Page
1
of
3
Privacy
Policy
1.
INTRODUCTION
This
website is operated by
VIE
FINANCE SEY LTD, a company formed in Seychelles with registered office at
Room
B11, First Floor, Providence Complex, Providence, Mahe, Seychelles and regulated by the Seychelles
Financial
Services Authority as a regulated investment firm with license number
SD123 operating under the
brand
name Zenstox (www.zenstox.com)
(hereinafter referred to as “Zenstox",
“Company”,
“us”,
“we”
as
appropriate).
The
purpose of this Privacy Policy is to provide
information
on the collection, process and security of any data
transmitted
to and collected by us within the scope of the provision of our financial investment services
(the
“Services”),
as well as where any personal data is supplied to us through the website,
www.zenstox.com
(the
“Website”),
as
per our legal obligations under the applicable data protection law. We are committed to taking
all
reasonable steps in protecting any personal data we receive and collect from you, from misuse, loss
or
unauthorised
access.
2.
INFORMATION
COLLECTED
In
order for you to able to access either the Website and/or to our Services, we will collect and store
certain
personal
information
about
you
which
includes, but is not limited to, the following:
➢
Your
Name and Surname.
➢
Date
of birth.
➢
National
Identity
Card/Passport
➢
Nationality
and Gender.
➢
Bank
statements.
➢
Your
Contact details (postal address including
postal
code,
email
address(es),
phone
number(s),
fax number).
➢
Driver’s
License.
➢
Your
Tax Identification Number(s) (TIN(s)).
➢
Utility
Bills.
➢
Profession
and employment details.
➢
Your
signature (where applicable).
➢
IP
address and location data.
➢
Bank
account details.
➢
Transaction
history of the trading account you
opened
with us.
We
also record and monitor
communications
with you for our internal compliance requirements.
3.
USE
OF YOUR PERSONAL DATA
Most
commonly we will use your personal data to help us manage the services we provide
and
more specifically
to
(1)
provide
you with our Services (including but not
limited to enable account registration, administration and
operation),
(2)
to
communicate with you about any queries you submit or resolve any issues that may arise
through
the provision of our
Services,
(3) to comply with any legal or regulatory obligation,
(4) communicate
with
you and provide you with news and/or notifications such as sending alerts, emails, or SMS, for you to
view
on
the status of your trading account, e.g. verification of account or margin call or other information, (5)
improve
its
Website
and/or any other related software and/or tools related to the Services and your experience quality
when
using the Website and/or such related software and/or tools, by collecting relevant statistics.
We
may disclose your personal data to any of our
group companies, to any third party to whom we assign any
of
our rights or obligations; and/or to any government, regulatory agency, enforcement or exchange body
or
court
where we are required to do so by applicable law or regulation or at their request.
4.
SHARING
OF PERSONAL DATA
We
may share your personal data only with purpose of fulfilling our obligations towards you. The following
list
is
only indicative and non-exhaustive:
-
Service
providers engaged by us and which assist us to comply with our
contractual
and regulatory
obligations.
Page
2
of
3
- Third party apps providers when you use our apps and communication systems. Third parties which
provide us with the necessary infrastructure to enable us to provide our Services to you under the
Agreement entered into between us and you (e.g. providers of trading platform(s) and related software).
- Third parties with which we collaborate for electronic identity verification purposes.
- Credit institutions processing your transactions and payment service providers.
- External advisors providing advice, guidance and support on matters related to our business.
- Governmental bodies and regulatory authorities as required to comply with our legal obligations, as well
as where and when requested to respond to a specific request made by such bodies and authorities.
- Law enforcement agencies, courts and tribunals as required by law and/or as requested and/or as
provided in our Terms & Conditions.
- Any third parties as required to enforce or apply our Terms & Conditions or other agreements relevant to
the provision of our services to you.
- Anyone authorised by you.
Any share of personal data to the abovementioned recipients/categories of recipients will only be made to the
extent it is necessary to comply with our contractual obligations under the Agreement, the obligations imposed
on us by any applicable law and regulation and/or as required to perform their contractual obligations towards
us. The third parties we engage are not allowed to use or share your personal data for a purpose other than to
provide services to us.
5. SECURITY
Personal data is processed in a manner that ensures appropriate security and confidentiality, including
preventing unauthorised access to or use of personal data. We shall protect all data from loss, misuse,
unauthorised access or disclosure, alteration, or destruction. The Company shall not be liable for unlawful or
unauthorised use of any personal information due to misuse or misplacement of the passwords, negligent or
malicious use.
We maintain policies and procedures and have measures in place in order to ensure high levels of protection
of personal data which include, inter alia, appropriate restrictions on permissions of access to personal
information, controls and monitoring of storing and distribution of data.
All our employees and associates are required to follow our privacy and security policies and procedures. The
Company is not responsible for the security and privacy of any third party and/or social networking services or
any information collected by them.
6. HOW LONG WE KEEP YOUR PERSONAL DATA
We retain personal information for as long as we reasonably require it for legal or business purposes. In
determining data retention periods, we take into consideration local applicable laws and contractual obligations.
When information is no longer needed, we proceed with destruction procedures.
7. RIGHTS
Note that under data protection laws, in certain circumstances you have the below rights in relation to your
personal data:
Right to access your personal data
You may request from us to receive a copy of the personal data we hold about you and check that we are
lawfully processing it. The Company hereby reserves its right to charge a relevant fee for providing such record
of personal data to the person requesting this, except where this is not allowed under local legislation.
Right to correction of the personal data in our records
You may request us to correct any incomplete or inaccurate data we hold about you, though we may need to
verify the accuracy of the new data you provide to us.
Right to erasure of your personal data
You have the right to request that we erase or remove your personal data in certain circumstances. This applies
where there is no good reason for us continuing to process it, or where you have successfully exercised your
right to object to processing (as per below), or where you believe we may have processed your information
unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that
we may not always be able to comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
- Third party apps providers when you use our apps and communication systems. Third parties which
provide us with the necessary infrastructure to enable us to provide our Services to you under the
Agreement entered into between us and you (e.g. providers of trading platform(s) and related software).
- Third parties with which we collaborate for electronic identity verification purposes.
- Credit institutions processing your transactions and payment service providers.
- External advisors providing advice, guidance and support on matters related to our business.
- Governmental bodies and regulatory authorities as required to comply with our legal obligations, as well
as where and when requested to respond to a specific request made by such bodies and authorities.
- Law enforcement agencies, courts and tribunals as required by law and/or as requested and/or as
provided in our Terms & Conditions.
- Any third parties as required to enforce or apply our Terms & Conditions or other agreements relevant to
the provision of our services to you.
- Anyone authorised by you.
Any share of personal data to the abovementioned recipients/categories of recipients will only be made to the
extent it is necessary to comply with our contractual obligations under the Agreement, the obligations imposed
on us by any applicable law and regulation and/or as required to perform their contractual obligations towards
us. The third parties we engage are not allowed to use or share your personal data for a purpose other than to
provide services to us.
5. SECURITY
Personal data is processed in a manner that ensures appropriate security and confidentiality, including
preventing unauthorised access to or use of personal data. We shall protect all data from loss, misuse,
unauthorised access or disclosure, alteration, or destruction. The Company shall not be liable for unlawful or
unauthorised use of any personal information due to misuse or misplacement of the passwords, negligent or
malicious use.
We maintain policies and procedures and have measures in place in order to ensure high levels of protection
of personal data which include, inter alia, appropriate restrictions on permissions of access to personal
information, controls and monitoring of storing and distribution of data.
All our employees and associates are required to follow our privacy and security policies and procedures. The
Company is not responsible for the security and privacy of any third party and/or social networking services or
any information collected by them.
6. HOW LONG WE KEEP YOUR PERSONAL DATA
We retain personal information for as long as we reasonably require it for legal or business purposes. In
determining data retention periods, we take into consideration local applicable laws and contractual obligations.
When information is no longer needed, we proceed with destruction procedures.
7. RIGHTS
Note that under data protection laws, in certain circumstances you have the below rights in relation to your
personal data:
Right to access your personal data
You may request from us to receive a copy of the personal data we hold about you and check that we are
lawfully processing it. The Company hereby reserves its right to charge a relevant fee for providing such record
of personal data to the person requesting this, except where this is not allowed under local legislation.
Right to correction of the personal data in our records
You may request us to correct any incomplete or inaccurate data we hold about you, though we may need to
verify the accuracy of the new data you provide to us.
Right to erasure of your personal data
You have the right to request that we erase or remove your personal data in certain circumstances. This applies
where there is no good reason for us continuing to process it, or where you have successfully exercised your
right to object to processing (as per below), or where you believe we may have processed your information
unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that
we may not always be able to comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
Page
3
of
3
Right to object to the processing of your personal data
Where we are using your data because we deem it necessary for our legitimate interests to do so, and you do
not agree, you have the right to object.
Right to request restriction of processing of your personal data
You have the right to request that we restrict and/or suspend our processing of your personal data in certain
circumstances: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but
you prefer us to restrict our processing of it rather than erasing it; (c) where you need us to hold the data even
if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected
to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to request the transfer of your personal data to you or to a third party
Upon your request we can provide you with your personal data or provide these to a third party you have
chosen.
Right to withdraw consent at any time
Where we have obtained your consent to process your personal data, you may withdraw your consent at any
time. Note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
8. ACCEPTANCE OF THE PRIVACY POLICY
By using the Website, you consent to the collection and processing of your personal data in addition to all such
terms and conditions provided for in this Privacy Policy as well as other information found in the Website. You,
therefore, agree to waive all rights in holding the Company liable for any claim arising out of or in connection
with the processing of your data, as mentioned herein, unless such data has been fraudulently or negligently
processed against the terms of this Privacy Policy and you further warrant that all personal data and information
provided by you is accurate and up-to-date.
By accepting this Privacy Policy, you are, accepting the data processing and relevant collecting provisions
herein and you are giving your consent to the processing of your personal data as per this Privacy Policy.
9. MODIFICATIONS TO THE PRIVACY POLICY
The Company is entitled to modify this Privacy Policy at its sole discretion. This Privacy Policy may be amended
from time to time and you may refer to our page regularly to stay up to date.
10. HOW TO CONTACT US
Should you have any queries in relation to this Privacy Policy, your personal data held by us, or any other
general questions in relation to the Company or the services it provides, do not hesitate to contact us through
the contact details provided on this Website.
Right to object to the processing of your personal data
Where we are using your data because we deem it necessary for our legitimate interests to do so, and you do
not agree, you have the right to object.
Right to request restriction of processing of your personal data
You have the right to request that we restrict and/or suspend our processing of your personal data in certain
circumstances: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but
you prefer us to restrict our processing of it rather than erasing it; (c) where you need us to hold the data even
if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected
to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to request the transfer of your personal data to you or to a third party
Upon your request we can provide you with your personal data or provide these to a third party you have
chosen.
Right to withdraw consent at any time
Where we have obtained your consent to process your personal data, you may withdraw your consent at any
time. Note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
8. ACCEPTANCE OF THE PRIVACY POLICY
By using the Website, you consent to the collection and processing of your personal data in addition to all such
terms and conditions provided for in this Privacy Policy as well as other information found in the Website. You,
therefore, agree to waive all rights in holding the Company liable for any claim arising out of or in connection
with the processing of your data, as mentioned herein, unless such data has been fraudulently or negligently
processed against the terms of this Privacy Policy and you further warrant that all personal data and information
provided by you is accurate and up-to-date.
By accepting this Privacy Policy, you are, accepting the data processing and relevant collecting provisions
herein and you are giving your consent to the processing of your personal data as per this Privacy Policy.
9. MODIFICATIONS TO THE PRIVACY POLICY
The Company is entitled to modify this Privacy Policy at its sole discretion. This Privacy Policy may be amended
from time to time and you may refer to our page regularly to stay up to date.
10. HOW TO CONTACT US
Should you have any queries in relation to this Privacy Policy, your personal data held by us, or any other
general questions in relation to the Company or the services it provides, do not hesitate to contact us through
the contact details provided on this Website.