Skilling (Seychelles) Ltd - Integritetspolicy

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 Personal Data Protection Rules and Regulations. 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. 

The Policy also applies to personal information that we collect, use, manage, store or interact with our services through any correspondence made with us by phone, email or otherwise. The Policy aims to inform you about the type of information we gather, who we share it with, what we use it for, how we manage and store it and what your data privacy rights are. We have opted to apply both the Personal Data Protection Rules and Regulations, we are obliged to implement the stricter requirements of the two laws.  

1. 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. If you refuse to provide us with correct and  accurate information,  we may not be able to perform our contractual duties and legal obligations. In this event, we may have to cancel our Client Agreement with you. Please do keep us informed if your data changes during your relationship with us. 

2. Your Right to Privacy

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

2.1.1. The Right to Information: You have the right to request disclosure of the personal information we hold about you.

2.1.2. The Right of Access:  You may request access to your  personal data that we collect, process and store, including how and why we process your personal data, and how long we intend to store your personal data as shown in this Policy.

2.1.3. The Right to Rectification: You may request that we rectify any inaccurate or update or complete incomplete personal information that changes from time to time. We will then correct our records, and notify any third parties to whom such personal information may have been transmitted.

2.1.4. The Right to Erasure: You may request that we erase your personal information, and we will comply provided your personal data is no longer necessary in relation to the purposes for which we collected or otherwise processed. 

2.1.5. The Right to Object or Restriction of Processing: You may request that we withdraw processing your personal information. Please be advised that such restrictions may affect certain services for which the processing of your personal information is essential.   

2.1.6. The Right to Data Portability: You have the right to move or transfer your personal information in structured format, using a secure method, and within a month of receiving the request. 

2.1.7. The Right to Opt-Out: You have the right to stop receiving marketing communication by clicking on the "unsubscribe" in the marketing emails that we send you or by changing your preferences, which are accessible via the trading platform under ‘notifications’. You agree that the following may apply:
(i) Once you exercise your right to opt-out, we will refrain from reaching out to you regarding any email alerts, promotions, weekly content, announcements, updates, festive greetings and/or invitations to events; 
(ii) Any amendments in our Terms & Conditions and/or any announcements that may have an impact on your account with us and/or any other substantial notification will still be communicated to you even if you unsubscribe.

2.1.8. The Right to Avoid Automated Decision-Making: We run automated decisions at account opening, to assess whether the offered products or services are appropriate for you based on the information you provide to us, and to understand the risk involved when trading our products.

2.1.9. You may exercise the rights by emailing dpo@skilling.com.

3. Types of Personal information we Collect

3.1.  We collect the necessary information required to open a client’s trading account, and to provide clients with the services they require. We may collect certain personal information 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 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 offences 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 Seychelles Securities (Dealers) Acts and the Prevention and Suppression of Money Laundering and Terrorist Financing Acts, inter alia, to conduct the assessment of suitability test, and prevent fraud and money laundering acts (respectively)

3.2.  We process and manage your information 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. 

4. How We Collect Your Personal Information

4.1.  Direct Interactions. You provide us with personal information through completion of the registration process, upload identity documents, carry out transactions, communicate through instant live-chat, telephone or email. 

4.2.  Use of automated technologies or interactions. When using our services, your device automatically transmits to us its technical characteristics. Locale implemented for smooth processing of your personal information to produce the best possible service while using our platforms. 

4.3.  Use of our web services. We retain 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.

5. Personal Information Use

5.1.  We may use your personal information to exercise the production of quality services.  We have obligations that entails we gather, use and manage your personal information for purposes including but not limited 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; and to disclose information under statutory obligations.

6. Retention of Your Personal Information

6.1.  We have the obligation to collect and store your personal information with accordance to the Ant-money laundry laws and regulation. This information is referred to as Know Your Client information which is performed through our customer due diligence process of identifying and verifying your personal identity, transactional, financial, and other data.

6.2. We intend to store your personal information in our records for seven (7) 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. 

7. Personal Information Used Outside European Economic Area/ European Union

7.1.  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. Some of our third-party providers (processors) may be based outside the European Economic Area (EEA) or European Union (EU); if a firm 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). 

8. Confidentiality 

8.1.  Your personal information is stored and kept confidential for the purposes defined herein this Policy according to the legislation on protection of your personal information and processing thereof applicable in the jurisdiction in which Skilling with which you have registered an account is located. These affiliated-third-parties are not to use your personal information for their own purposes and only permit them to process your information 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:	Payment service providers or processors such ABSA, Payretailers, Neteller, Skrill, or other providers such AppsFlyers, and others with who we have contractual agreements.

9. Disclosure of Your Personal Information

9.1.   We may disclose your personal information with our partnerships, affiliates, associated, authorised third-party provider or competent authorities under legal and contractual obligation. Any information shared with the above parties are authorised related to offered products and services to meet our clients’ needs. Where we involve authorised third-parties to perform outsourced functions, your personal information will be transferred and processed according to Data Protection Laws. 

9.2.   Where you’ve been  introduced to us through our affiliate program, such business introducers may receive limited access to your personal information. You hereby unequivocally consent and acknowledge that we may share your information with such business introducer. 

10. Third-party Content on Our Website

10.1.  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 personal information. Before disclosing your personal information on any other website, we encourage you to examine the terms and conditions of using that website and its privacy policies.

10.2. We may share and use your personal information with authorised third-party for the purpose of providing you with promotional materials, related to our services as well as products, websites and applications, which may interest you. You are entitled to withdraw your consent, unsubscribe from receiving any marketing communication from us or our affiliated-third-parties by clicking on ‘unsubscribe’ bottom.  

10.3.   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.

11. Security

11.1.  We value your trust in providing us with your personal information, thus we endeavor to collect and use lawful means of protecting your personal information. 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. We use encryption to provide a high level of security and privacy for your personal information. When you complete information through our website or mobile application, we use encryption for transmission of your information between your device to our systems. 

12. Use of "Cookies"

12.1.  We use cookies to secure clients’ trading activities and to enhance the performance of the website. You can read more about our Cookies Policy. 

13. Mobile Application

13.1.  We may gather, use and manage data from mobile devices through softwares that uses advanced encryption mechanisms. Such information 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 or application and the mobile device.

14. Notification of Breach

14.1.  We  have the obligation to  notify you of breach which poses risk to your personal information within 72 hours of first having become aware of the breach (without undue delay). 

15. Minors

15.1.  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.

16. How to Resolve a Complaint

16.1.  Your possible privacy concerns are important to us. We are committed to resolving any complaint and to attending to answering general questions about our services or personal information that we collect, store and how it is used. If you are not satisfied with our response to your complaint, you have the right to further submit a complaint with the Seychelles Office of Commissioner for Personal Data Protection or our Supervisory Authority. You may further submit a complaint with your Personal Data Protection Authority in your country of residence. 

You may exercise your right by submitting written complaints or general questions about your personal information by emailing to: dpo@skilling.com.

17. Changes to this policy 

17.1. This privacy policy was last updated and published in December 2020.