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Privacy Policy

1. DATA PROTECTION AND CONFIDENTIALITY

When processing any personal information provided by you, Brokersclub Ltd (hereinafter referred to as “BTFX”) as Data Controller, shall take all necessary steps to comply with the Data Protection Act and all subsidiary legislation made there under.

1.1. For the purposes of this Policy, “Data Protection Act” means the Data Protection Act (Chapter 440 of the Laws of Malta), as may be amended or replaced from time to time, and includes any subsidiary legislation made there under and any related guidance provided by the Information and Data Protection Commissioner or any other competent authority; and the words and expressions “controller”, “data subject”, “personal data”, “personal data representative”, “process / processing”, “processor” and “third party” have the same meaning as is assigned to them by article 2 of the Data Protection Act.

1.2. To the extent that BTFX, as a controller, processes any information that constitutes personal data BTFX undertakes to process such data in accordance with the provisions of the Data Protection Act, in the manner and for the purposes indicated in this Policy, the Customer Agreement and as BTFX may disclose on its Website or notify to the Customer from time to time.

1.3. BTFX will process such personal data as may be necessary for the provision of the Services and as BTFX may be obliged or authorised to do by or under the Laws (including but not limited to, compliance with the Licence conditions and with applicable prevention of money laundering and funding of terrorism legislation and requirements there under applicable to BTFX). BTFX may in particular be required to record telephone conversations and/or electronic communications and to keep records of all services and transactions undertaken by it so as to enable the MFSA to monitor compliance with the requirements under the Laws.

1.4. Personal data may be processed by BTFX and may be disclosed to and processed by persons authorised by BTFX in that respect (including Introducing Brokers), and their or BTFX’s duly authorised agents and any of their respective group companies and affiliates wherever located (including outside the EU). Personal data may also be disclosed to and processed by third parties, including the Prime Broker, the Liquidity Providers, the Counterparties, the Service Providers, governmental or regulatory bodies and tax authorities (including outside the EU).

1.5. BTFX may further process such personal data in order to provide Customer from time to time, with information about BTFX’s products and services, by ordinary mail, electronic mail, telephone, telefax or any other means. Unless the Customer specifies otherwise, BTFX may contact the Customer via ordinary mail, electronic mail, telephone, telefax or any other means to inform the Customer about new services, products or changes made to the Policy. The Customer has the right to object to receiving any direct marketing material by sending a notice in writing to BTFX, in which event BTFX will comply with such request. Should you not wish to be contacted about or receive marketing information from BTFX please write to the Compliance Officer on email: compliance@btfx.com

1.6. The Customer hereby consents to the processing of personal data relating to it, its officers, agents, employees, and other persons related to the Customer in accordance with the provisions of this Policy, and undertakes to obtain the consent of its officers, employees, agents, and other persons related to the Customer in relation to the processing of personal data as described above, as may be required by or under the Data Protection Act.

1.7. The Customer, as a data subject, is entitled to request BTFX (i) to provide written information as to whether personal data concerning the data subject is processed, and (ii) to rectify, block or erase personal data that has not been processed in accordance with the Data Protection Act or regulations made there under. Such requests must be made by the Customer and will be handled by BTFX in accordance with the Data Protection Act.

1.8. The Customer, as a data subject, may at any time, revoke his consent to the processing of personal data as aforesaid for compelling legitimate grounds relating to his particular situation, in which case he shall specify in respect of which data and which processing such revocation relates; all this without prejudice to the provisions of the Data Protection Act which permit the processing of personal data, even without the consent of the data subject, in the circumstances and for the purposes mentioned in such Act (in which case the right of the data subject to object to such processing shall be available in the circumstances and as provided in the Data Protection Act).

1.9. BTFX, its Introducing Brokers, the Prime Broker, Liquidity Providers, the Counterparties and the Service Providers and other persons processing personal data for the purpose of the provision on the Services, may also be subject to and required to comply with data protection legislation in the relevant jurisdiction.

1.10. You have a statutory right to access free of charge your personal information held by BTFX. Should you wish to obtain a copy of the personal information held by BTFX you should write to the Compliance Officer, at the address hereunder, email: compliance@btfx.com . On adequate assurance of your identity, BTFX will provide you with a copy of your personal information within 30 days from receipt of your request.

2. LINKS TO OTHER WEBSITES

This Privacy Policy only extends to this website and does not extend to your use of, access to, provision of data to and collection of data on any other website which may be connected to this website through hyperlinks.

3. Facebook and Facebook Social Media Plugins

Our website uses social plugins (“plugins”) provided by the social network facebook.com, operated by Facebook Inc., 1601 S. California Avenue, Palo Alto, CA 94304, USA (“Facebook”). The plugins are identifiable by a Facebook logo (white letter f on blue background or a thumb up icon) or the notice “Facebook Social Plugin”. For a full list of all social Plugins please see http://developers.facebook.com/plugins.

When you visit a page of our website that contains a social plugin, your browser establishes a direct connection to Facebook servers. Facebook directly transfers the plugin content to your browser which embeds the latter into the website, enabling Facebook to receive information about your having accessed the respective page of our website. Thus we have no influence on the data gathered by the plugin and inform you according to our state of knowledge:

The embedded plugins provide Facebook with the information that you have accessed the corresponding page of our website. If you are logged into Facebook, your visit can be assigned to your Facebook account. If you interact with the plugins, for example by clicking “Like”, or entering a comment, the corresponding information is transmitted from your browser directly to Facebook and stored by it. Even if you are not logged into Facebook, there is possibility that the plugins transmits your IP-address to Facebook.

For the information on the purpose and scope of data collection and procession by Facebook, as well as your rights in this respect and settings options for protecting your privacy please visit Facebook’s privacy policy: http://www.facebook.com/policy.php.

If you are a Facebook member and do not want Facebook to connect the data concerning your visit to our website with your member data already stored by Facebook, please log off Facebook before entering our website. Further you can block Facebook social Plugins by using add-ons for your browser, like the “Facebook Blocker“.

4. Jetpack/ WordPress.com-Stats

This website uses WordPress.com-Stats, a web analytics software provided by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110-4929, USA, with use of the Trackingtechnology of Quantcast Inc., 201 3rd St, Floor 2, San Francisco, CA 94103-3153, USA. WordPress.com-Stats uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address anonymized prior to its storage) will be stored on the server in the USA. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can opt-out from being tracked by Quantcast with effect for the future by setting an opt-out cookie in your Browser:http://www.quantcast.com/opt-out. If you delete your browser’s cookies, you’ll have to set this opt-out cookies again.

5. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States.

In case IP-anonymisation is activated on this website, your IP address will be truncated within the area of Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transfered to a Google server in the USA and truncated there. The IP-anonymisation is active on this website.

Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing them other services relating to website activity and internet usage.

The IP-address that your Browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Addon for your current web browser: http://tools.google.com/dlpage/gaoptout?

6. Using pixel tags and other similar technologies:

Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.

7. COOKIES:

BTFX may set and access BTFX cookies on your computer, enabling us to learn which promotions bring users to our Web site. BTFX may use cookies in connection with our products and services to track your activities on our Web sites. Such information that we collect and share is anonymous and not personally identifiable.

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. BTFX uses cookies on its site(s). The Firm does not link the information stored in cookies to any personally identifiable information you may submit.

BTFX uses both session ID cookies and persistent cookies. A session ID cookie does not expire when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s ‘Help’ file.

BTFX sets a persistent cookie for statistical purposes. Persistent cookies also enable the Firm to track and target the location and the interests of users that access the BTFX site(s) and to enhance the experience of services offered.

If you reject cookies, you may still use the BTFX site(s), but you will not be able to use to submit your application form.

Some of the BTFX business partners use cookies on the Firm’s site(s); BTFX has no access or control over these cookies.

8. ENCRYPTION TECHNOLOGY

BTFX uses Secure Socket Layer (SSL) encryption technology in order to protect certain information that you submit. This type of technology protects you from having your information intercepted by anyone other than BTFX while it is being transmitted to us.

9. CHANGES TO THIS PRIVACY POLICY

This website may be updated from time to time and the content of or the services featured on this website, including this Privacy Policy are subject to change at any time without notice. Material changes to this Privacy Policy will be posted on a prominent announcement in the website.

10. LICENSING STATEMENTS

Brokersclub Ltd is licensed to provide investments service by the Malta Financial Services Authority (MFSA).Licence Number IS/52844.

‘BTFX’ is the trade name of Brokersclub Limited. Brokersclub Limited is licenced and regulated by the Malta Financial Services Authority as a Category 2 investment services licence holder and holds

Licence no IS/52844.

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