this policy we explain how we will handle your personal data. “Personal Data” is information we hold which is identifiable as being about you. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. Our website incorporates privacy controls which affect how we will process your Personal Data, such as cookie management.

2. COLLECTION OF PERSONAL DATA

• We will, from time to time, receive and store Personal Data you enter onto our website, provide to us directly, or give to us in other forms.
• We may collect additional information at other times, including but not limited to when you provide feedback, when you provide information about your personal business affairs, change your content or email preferences, respond to surveys/or promotions, provide financial or credit card information, or communicate with our customer support team.
• Types of Information
  Identification Information: We may ask you to provide basic information such as your name, date of birth, title, gender, phone number, address, email address, occupation and job title, nationality, and tax identification number to enable us to send information, provide updates and process your product or service order. We may also collect identity documents such as government issued ID, health care cards, passports, drivers licence. We need these documents to verify your identity. The legal basis for this processing is the proper administration of our website and business according to applicable legislation.
  
  Account Information: We may process information about your account. The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our products and services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the proper administration of our website and business according to applicable legislation.

  Financial Information: In order to process payments booked by you and to comply with regulations, we may collect financial information such as bank account details, credit or debit card numbers. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

  Transaction Information: In order to process a transaction, we also need to collect information about the parties to the transaction, the source of funds, the reason for the transaction and the devices and payment methods used to complete the transaction. You will need to provide information about the recipient of the funds, including, the recipient’s name, mailing address, email address and bank account information. When you provide us with third party information, you are confirming you have obtained their approval to provide us with their information. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

  Business Information: We may also collect information about the business entities you are using our services on behalf of. We may ask for information about organisational structures, individuals involved with the company and corporate records as well as Personal Data about the beneficial owners. You agree that you have obtained the beneficial owners approval or are otherwise allowed to provide us with their information, and they are aware of the contents of this privacy policy.

  Background Information: We may also, from time to time, obtain background checks (such as police checks) and credit checks.

  Usage Data: We may process data about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring the use of our products and services and ensuring we comply with our legal obligations.

  Enquiry Information: We may process information contained in any enquiry you submit to us regarding products and/or services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is that we will always ask for your consent before processing your enquiry data for the aforementioned purposes.

  Statistical Information: We may collect information about your online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes.

  Notification Information: We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. The notification information may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your permission and additionally, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

  Information you send us: We may collect any personal correspondence that you send us, or that is sent to us by other users of the website about your activities.

  Aggregated/Anonymized Data: We may also collect or create data that is no longer considered Personal Data for business purposes. Such as to analyse industry and market analysis, demographic profiling, marketing and advertising.

  Correspondence Information: We may process information contained in or relating to any communication that you send to us. The correspondence information may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

  In addition to the specific purposes for which we may process your Personal Data set out in this section, we may also process any of your Personal Data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3. HOW WE COLLECT YOUR PERSONAL DATA

• We collect Personal Data from you in a variety of ways, including when you provide information during the course of completing application forms or using our services, when you interact with us electronically or in person, when you access our website or other platform. We may also receive Personal Data from third parties. If we do, we will protect it as set out in this Privacy Policy.

4. USE OF YOUR PERSONAL DATA

• We may use Personal Data collected from you for various reasons, including to;

• • provide or improve our services.
  • comply with legal obligations.
  • verify your identity and to authenticate your right to access an account or other information.
  • monitor our system for fraud, money laundering or other crimes.
  • provide you with information and updates.
  • respond to your inquiries.
  • make you aware of new and additional products, services, and opportunities available to you.
  • monitor and analyse trends, usage and preferences.
  • evaluate your use of our services.
  • provide customer support

We may also use your Personal Data for other reasons, which will be disclosed at the time we collect the Personal Data.

• We may contact you in a number of ways, including but not limited to via telephone, email, sms or mail.

5. DISCLOSURE OF YOUR PERSONAL DATA

• We may disclose your Personal Data to any of our employees, officers, related companies, insurers, professional advisers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal Data is only supplied to a third party when it is required for the delivery of our services.
• We may from time to time need to disclose Personal Data to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
• We may also use your Personal Data to protect the trademarks, legal rights, property or safety of Novatti, www.novattixb.com, our customers or third parties.
• Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside the European Economic Area (EEA). We and our other group companies have offices and facilities in England, Australia, South Africa, Cyprus, and new locations are imminent. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
• Countries that we are likely to transfer information to include the United States of America, United Kingdom, New Zealand, Singapore, countries in the European Union and countries in Asia. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
• You acknowledge that Personal Data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such Personal Data by others.
• By providing us with Personal Data, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your Personal Data to third parties, we will request that the third party follow this Policy regarding handling your Personal Data.

6. RETAINING AND DELETING PERSONAL DATA

• This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of Personal Data.
• Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
• We will retain and delete your Personal Data as follows:
  (a) Personal Data will be retained for 5 years following the date of collection, at the end of which period it will be deleted from our systems.
• In some cases it is not possible for us to specify in advance the periods for which your Personal Data will be retained. In such cases, we will determine the period of retention based on the following criteria:
  (a) the period of retention of Personal Data will be determined based on our legal obligations. Novatti will only store information that is requested from us by law for a period of 5 years. The rest of the data held/stored by us will be deleted after the data has been processed in accordance with the General Data Protection Regulation.
• Notwithstanding the other provisions of this Section, we may retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. YOUR RIGHTS

• In this Section, we have summarised the rights that you have under the General Data Protection Regulation. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
• Your principal rights under data protection law are:
  (a) the right to access;
  (b) the right to rectification;
  (c) the right to erasure;
  (d) the right to restrict processing;
  (e) the right to object to processing;
  (f) the right to data portability;
  (g) the right to complain to a supervisory authority; and
  (h) the right to withdraw consent.
• You have the right to confirmation as to whether or not we process your Personal Data and, where we do, access to the Personal Data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Data concerned and the recipients of the Personal Data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your Personal Data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
• You have the right to have any inaccurate Personal Data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed.
• In some circumstances you have the right to the erasure of your Personal Data without undue delay. Those circumstances include:
  (a) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  (b) you withdraw consent to consent-based processing; and
  (c) the processing is for direct marketing purposes; and the Personal Data have been unlawfully processed.
• However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary:
  (a) for exercising the right of freedom of expression and information;
  (b) for compliance with a legal obligation; or
  (c) for the establishment, exercise or defence of legal claims.
• In some circumstances you have the right to restrict the processing of your Personal Data. Those circumstances are:
  (a) you contest the accuracy of the Personal Data;
  (b) processing is unlawful but you oppose erasure;
  (c) we no longer need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise or defence of legal claims; and
  (d) you have objected to processing, pending the verification of that objection.
• Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only otherwise process it:
  (a) with your consent;
  (b) for the establishment, exercise or defence of legal claims;
  (c) for the protection of the rights of another natural or legal person; or
  (d) for reasons of important public interest.
• You have the right to object to our processing of your Personal Data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
  (a) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or
  (b) the purposes of the legitimate interests pursued by us or by a third party.
• If you make such an objection, we will cease to process the Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
• You have the right to object to our processing of your Personal Data for direct marketing purposes including profiling for direct marketing purposes. If you make such an objection, we will cease to process your Personal Data for this purpose.
• You have the right to object to our processing of your Personal Data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
• To the extent that the legal basis for our processing of your Personal Data is consent, and such processing is carried out by automated means, you have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
• If you consider that our processing of your Personal Data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
• To the extent that the legal basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
• You may exercise any of your rights in relation to your Personal Data by written notice to us.

8. SECURITY OF YOUR PERSONAL DATA

• Novatti is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
• The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that Personal Data that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

9. COMPLAINTS

• If you have any complaints about our privacy practices, you can contact us using the details listed in section 12.

10. WEBSITE

• When you visit our website
  When you come to our website (www.novattixb.com) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
• Third Party Sites
  Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval.

11. COOKIES

• A cookie is a file containing an identifier, a string of letters and numbers that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but Personal Data that we store about you may be linked to the information stored in and obtained from cookies.

• Cookies that we use

  We use cookies for the following purposes:

  Authentication: We may use cookies to identify you when you visit our website and as you navigate our website;

  Status: We may use cookies to help us to determine if you are logged into our website

  Personalisation: We may use cookies to store information about your preferences and to personalise the website for you;

  Security: We may use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

  Analysis: We may use cookies to help us to analyse the use and performance of our website, products and services; and

  Cookie consent: We may use cookies to store your preferences in relation to the use of cookies more generally.

  In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit.

• Cookies used by our service providers
  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
• Google Analytics
  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/
• Managing cookies
  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
  (a) Chrome;
  (b) Firefox;
  (c) Opera;
  (d) Internet Explorer;
  (e) Safari; and
  (f) Edge.

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features on our website or our services.

12. CONTACT US

• If you have any questions or concerns about this policy, if you need to receive it in an alternative format, or if you have a specific request related to your Personal Data, you can contact our Data Protection Officer at:
  Attention: Data Protection Officer
  Mail: P.O. Box 171 380 Bourke Street Melbourne, VIC, AUSTRALIA, 3001
  Email: [email protected]
  Phone: +61 03 9013 0066

13. CHANGES TO PRIVACY POLICY

• We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.
• This Privacy Policy was updated on 20 July 2021.