Personvernerklæring

Privacy Policy

This policy is the property of Skilling. The reproduction in whole or in part in any way including the reproduction in summary form, the reissue in a different manner and any changes in the original manual or any translated version is strictly forbidden and is only allowed with the prior written consent of Skilling.

Skilling (Seychelles) Limited, and its related entities (hereafter the "Company”, "we,'' "our"), is responsible as ‘controller’ for the protection of privacy and the safeguarding of clients’ personal and financial information pursuant the General Data Protection Regulation (“GDPR”). By opening a trading account with us, the client (hereinafter referred to as the “ Client”, you``, '' your'') hereby gives its consent to such collection, processing, storage and use of personal information by the Company as explained below. 

Scope

The purpose of this Privacy Policy (“Policy”) is intended to inform you how we collect, use, record and disclose your personal information and/or data. You are encouraged to carefully read and use this Policy to make informed decisions.  The terms used in this Privacy policy have the same meanings as our General terms and conditions, which is available to all our clients through our Website. By using our website and services you agree to the terms of this Policy and continued use of your information and data within the scope  of this Policy. 

We comply with both the General Data Protection Regulation and national data protection legislation. For higher levels of data protection, we  are obliged to implement the stricter requirements of the two laws. 

 

  •   Your consent to our use of the collected personal use

 

1.1.  Upon your registration as a client with us for a trading account or submission of other registration forms (including corporate entity account or elective professional client request) or subscribing to our services or marketing material, (“Personal data”) information about you is collected, recorded and stored for legal and regulatory purposes. 

1.2. You have the right to opt-out or decline consent to use your data simply by contacting us whether by telephone or email and request that no further contact  be made,  subject to the conditions described in the below point 2. Moreover, your refusal to provide us with correct and  accurate information,  we may not be able to perform our contractual duties. In this case, we may have to cancel such a service agreement. Please do keep us informed if your data changes during your relationship with us. 

 

  •   Your right to privacy

 

2.1. Under the General Data Protection Regulation, each individual client’s right to privacy and value our business relationship are . In summary, these rights include:

2.1.1.  You have the rights (a) to access personal data which is recorded by us (b) to request correction of inaccurate data that is held with us (including mistakes in your data held with us); (c) under certain case request personal data erased, (d) to object to receiving direct marketing and (e) to move personal data from one service to another (data portability) as required by law; (f) to refuse to give consent or withdraw consent or opt-out or object to the use of your personal data  at any time; (g) to object to in certain situation to our continued process of your personal data.   Otherwise, restrict the processing of your personal data in certain circumstances.  

2.1.2.  Without derogating from the above, you have the right to request the erasure of your personal data without undue delay under certain circumstances. Those circumstances include: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing under certain rules of applicable data protection law; (iv) the processing is for direct marketing purposes; and (v) the personal data have been unlawfully processed. There are general exclusions that may include where processing is necessary to comply with our legal obligation; or to the establish, exercise or defend legal claims, as permissible by law.

2.1.3.  You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. But, this right does not apply where it would adversely affect the rights and freedoms of others. 

2.1.4.  As a client registered with us, 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: If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, or to exercise or defend legal claims, as permissible by law.

2.1.5.  In the event that you submit a written request for a copy of the personal data that we hold, we may charge a reasonable fee to comply with the request when it is excessive, repetitive or unconfirmed data.

2.1.6.  You may exercise any of your rights in relation to your personal data by submitting a written notice to us.

 

  • Types of personal data we collect

 

3.1.  We collect the necessary information and/or data required to open a client’s trading account, perform transactions and safeguard the clients’ assets and privacy, and to provide clients with the services they require. The information that we collect includes information required to communicate with and identify its clients. We may collect certain personal information and/or demographic data including but not limited to:

Type of personal data

Purposes

(a) Personal information such as name, residential address, nationality, birth date, contact number, email

To complete our registration process and onboard you as a client; and to secure authentication and verify the client’s identity;

(b) Profile information such as Client’s Skilling account details and username, transactions made by you, your interests, preferences, feedback and/or information received through your interaction with us within the course of providing our services and/or survey responses

To produce data, reports and statistics but not limited to the clients’ related to trading activities which have been anonymized or aggregated in a manner that does not identify the client as an individual;

(c) Economic information such as estimated annual income, net worth, source of funds and amount expected to invest  

Conformity information such as employment status, investment knowledge and investment trading experience

To comply with Know Your Client’, ‘Customer Due Diligence’ as well as regulatory obligation related to assessing the appropriateness of our services and products

(d) Banking information such as details of number of payment wallets and/or information of your bank card, including information of the issuing bank, card number, cardholder name, card expiration date, payment system, Card validation code (CVV2) and/or card e-statement

To monitor transactions for the purposes of preventing Money Laundering, fraud, irregular and suspicious account activities, and detection of related risks

(e) Technical information such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, and other technologies on the devices you use to access our Website and use of cookies stored on your device

To set-up your profile and effective  monitor as well as detect any security information breaches 

(f) Transaction information such as details about the transactions performed by you, details about payments, withdrawals, exchanges, trading history, profit, balance, deposited and withdrawal amount methods, and any other details in relation to the services you have made use of through our Website

To comply with Anti-money laundering monitoring and reporting obligations

(g) KYC (“Know Your Client”) or Identity documents or data such as passport, ID card, utility bill, bank statement, Social insurance number or/ Tax identification number (incorporation documents for legal entity)

Sensitive data such as biometric data, and/or criminal convictions and offenses either made available to us by third parties or by yourself

BankID data such as e-ID information on personal ID number, name, user ID and login code 

To comply with Anti-money laundering laws, legislation and regulatory obligation in relation to ‘Know Your Client’ and ‘Customer Due Diligence’ requirements when verifying your identity

(h) Audio and electronic data such as full voice recordings of telephone calls, emails, chat-history or other communications with us 

To comply with our regulatory obligations (GDPR); and to administer, manage and protect our business and website (including data analysis, system maintenance, reporting, hosting of data or troubleshooting).

(i) Data collected in the abovementioned points (a)-(h)

To perform our contract with you and safeguard our legitimate interests as well as comply with the Markets in Financial Instruments Directive II (“MIFID II”) and the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007-2019, inter alia, to conduct the assessment of suitability, appropriateness test, and prevent fraud and money laundering acts (respectively) 

3.2.  We process your data in accordance with the principles of lawfulness, fairness, transparency, and always adhering to the intended purpose of data processing, the principle of data minimization, accuracy, limited data storage, data integrity, confidentiality and accountability. 

3.4.  In this respect, we gather information directly from the clients and may, in certain circumstances, gather information indirectly from the banks and/or credit agencies, and/or clearing agencies and/or other sources which will help us to construct the clients’ profile based on their requirements and preferences in order to provide its services effectively. 

 

  •   How we collect your personal data

 

4.1.  Direct Interactions. You will provide to us your Identity, Contact and Financial Data online through the Website and/or by filling in online forms and/or by corresponding with us by email or otherwise. Data may be submitted to us by you when you wish to: (a) Register for a Trading Account; (b) Register for a Demo Account; (c) 

Subscribe to our publications and ongoing updates; (d) Request marketing and promotions to be sent to you; and (e) Give us feedback or contact us. 

4.2.  Use of automated technologies or interactions. When using our services, your device automatically transmits to us its technical characteristics. Locale (a set of parameters that determine regional settings of your interface, namely, residence country, time zone and the interface language) is used for the purpose of providing you with the best possible service within our platform. 

4.3.  Use of our web services. We derive data from IP address, cookies files, browser data  or operating system used, the date and time of access to the site, and the requested pages addresses allows us to provide you with the optimal operation on our web application, mobile app and/or desktop versions of our application and monitor your behaviour for the purpose of improving the efficiency and usability of our services.

 

  • Use of personal data

 

5.1.  We use the clients’ personal information and/or data only as required to provide quality service and security to our clients.  Such information helps us  in the following ways

  • to to diagnose or fix technical problems;
  • to communicate with you and provide you with support services;
  • to produce data, reports and statistics but not limited to the clients’ related to trading activities which have been anonymized or aggregated in a manner that does not identify the client as an individual;
  • to monitor transactions for the purposes of preventing Money Laundering, fraud, irregular and suspicious account activities, and detection of related risks;
  • to investigate violations and enforce our policies, and as required by applicable Laws, Regulations or the competent government authority;
  • to notify clients about the benefits and changes to the features of products and/or services;

5.2.  Moreover, we may disclose your personal data to the competent authorities, banks, or credit providers, repository agencies, clearing agencies, service providers and/or specialist advisers under a contract for IT, financial, regulatory or other services which will help us provide our services effectively in accordance with applicable laws and regulations.

 

  •   Retention of your personal data 

 

6.1.  We shall retain your personal information or data only for as long as it is necessary to fulfil the purpose for which you have provided it to us or to comply with the Ant-money laundry regulatory or our regulatory obligations according to applicable laws and regulation for the protection of personal data.

6.2.  If and when you or we choose to end the business relationship, we are required to keep your personal data on records for a further five (5) years pursuant to the applicable laws, and  where it is required of us to do so in relation to the fulfilment of our services or to discharge our regulatory obligations.

6.3.  If, for any reason, you do not want to receive information of this nature, you may contact support@skilling.com.

 

  •    Protection of personal data

 

7.1.  Any personal information provided to us by a client will be treated as confidential and shared only within the Company and its affiliates and will not be disclosed to any third party except under any regulatory obligation or legal proceedings. Any disclosure that is required to be made by law or any competent (supervisory) authority, it will be made on a ‘need-to-know’ basis, unless otherwise instructed by the competent authority. Under such circumstances, we shall expressly inform the third party regarding the confidential nature of the information.

 

  •   Data transfers outside of the European Economic Area/ European Union

 

8.1.  We may transfer the client’s personal information and/or data outside the EU/EEA subject to the below conditions, and ensuring appropriate and suitable safeguards based on (a) the Standard Contractual Clauses (“SCC”) as adopted by the European Commission; or (b) the EU has designated a country as providing an adequate level of data protection; (c) through approved model contracts or binding corporate rules; (d) implementing Binding Corporate Rules for Processors or (e) by complying with an approved certification mechanism, e.g. EU-US Privacy Shield  (if applicable), as permissible under the limited additional provisions of the GDPR. 

8.2.  Some of our third-party providers (processors) may be based outside the European Economic Area (EEA) or European Union (EU); if it is located outside EEA/EU in a jurisdiction without adequate level of data protection, the transfer can only be completed if a transfer agreement based the EU Standard Contractual Clauses (including clauses on safeguard data). 

 

  •   Confidentiality 

 

9.1.  Your data is stored and kept confidential for the purposes defined herein this Policy according to the legislation on protection of person data and processing thereof applicable in the jurisdiction in which Skilling with which you have registered an account is located.

9.2.  All entities under Skilling Group and any third-parties processing data on our behalf do so by taking into account personal data protection measures according to the provisions of the GDPR, the Personal Data Protection Law, as amended from time to time as well as other regulations (respectively). These affiliated-third-parties are not to use your personal data for their own purposes and only permit them to process your data for specific purposes and in accordance with our instructions. 

Skilling Group of companies:

Fore more information, please visit the  ‘About us’ page on our website.

Third-party service providers:

Trustly Group, Wirecard AG, Sofort GmbH, Neteller, Skrill, BankID, Trusty, Swish, AppsFlyers and other providers with whom we have contractual agreements.

 

  •   Disclosure of your personal data

 

10.1.   We may share information with affiliates in the event such information is reasonably required by such affiliate in order to provide the products or services to its clients. Moreover, we may share information with partners, affiliates and associates in order to offer additional similar products and services that meet clients’ needs and which are delivered in a manner that is useful and relevant only where clients have authorised the Company to do so. We also 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. 

10.2.   If a client has been introduced to us by a business introducer, such business introducer may have access to clients’ information. Hence, you hereby unequivocally consent to the sharing of information with such business introducer. 

 

  •  Third-party content on our website

 

11.1.  We may provide links to third-party websites in our website, and such websites are not under our control. We cannot accept responsibility for the conduct of third-parties linked to our website, including without limitation to the collection or disclosure of your data. Before disclosing your data on any other website, we encourage you to examine the terms and conditions of using that website and its privacy policies.

11.2.  In addition to the purposes mentioned above, the Company may share and use your personal information and/or data with third parties or/ affiliates for the purpose of providing you with promotional materials, related to our services as well as products, websites and applications, which may interest you.

11.3.  You are entitled to withdraw your consent, opt-out or/ unsubscribe from receiving any marketing communication from us or our affiliated-third-parties by clicking on ‘unsubscribe’ bottom.  

11.4.   We are not responsible for the privacy policies or the content of sites to which our Website links to and has no control over 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 website or to a linked website, the client may be asked to provide registration or other personal information. Please note that such information is recorded by a third party and will be governed by the privacy policy of that third party.

 

  •   Security

 

12.1.  We value your trust in providing us with your personal information and/or data, thus we endeavor to collect and use lawful means of protecting the clients’ personal information and/or data.

12.2.   You acknowledge that the transmission of information via the internet is not completely secure and that we shall not guarantee the non-existence of viruses, cyber-security-threats and we shall not be held responsible in case of damage caused to your software device.

12.3.  We use encryption to provide a high level of security and privacy for your data. When you enter your data onto our website or mobile application or online trading platform, we use strong encryption technologies to protect your data during transmission from your devices to our servers. 

12.5.  We  shall notify you of any data breach which is likely to result in a risk for the rights of the client within 72 hours of first having become aware of the breach (without undue delay), as required by the applicable Laws and Regulations. 

 

  •   Use of "Cookies"

 

13.1.  We use cookies to secure clients’ trading activities and to enhance the performance of the website. When you visit our website, our system automatically collects information about your visit, such as your technical data, including inter alia to, your browser type, your IP address and the referring website.  You can read more about our cookie policy which is available through our Website. 

 

  • Mobile application

 

14.1.  We may collect data from the client’s mobile device through a third party softwares that uses advanced encryption mechanisms. Such information or data includes the brand, type and hardware token of the mobile device transferred to us during registration of the device in the application and it is used for explicit identification of the applicant and/or application and the mobile device.

 

  •  Modification of your personal data

 

15.1.  You may submit a request to modify, correct or/ update your information and/or data which is held under our records, but not limited to residential address and passport number. You agree to provide us with the updated and/or supporting documentation to enable us to update our records and hold accurate information or/ data as required by applicable laws of the competent authority.

 

  •  Minors

 

16.1.  Our services are not available to people aged under the age of 18 or who have not attained the legal age (“Minors”). We disclaim any liability for unauthorized use by minors of our online services, trading platform in any manner or another.

 

  •   How to resolve a complaint

 

17.1.  Your possible privacy concerns are important to us. We are committed to resolving any complaint and to attending to answering any general questions about our services or/ information that we collect and how it is used by us. All privacy-related complaints and general questions may be communicated to us by emailing to support@skilling.com.

17.2.  If you are not satisfied with our response to your complaint, you have the right to file a complaint with our supervisory authority, the Cyprus Data Protection Commissioner or if you are a client of any of the remaining Skilling Group entities.   You also have the right to file a complaint with the data protection authority of your country of residence (if applicable). 

 

  •   Changes to this policy 

 

18.1.  We reserve the right to review and/or amend this Policy at its sole discretion, whenever it deems fit or appropriate by law, and the revised Policy will be uploaded on our Website. Your continued use of our services, following any notification of such amendments, constitutes your acknowledgement and consent to such amendments to this Policy and your agreement to be bound by the terms of such amendments.

18.2.  This privacy policy was last updated and published in April 2020.

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