Privacy Policy

ForexCup Trading Championship 2021

FXOpen Investments Inc. is a company registered in Panama under registered number 702638, Document 1784605, having its registered address at Plaza 2000, 10th Floor, 50th Street Panama City, P.O. Box 0833 and for the purposes of this Privacy Policy, referred hereinafter to as “FXOpen”, "we" or "us". This Privacy Policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us on www.championship.forexcup.com (“website” or “our website”). Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By using our website, you agree to be bound by this Privacy Policy and authorize us to collect, keep, transfer and use your personal data in accordance with this Privacy Policy.

Privacy

We know that you are concerned with how we deal with your personal information. This Privacy Policy sets out our current policies and demonstrates our commitment to your privacy. Your further rights and our obligations in respect to collecting and dealing with your personal information are disclosed in the Privacy Act 1993 and Regulation (EU) 2016/679 (General Data Protection Act) (for European Economic Area residents).

Purpose of the Information Processing

We collect personal information only with your consent and that you voluntarily provide to us when using our website expressing an interest in obtaining information about us, taking part in the Championship or contacting us. We only use and collect your personal information as appropriate to hold the Championship and to fulfil our legal and operation obligations.

We are required to maintain certain personal information about individuals for the purposes of taking part in the Championship and satisfying our operational and legal obligations. We recognize the importance of correct and lawful treatment of personal information as it helps to maintain confidence in our organization and to ensure efficient and successful outcomes when using this information.

Principles of the Information Processing

All personal information is:

a) Fairly and lawfully processed;

b) Processed for a lawful specified purpose;

c) Adequate, relevant and not excessive;

d) Not kept for longer than necessary;

e) Accurate;

f) Processed in accordance with the individual’s (data subject’s) rights;

g) Secured;

h) Not transferred to other countries without adequate protection.

Personal Information We Collect

We may collect and process the following data about you:

a) Information that you provide during registering and taking part in the Championship: FXOpen trading accounts transactions records; trading activity, financial and other information that FXOpen trading accounts contain (e.g. FXOpen account’s number, trading results); name and surname; email and other details of the participation in the Championship. You give us the permission to obtain the information as disclosed above from the third parties where you hold such trading accounts registered for the Championship;

b) Information that you provide by filling in forms on our website, in emails, by calls, in our live chat, support center etc.;

c) Information you provide to us in the applications we ask you to fill in;

d) Details of your visits to our website, details of your emails, calls and requests sent through the live chat and the support center from, including, but not limited to: traffic information, location information, web logs and other communication information, the resources that you access, devices and services you use to contact us.

We also collect the information about current, past and prospective website visitors with whom we have dealings. This information may include information required to communicate with you, including your name and surname, telephone number, email address and your location information.

We may also ask you for information when you report a problem with our website. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

The information we collect depends on the context of your interactions with us, the choices you make, including your privacy settings,. We shall comply with the regulations applicable to us and our website. As a result, we need to collect, process and keep your personal information to meet the applicable legislation requirements. Personal information may consist of information kept on paper, computer or other electronic media all of which is protected under the applicable law. You have choices about the information we collect. When you are asked to provide personal information, you may decline. Subject to the provisions of this Privacy Policy specified below, you are also entitled to have us erase your personal information, cease further dissemination of the information and potentially have third parties halt the processing of the information. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. However, if you choose not to provide information that is necessary to register you with the Championship or the proper operation of the website or to withdraw the information that is still relevant to the purposes of processing in accordance with this Privacy Policy, you may not be able to participate in the Championship or the website may work or display in an inappropriate way.

Your rights

As a data subject which provides its personal information to us you are entitled to:

a) obtain from us information on whether your personal information is being processed by us. You may also access your personal information and request us to provide you with a copy of your personal information;

b) obtain from us without undue delay the rectification of inaccurate personal information. You also have the right to have incomplete personal information completed;

c) subject to the information protection regulations applicable to you, you may request from us the erasure of your personal information without undue delay. The request shall be made on the legal grounds provided in the information protection regulations applicable to you, which include among others:

(i) the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

(ii) you withdraw your consent on which the processing is based according to the provisions of the applicable information protection regulations and where there is no other legal ground for the processing;

(iii) you object to the processing pursuant to the applicable information protection regulations and there are no overriding legitimate grounds for the processing, or the information subject objects to the processing;

(iv) the personal information has been unlawfully processed;

(v) the personal information has to be erased for compliance with a legal obligation in the European Union or any other applicable instruction to us by law.

d) Subject to the information protection regulations applicable to you, you may request us to restrict processing of your personal information in the following cases:

(i) the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of your personal information;

(ii) the processing of your personal information is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;

(iii) we no longer need the personal information for the purposes of processing, but it is required by you for the establishment, exercise or defense of legal claims;

(iv) in other cases as specified in the applicable legislation.

e) Receive your personal information, provided to us, in a structured, commonly used and machine readable format and you have the right to transmit that information to any third party. You may also ask us to transmit your personal information directly from us to other person in case such other person supports the information format and secure connections used by us to transmit such information;

f) object, on grounds relating to your particular situation, at any time to the processing of your personal information. If you do so, we wouldn’t process your personal information unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims;

g) You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. However, we could do so if this is necessary for entering into, or performance of, a contract between us. We use an automated information system, which collects and process your personal information and

makes a pre-decision in respect to the entering into agreement with you or requests an additional information from you in order to execute our obligations under the agreement with you.

Reasons we share your personal information

We share your personal information with our partners, affiliates, vendors and service providers, including IT and software providers and vendors with your consent or as necessary to hold the Championship. We may also share your personal information with third parties and authorities if required by law, in respond to legal processes, to protect participants of the Championship and website visitors and to protect our rights or property.

We do not sell, license, lease or otherwise disclose your personal information to any third party for any reason, except as described below.

We reserve the right to disclose your personal information to third parties when required to do so by law to regulatory, law enforcement or other government authorities. We may also disclose your information to non-affiliated third parties if it is necessary to protect our rights or property.

All third parties receiving your personal information from us under the respective agreements are required to protect your personal information in a manner similar to the way we do this. We use a variety of legal mechanisms, including contracts, to help ensure your rights and protections.

Restriction of responsibility

Any personal information you share with third parties on any other sites for exception of our website will no longer be controlled under our Privacy Policy. We are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of information provided by you or collected by those sites. Whenever you elect to visit a linked website, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party and you should familiarize yourself with the Privacy Policy provided by that third party.

Access to Personal Information

All individuals who are the subject of personal information held by us are entitled to: a) ask what information we hold about them and why;

b) ask how to gain access to it;

c) be informed how to keep it up to date;

d) have inaccurate personal information corrected or removed;

e) to receive the personal information concerning them, which they have previously provided;

f) prevent us from processing information or request that it is stopped if the processing of such information is likely to cause substantial, unwarranted damage or distress to the individual or anyone else, etc.;

g) require us to ensure that no decision which significantly affects an individual is solely based on an automated process for the purposes of evaluating matters relating to him/her, such as conduct or performance;

h) be informed what we are doing to comply with our obligations under the personal information protection laws.

If you cannot access certain information and personal information collected by us, you can always contact us via the contact details as specified in this Privacy Policy. We will respond to requests to access or delete your personal information within 30 days.

Should you consider that your rights under this Privacy Policy and/or applicable legislation are infringed by us and we did not take all necessary actions to remedy such violation or rejected your claim, you have the right to lodge a complaint with a supervisory authority and before the competent court.

Security of Personal Information

We maintain strict security standards and procedures with a view to preventing unauthorized access to your information by anyone, including our staff. We use leading encryption technologies to secure your information on a hardware and software levels. The hardware protection includes Cisco security products. The software protection tools include strict control mechanisms as follows: SSL, TLS with keys larger than 2048-bit. All our members, staff and third parties whenever we hire them to provide support services, are required to observe our privacy standards and to allow us to audit them for compliance.

Retention of Personal Information

FXOpen retains your personal data for as long as necessary to hold the Championship or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. The criteria used to determine the retention periods include, for instance:

a) the period of your personal data processing needed to hold the Championship. This includes such things as keeping our systems secure and maintaining appropriate business and financial records. It is a general rule that establishes the baseline for most data retention periods;

b) the personal data subject's consent for a longer retention period. If so, we shall retain your personal data in accordance with the consent;

c) FXOpen is subject to a legal, contractual, or similar obligation to retain your personal data. Mandatory personal data retention laws can be applied in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or personal data that must be retained for the purposes of litigation. The information subject's consent for a longer retention period. If so, we will retain information in accordance with the consent.

Use of Cookies

We use cookies to assist us to enhance the performance of our website (Cookies are small text files sent from the web server to your computer.) Cookies used by us do not contain any personal information, nor

do they contain account or password information. They merely allow the site to recognize that a page request comes from someone who has already logged on.

We may share website usage information about visitors to the website with reputable advertising companies for targeting our Internet banner advertisements on this site and other sites. For this purpose, pixel tags (also called clear gifs or web beacons) may be used to note the pages you've visited. The information collected by the advertising company through the use of these pixel tags is not personally identifiable.

To administer and improve our website, we may use a third party to track and analyze usage and statistical volume information including page requests, form requests, and click paths. The third party may use cookies to track behavior and may set cookies on behalf of us. These cookies do not contain any personally identifiable information.

Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. In the event we materially change this Privacy Policy, the revised Privacy Policy will promptly be posted to the websites and we will post a notice on our websites informing you of such changes. You agree to accept posting of a revised Privacy Policy electronically on the website as actual notice to you. Any dispute over our Privacy Policy is subject to this notice and our agreement with you. We encourage you to periodically check back and review this Privacy Policy so that you will always know what information we collect, how we use it, and to whom we disclose it. If you have any questions that this statement does not address, please contact us.

Contact

If you have a privacy concern, complaint or a question regarding your personal information collection, processing and keeping, please contact the Information Protection Officer by email at [email protected] or send written correspondence to Plaza 2000, 10th Floor, 50th Street Panama City, P.O. Box 0833. We will respond to questions or concerns within 30 days.

Unless otherwise stated, FXOpen is a data controller for personal information we collect through the services subject to this statement.