Privacy policy

Eurivex Privacy Policy

Eurivex Ltd (also referred to as “Eurivex”) is fully committed to safeguarding the privacy of its website, visitors and electronic mail users. The details of this policy, together with the Eurivex Ltd Terms and Conditions and Terms of Use, describe the way personal data is collected from the User, and how this data is managed, processed and protected.

The User is expected to fully read and understand Eurivex Ltd’s Privacy Policy.

The User is expected to fully read and understand Eurivex Ltd’s Privacy Policy.

Who we are?

Eurivex is an EU Investment firm, incorporated and based in Cyprus, regulated by the Cyprus Securities & Exchange Commission (CySEC), number 114/10, licensed to offer Reception & Transmission and Execution of Orders on behalf of clients, as well as Dealing on Own Account. It is also licensed to hold customer funds in Safe Custody, provide Advice to Undertakings, as well as Foreign Exchange services when these are connected to the provision of investment services. Eurivex is operating in compliance with the Processing of Personal Data Law (138(I) 2001) of Cyprus and the European General Data Protection Regulation (GDPR) 2016/679, under which Eurivex Ltd acts as the Data Controller and Data Processor and the Client as the Data Subject.

What kind of information do we collect?

We are required by law to verify the identity of our clients on the opening of each new account or on the addition of a new signatory on an existing account. Anti-money laundering laws require us to see the originals or certified true copies of certain documents to meet the standards, set under those laws. Such documentation, relevant to the services we provide to you includes:

(a) passport;

(b) internal passports (where applicable);

(c) national identity card (only in the case of EU nationals);

(d) utility bills (avoid mobile phone bills);

(e) trust deed (if applicable);

(f) a credit check on the individual (if applicable); or

(g) other information we consider necessary to perform our activities.

If you are a legal entity, we are required to collect additional information such as full corporate documents, Legal Entity Identifier, Tax Identification Number, financial statements (audited and management accounts) as well as additional personal information on the Shareholders and Directors. We have the right to request any additional information we deem necessary to comply with legal and regulatory requirements.

Information about you may also be collected from third parties either through publicly available sources, social media platforms, introducing brokers and affiliates, bankers and credit card processors, subscription-based intelligence databases or any other third-party associates.
As part of our business, we collect personal data from customers and potential customers that include the following:

• Name, Surname and contact details
• Date of birth
• Information about your income and wealth including details about your assets and liabilities as well as your Tax Identification Number (TIN)
• When establishing source and origin of funds as part of our Anti-Money Laundering and Compliance procedures, we shall collect account balances, trading statements, tax and financial statements and any other information we deem necessary to establish the source and original of your funds that you intend to transfer to us
• Profession and employment details
• Location data
• Knowledge and experience in trading, risk tolerance and risk profile
• IP address, device specifications and other information relating to your trading experience
• Bank account, e-wallets and credit card details
• Details of your visits to our Website or our Apps including, but not limited to, traffic data, location data, weblogs and other communication data.
• Information, such as your name and email address, that you enter in order to set up subscriptions to our newsletters;
• Information that you enter while using the services on our website; information that is generated while using our website, including when, how often, and under what circumstances you use it;
• Information relating to services you use, or transactions you make through our online trading platform, which includes your name, address, telephone number, email address, and other details;
• Information contained in any communications that you send to us by email or through our website, including its communication content and metadata;
• Any other personal information that you send to us.

Eurivex may collect and store the following data about the User:

1. Information that the User provides by filling in forms on the Eurivex websites www.eurivex.com or www.eurivextrade.com (“Eurivex website”). This includes information provided to open an account and other functions on the website. Eurivex may also ask the User for information when the User reports a problem or a complaint with the website, services, etc.
2. If the User contacts Eurivex, Eurivex may keep a record of that correspondence. Eurivex may also ask the User to complete surveys that it uses for research purposes, although the User is not bound to respond to requests to complete forms or surveys.
3. Details of transactions the User carries out through the Eurivex website and of the fulfillment of the User’s orders whether through the website or other means.
4. Details of the User’s visits to the Eurivex website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for Eurivex’s own billing purposes or otherwise and the resources that the User accesses.

How do we collect your data?

You directly provide our Company with most of the data we collect. We collect data and process data when you:

• Register online and fill in your personal information, as well as complete a customer questionnaire
• Submit your documentation in person or via our online portal, or via email communication
• Place an order for any of our services.
• Use or view our website via your browser’s cookies.

How will we use your data?

We are committed to safeguarding and protecting personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any personal data provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

Our Company collects your data so that we can:

• Process your order and manage your account.
• Email you with information on other products and services we think you might like.
• Sending you trade order notifications (that you have placed an order to trade), order cancellations, expiry of orders.
• Sending trade confirmations, notification of deal maturities, secondary market trading information.
• Sending statements, invoices, and payment reminders to you, and collecting payments from you;
• Sending you non-marketing commercial communications;
• Sending you email notifications that you have specifically requested;
• Sending you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
• Sending you marketing communications relating to our business which we think may be of interest to you by email or similar technology (you can inform us at any time if you no longer require marketing communications);
• Providing our regulator CySEC, the Central Bank of Cyprus, Cyprus Inland Revenue, other EU governmental organisations with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
• Dealing with inquiries and complaints made by or about you relating to our website and services;
• Keeping our website secure and prevent fraud;
• Verifying compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service); and

We will not, without your express consent, supply your personal information to any third party for their or any other third party’s direct marketing.

Disclosing personal information

We may disclose your personal information to any of our employees, officers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy and to our Regulator (CySEC) when such a request is made.

When our Company processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent use of our services.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

1. to the extent that we are required to do so by law;
2. in connection with any ongoing or prospective legal proceedings;
3. in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
4. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
5. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

International data transfers

We require organizations who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all relevant data protection laws and this privacy notice.

1. Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
2. Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: Ukraine.
3. Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

How do we store your data?

Our Company securely stores your data at our headquarters located at 18 Kyriacou Matsi Avenue, Victory Tower, 1^st floor, Nicosia 1082 Cyprus with backup disks stored at a secure location in Cyprus. We also store your data on secure cloud-based services operated by global multinationals based in the European Union.

Our Company will keep your personal information supplied by you for opening the account and all order/communication history for the entire period that a relationship exists. On termination of the agreement, we will delete your data only after the end of five years from the termination date in line with CySEC’s requirements.

1. This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.
2. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. Notwithstanding the other provisions, we will retain documents (including electronic documents) containing personal data:
   1. to the extent that we are required to do so by law;
   2. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
   3. in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

In brief, the data protection measures we have in place are the following:

• we train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals
• requiring our employees to use passwords and authentication when accessing our systems;
• we apply Chinese walls and employees only have access to the personal data required for the purposes of the tasks they handle.
• We apply data security technologies during data transmission during internet transactions and client access codes transmitted across networks
• employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses entering our systems;
• using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;

Marketing

Our Company would like to send you information about products and services of ours that we think you might like, as well as those of our subsidiaries.

• In addition to Eurivex Ltd, we will periodically send you information from Eurivex Trade Finance Limited (which is a 100% subsidiary of Eurivex Ltd), from Eurivex PLC (which is a 100% subsidiary of Eurivex Trade Finance Limited) and Eurivex Nominees Ltd.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop our Company from contacting you for marketing purposes or giving your data to other members of our Company Group.

Security of your personal information

1. We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
2. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
3. All electronic financial transactions entered into through our website will be protected by semi-encrypted technology.
4. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
5. You are responsible for keeping the password you use for accessing our platform confidential; we will not ask you for your password (except when you log in to our platform).

What are your data protection rights?

Our Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request our Company for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that our Company correct any information you believe is inaccurate. You also have the right to request for our Company to complete the information you believe is incomplete.

The right to erase – You have the right to request that our Company erase your personal data, but you should understand that your rights are limited since as an EU investment firm we abide and follow very strict laws and regulations, and due to CySEC’s requirements that oblige us to keep client data five years after the termination date, we will not be able to process your request fully. In such case where you have requested erasure of your personal information, we shall only keep data that is mandatory for reporting purposes for five years after the termination date and dispose of any other unnecessary data that is not required. These regulations supersede GDPR rights and if you believe that your rights are not safeguarded because of such restrictions, then it is best that you opt not to open an account with Eurivex and enter into a business relationship.

The right to restrict processing – You have the right to request that our Company restrict the processing of your personal data, under certain conditions, subject to these not disturbing our operations as a regulated EU investment firm.

The right to object to processing – You have the right to object to our Company’s processing of your personal data, but you should understand that your rights are limited since as an EU investment firm we abide and follow very strict laws and regulations on Compliance, Know-Your-Client (KYC), Know-your-business (KYB) and Anti-Money Laundering (AML) regulations which supersede GDPR rights and if you believe that your rights are not safeguarded because of such restrictions, then it is best that you don’t open an account with Eurivex and enter into a business relationship.

The right to data portability – You have the right to request that our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions subject to these not disturbing our operations as a regulated EU investment firm.

Once a request is made, you can expect an official reply within the timeframe of one month. If you would like to exercise any of these rights, please contact us at:

Call us: +357 22 028830

Email us: [email protected]

Attn: Compliance Officer

Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. More information can be found in our Terms of Use document available on our website.

For further information, visit www.allaboutcookies.org

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in
• Understanding how you use our website

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

• Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Changes to our privacy policy

Our Company keeps its Privacy Policy under regular review therefore it is important that you check our Policy from time to time for any updates. If we make changes we consider to be important, we will communicate them to you.

How to contact us

If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us from your registered email address at: [email protected]

Call us: +35722028830

Or write to us at: 18 Kyriacou Matsi Avenue, Victory Tower, 1^st floor, Nicosia 1082, Cyprus

Complaints Handling

Eurivex aims to achieve the highest levels of compliance in providing the Client a transparent, professional, discrete and personalized service. Within this context Eurivex takes Client complaints very seriously. Such complaints shall be handled professionally and with full discretion.

Client complaints can be communicated to Eurivex via email at:

[email protected]

Please see our Complaints Handling procedures found on our web site in order to submit a complaint, how and when we handle your complaint and if you are not satisfied, how to submit a complaint to the authorities.