Protecting the privacy and safeguarding the personal and information of our Customers and website visitors is one of our highest priorities. The following Privacy Statement explains how Timios Global Markets Ltd collects and protects your personal information. References to “funding™” in this Privacy Statement include all funding companies and divisions, including funding.COM.
By opening a funding™ account or by using funding™ websites, you give your consent to the collection and use of personal information by funding™ as explained in this Privacy Statement.
1. Collection of personal information
We collect your personal information directly from you and indirectly as a result of your relationship with us. funding™ may use the information collected from you to verify your identity and contact information, establish your trading account, issue you an account number and a secure password, maintain your account activity and contact you with account information, among other reasons. This information also helps us improve our services to you, customize your browsing experience and inform you about additional products, services or promotions that may be of interest to you.
You directly provide us with the majority of information we collect. This information includes your contact details, including name, mailing address, telephone number and e-mail address, personal identification data we are required by law to collect, including your passport number and/or tax identification number, and information required by law to assess your trading experience and risk tolerance, including your annual income, net worth and available risk capital. We also collect demographic information when you open an account, including gender, birth date, occupation and employment status.
You provide us with this information by completing the account application and related documentation, by sending us an e-mail or by submitting information in response to a promotion or special offer.
The information we collect indirectly from you includes your Internet protocol (“IP”) address, browser type, operating system, Internet service provider (ISP), time stamps and transaction history.
Should you close your account with us, funding™ will retain your information, but only use it to comply with regulatory requirements and to periodically contact you to offer you the opportunity to reactivate your account or participate in other offers.
2. Cookies
We use cookies and web beacons (also known as action tags or single-pixel gifs), and other technologies (collectively, “cookies”) to provide us with data we can use to improve your experience and to know you better. Cookies are small text files sent from Web servers that may be stored on your computer. Cookies enable us to capture how you arrived at our site, when you return, which pages on our site you visit, and to recognize that you are already logged on when we receive a page request from your browser. We may link the information we store in cookies to personally identifiable information you submit while on our site. We will never share this information with any 3rd party. Cookies are readable only by us and do not contain any personal information nor do they contain account or password information. We cannot and will not gather information about other sites you may have visited.
We may share usage information about visitors to our websites with reputable advertising companies for the purpose of targeting our Internet banner advertisements. The information collected by the advertising company through the use of these pixel tags is not personally identifiable. We may also use 3rd party software to track and analyze usage and volume statistical 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 funding™.
All web browsers have settings that allow you to block cookies. By visiting our website with your browser set to allow cookies, you consent to our use of cookies as described above. If you choose to block cookies you may use our services, but some functions may not work as designed.
3. Sharing Personal Information with funding™ affiliates and Non-affiliated third parties
funding™ does not sell, license, lease or otherwise disclose your personal information to any affiliate or third party for any reason, except as described below.
funding™ may share information with affiliates if the information is required to provide the product or service you have requested or to provide you with the opportunity to participate in the products or services our affiliates offer.
To help us improve our services to you, we may engage another business to help us carry out certain internal functions, such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a non-affiliated third party with client information
from our database, including your name, address, phone number, and/or e-mail address, to help us analyze and identify client needs, notify Customersof product and service offerings or conduct general marketing and market research for us.
funding™ also forges partnerships and alliances with non-affiliated third parties which offer high-quality products and services that might be of value to our clients. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, funding™ may share some personal information with these non-affiliated third parties.
We generally require that all non-affiliated third parties to which we provide your nonpublic personal information agree to keep your information confidential and use such information solely for the limited purpose for which we have engaged them, or as otherwise required by law. In addition, where offers are made to you by non-affiliated third parties, we generally require that they disclose that the offer is being extended because of your relationship with us. We also seek to ensure that these non-affiliated third parties maintain appropriate data security procedures to guard against unauthorized use of, or access to, your personal information.
When required by law, funding™ reserves the right to disclose your personal information to third parties or regulatory, law enforcement or other government authorities. We may also disclose your information to credit reporting or collection agencies, or when necessary to protect our rights or property.
If at any time you choose to purchase a product or service offered by another company, for example by clicking on an advertisement on a website owned or controlled by funding™, any personal information you share with that company will no longer be controlled under our Privacy Statement. We are not responsible for the privacy policies or the content of sites we link to, and we have no control over the use or protection of information provided by you to, or collected by, those websites. Whenever you elect to link to a co-branded website or to 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 published by that third party.
4. The security of your personal information
We employ security software, systems and procedures to offer you a safe and secure trading environment and to protect your personal, financial and trading information.
When you open an account with us, you are issued a unique account number, User ID and a password. Only a limited number of funding™ employees who have a need to know this information will have access to your account number, UserID, and password. Remember that you are ultimately responsible for maintaining the secrecy
of your account number, UserID and password. We strongly recommend that you do not disclose this information to anyone.
On our websites and online account applications we use technology to encrypt information transmitted by or to you. We use certificate authority (CA) certificates to authenticate our websites and secure trading and customer-facing applications, allowing you to verify that you are connected to our websites.
5. Changes to this Privacy Statement and Opting Out
In the event funding™ materially changes this Privacy Statement, the revised Privacy Statement will promptly be posted to our websites. By opening an account with us, you are deemed to agree to accept posting of a revised Privacy Statement electronically on our website as actual notice to you.
Under certain circumstances, such as with respect to our sharing of your personal information with non-affiliated third parties, you may inform us that you would like to “opt out” by contacting us through the contact information listed below. Note that for joint accounts, an-opt out election made by one account owner of a joint account is applicable to all account owners of the joint account. An opt-out election must be made for each separate account you hold at funding™.
Any dispute over our Privacy Statement is subject to this notice and the funding™ Customer Agreement. If you have any questions that this Privacy Statement does not address, please contact a Client Services representative.
You may contact funding™ for any reason under this Privacy Statement, or otherwise, as follows:
Email: support@funding.com.
Postal:
Timios Global Markets Ltd Attention: Privacy 1-13(A), First Floor, Paragon, Jalan Tun Mustapha, 8700
When using our services, as a resident of one of the EU member states, we shall process personal data of our customers (“you”, “your” or the “Customer”) as following. This Privacy Policy (the “Policy”) provides you with information about how your data are processed.
In this Privacy Policy, you will find information regarding the following:
- Who is the controller of your personal data and whom to contact?
- What information do we collect about you and how do we obtain it?
- How do we use your personal data?
- How do we store personal data and how are they secured?
- To whom do we make your personal data available?
- Do we transfer your data to third countries and international organisations?
- What are your rights and how can you exercise them?
1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA AND WHOM TO CONTACT?
The controller of personal data is Timios Global Markets Ltd, with its registered office at 1-13(A), First Floor, Paragon, Jalan Tun Mustapha, 87009 Labuan F.T., company no.: LL 17376, Regulated by the Labuan FSA with license number: MB/22/0097 (hereinafter referred to as “we”, “our”, “our Company”, or “Controller”).
You can contact Timios Global Markets Ltd at office at 1-13(A), First Floor, Paragon, Jalan Tun Mustapha, 87009 Labuan F.T., or at support@funding.com. regarding any questions and the exercise of rights relating to the processing of your personal data.
2. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE OBTAIN IT?
In this section, you can read general information about which of your personal data we collect and how we collect it. Detailed information on the purposes for which we process personal data is given in Section 3 of this Policy. All information on the basis of which we can directly or indirectly identify you or which is related to you is considered personal data.
We obtain most of the data we collect about you directly from you in connection with your use of our services. This includes, in particular:
- Data that you provide to us yourself, especially when you register on the website, enter information into your user account, order services, participate in our events and projects, or when you communicate with us through customer support or social networks. These are identification and contact data, specifically the name, surname, telephone number, e-mail address, postal address, date of birth, user name and password, and business identification number or tax registration number, if you are an entrepreneur; payment data, such as bank details; and other data, such as records of communication between you and our company or details of any warranty claims.
- Data that we automatically collect when you use our services. These are data about your device (such as the IP address, device type, operating system, browser used, connection provider); website usage data (such as the date, time and duration of visit, a country from which you visit the website, website browsing history), and data on the use of services (such as the login and logout information, your account settings, the value of your fictitious capital, your account currency, business strategy).
Some data about you is provided to us by third parties, such as providers of trading platforms that you choose for use of our services, and social network operators if you decide to link your social networking accounts to an account on the website. This includes:
- Data about the simulated transactions you have completed (such as the type of financial instrument, time of opening and closing the position, amount of investment, profit and loss) and data from social networks (user name, profile picture, e-mail address associated with the account on the social network). For information on how your personal data are processed by trading platform providers and social network operators for their own purposes, please refer to the privacy policies of those parties.
3. HOW DO WE USE YOUR PERSONAL DATA?
We use personal data for the following purposes:
- Registration and user account
In order to use the services, you must register on the website and create your account, and for this purpose we process your personal data.
Personal data: identification and contact data; we may also process your data related to the settings of your user account.
Legal ground for the processing: Processing is necessary for the performance of the contract, and the provision of these personal data is required, as we cannot register your user account without them.
- Provision of services and exercise of rights and obligations under the contract between us and the customer
In order to be able to provide you with our services, i.e. in particular to provide you with the relevant access, tools and support, and to carry out trades, we need to process your personal data. For this purpose, the following shall apply:
Personal data: Identification and contact data and, in the case of paid services, also payment data, data on the use of the services, data on the simulated trades and, if you decide to link your social networks accounts with the account on the website, also data from social networks.
Legal ground for the processing: Processing is necessary for the performance of the contract on the basis of which we provide our services, or on the basis of our legitimate interest. After we stop providing you with services, we process personal information for a limited period of time. Such processing is necessary for the purposes of exercising and protecting our rights based on our legitimate interests.
- Marketing communication about our services and products or about events in which we take part
If you are our current or past customer, we may from time to time send you marketing communications that relate to our services. We may also send you commercial communications to the extent to which you give us your consent. Each of the e-mails sent will be marked as a business communication and each of them will contain a link with the help of which you can easily unsubscribe from the business communications. For this purpose, the following shall apply:
Personal data: Identification and contact data.
Legal ground for the processing: If we have provided you with our services, we may from time to time send you marketing communications based on our legitimate interest, namely keeping in touch with our customers. If you give us your consent to process your data for marketing purposes, then we process your data on the basis thereof.
- Customer support and communication
If you use our customer support services, we will process your personal data. For this purpose, the following shall apply:
Personal data: Identification data, contact data, other data and data from social networks, if you contact us through social networks.
Legal ground for the processing: Processing is based on our legitimate interest, namely in maintaining customer satisfaction and supporting the use of our services.
- Improving services
If you use some of our services, we will process your personal data in order to develop, test and enhance the services and improve their security. For this purpose, the following shall apply:
Personal data: Identification and contact data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.
Legal ground for the processing: Processing is based on our legitimate interest, namely in improving our services.
- Analytics
To obtain information about how our website and our services are used, we analyse customer behaviour. For this purpose, the following shall apply:
Personal data: Identification data, contact data, payment data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.
Legal ground for the processing: Processing is based on our legitimate interest, namely in ascertaining customer behaviour and estimating customer preferences.
4. HOW DO WE STORE PERSONAL DATA AND HOW ARE THEY SECURED?
We process your personal data in an encrypted database on computers and other devices. In order to ensure protection against unauthorised access or unauthorised alteration, disclosure or destruction of the data that we collect and process, we have adopted organisational and technical measures to secure them, which we strictly adhere to.
5. HOW LONG DO WE PROCESS YOUR DATA?
Personal data are processed to the extent necessary to fulfil the purposes described above and for the time necessary to achieve those purposes or for a period directly stipulated by law. Thereafter, the personal data are deleted or anonymised. We process personal data for the following periods of time:
- for the purpose of performance of the contract and for the exercise of rights and obligations in connection with the contract, including any complaints, settlement of damage claims or related litigation, personal data are processed for the necessary period of time, but not more than 10 years from the termination of the last contract;
- for the purpose of sending business communications without your given consent, personal data are processed for a maximum of 5 years from the expiry of the last contract between us or until you raise an objection or unsubscribe from the business communications;
- for the purpose of enhancing our services, we usually process personal data for a maximum period of 6 months;
- in order to fulfil our legal obligations, we process personal data for the period set out by the relevant legal regulations (e.g. in accordance with tax regulations for a period of 10 years from the issuance of the relevant documents for your order);
- if you have given your consent, for the period specified in the consent.
6. DATA SHARING AND TRANSFERS TO THIRD COUNTRIES
We make your data available or transfer them to persons that help us provide our services, in particular the following persons:
- The trading platform provider, in order to enable you to perform the simulated trades.
- Other third parties that help us run our website and provide our services (such as other companies in our group, hosting and cloud service providers, payment system operators and financial institutions, providers of customer support tools and services, IT companies and system administrators, marketing and communication agencies, consultants and postal service providers);
In addition, we may transfer your data to persons in respect of which you give your consent thereto, as well as in the cases where it is our obligation under the law or under a judicial or any other legally binding decision. Each such entity to whom personal data are transferred is contractually obligated to protect your personal data in accordance with legal provisions and to process the data exclusively according to our instructions.
Certain third parties collect personal data for their own purposes as controllers. In such a case, their own rules for the processing of personal data shall apply.
7. YOUR RIGHTS
You can exercise all your rights mentioned below, including your right to erasure of personal data and the withdrawal of your consent, by sending a request to us via email at support@funding.com, alternatively you can use our contact details in Section 1 of this Privacy Policy. There are no specific words that you must use in your request, but please be specific enough, so we can help you with your request (e.g. identify yourself, specify the right you wish to exercise, what action you wish us to take, details of what personal data you want erased/deleted, etc.)
In connection with the processing of personal data you have the following rights:
- Right of access to personal data
You can ask us at any time to send you a confirmation as to whether or not your personal data are being processed. If we process your data, we will provide you with further details on the processing. If you request it, we will also provide you with a copy of the personal data processed. Please note that the first copy is free of charge, but later copies will be provided for a small fee.
- Right to rectification of personal data
If we process your personal data inaccurately, you can notify us of this fact, and we will rectify the inaccurate personal data without undue delay. If you register on the Website, you will be able to rectify and amend your personal data yourself by editing your user account.
- Right to erasure of personal data (“right to be forgotten”)
You have the right to obtain from us the erasure of personal data concerning you without undue delay in the following cases:
- If the data are no longer necessary in relation to the purposes for which we have collected or otherwise processed them;
- If you withdraw your consent to their processing and, at the same time, there will be no other legal ground for their processing (this only applies in the cases where we process personal data on the basis of your consent);
- If you object and there are no overriding legitimate grounds for the processing, or if you object to the processing for direct marketing purposes; or
- If your personal data are processed unlawfully.
We will not be able to act on the request for the erasure of personal data if their processing is necessary for exercising the right of freedom of expression and information, for compliance with any of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise, or defence of our legal claims, or for other reasons provided for by law.
- Right to restriction of processing
In cases stated in article 18 of the GDPR, you have the right to obtain from us restriction of processing of your personal data for a certain period.
- Right to data portability and to the provision of data in a machine-readable format
In the case of automated processing based on your consent or performance of the contract, you have the right to receive the data in a structured, commonly used and machine-readable format and to have them transmitted by us to another personal data controller.
- Right to object
If we process personal data on the basis of our legitimate interest, you have the right to object to such processing. If you file such an objection, we will not be able to process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests or rights and freedoms, or for the establishment, exercise or defence of our legal claims.
In case we process your personal data for marketing purposes about our products and services, we will terminate the processing without undue delay upon receipt of the objection. In such a case, we will no longer be able to send you offers of our products and services.
- Right to withdraw consent
If processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on the consent given before its withdrawal.
- Right not to be the subject of automated decision-making
Except where processing is necessary for entering into, or performance of, a contract, where this is permitted by applicable law, or based on your express consent, you have the right not to be the subject of any decision which is based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you to a significant extent.
- Right to lodge a complaint with the supervisory authority
If you believe that we are processing your data in violation of the relevant legal regulations, you can lodge a complaint with the relevant supervisory authority. Based on our registered office, our relevant supervisory authority is The Office for Personal Data Protection with its address at Pplk. Sochora 27, Prague 7, postcode 170 00, Czech Republic, or email posta@uoou.cz. More information about the Office can be found on the following website: https://www.uoou.cz/en/.
8. FINAL PROVISIONS
We may change this policy unilaterally, but we will do so only when necessary and we will notify you about such change. You can find the latest version of this policy in your Client Section.
Protection of Personal Information
Timios Global Markets Ltd (“funding™”) Protection of Personal Information Policy for Customers residing in Canada
1. Policy Context
1.1. Context Description
In the course of its daily activities, funding™ may gather personal information from individuals, in order to provide services, make decisions and support its business operations, programs and activities.
This Policy was developed according to the requirements of, and in compliance with, the Privacy Act of Canada.
1.2. Principles
funding™ has long recognized and accepted its responsibility to protect the privacy of individuals who interact with funding™ through electronic or other means and to safeguard their personal information.
2. Policy Statement
The purpose of this policy is to outline the funding™’s commitment to protect personal information and manage this information with the utmost responsibility and care.
It governs the collection, use, and disclosure of all personal information of individuals who interact with the funding™, regardless of whether the information is held in paper, electronic or digital form.
3. Scope
This Policy applies to information collected by funding™ or on behalf of funding™ by service providers pursuant to a contract.
funding™ will identify the purposes for which personal information is collected at the time or before the information is collected. These purposes include but are not limited to manage:
- Online eegistration as costumers of funding™;
- Any such other purposes as required by the funding™
funding™ reserves the right, in appropriate circumstances, to collect and hold information outside of Canada.
4. Mandatory Policy Requirements
4.1. Limiting collection, use and disclosure of personal information
- funding™ only collects personal information that relates directly to authorized programs or activities.
- Wherever possible, personal information is collected directly from the individual to whom the information relates and individuals are informed of the purpose of the collection at the time of the collection.
- funding™ only uses personal information or discloses it to third parties for the purpose for which the information was originally obtained or compiled, for a use consistent with that purpose or for a purpose permitted under the Privacy Act.
- The consent of the individual in question must be obtained before his or her personal information is used or disclosed for any other purpose.
- Any disclosure to third parties will be done pursuant to agreements setting out the requirements for use, safeguarding, retention and disposal of such information, or as required by law.
4.2. Safeguarding personal information
- Personal information, whatever its form, is classified according to the sensitivity of the information and is protected from unauthorized access, use, disclosure, removal, alteration and destruction in accordance with the funding™’s Internal Security Policy and Operational Standard: Information Security Policy.
- funding™ may use outside service providers or agents to collect and/or use personal information on its behalf. As part of the contractual agreements, these suppliers must protect personal information in a manner consistent with the privacy policies and practices established by funding and as obligated under the Privacy Act.
4.3. Retention and disposal of personal information
- funding™ retains and disposes of personal information in accordance with the funding™’s Corporate Records Management Policy, which meets the requirements set out in applicable legislation (i.e. the Privacy Act, the Library and Archives Act).
- Retention schedules for Personal Information held by funding™ are corelating with the requirements as set out in applicable legislation.
4.4. Access to, and accuracy of, personal information
- Upon request, funding™ shall provide an individual with timely access to his or her personal information contained in records under the control of the funding™. Individuals may also request correction to their personal information which is under the funding™’s control. Requests can be made in writing to the funding™’s Access to Information and Privacy Coordinator citing the Privacy Act.
- funding™ may require sufficient information to allow it to confirm that the person making the request is authorized to receive the related information before granting access or making corrections.
- Access will not be provided when the records contain information that would be exempt from access under the Privacy Act, such as containing personal information about other individuals. If access to personal information cannot be provided, funding™ shall provide the reasons for denying access.
4.5. Responding to privacy complaints
funding™ is committed to investigating and resolving all complaints related to privacy, confidentiality or its information-handling practices in the most thorough, prompt and confidential manner possible. Any individual who believes their privacy or access-related rights have been breached can submit a complaint in writing to the funding™’s Access to Information and Privacy Coordinator at:
Email: support@funding.com.
Postal:
Timios Global Markets Ltd Attention: Privacy 1-13(A), First Floor, Paragon, Jalan Tun Mustapha, 87009 Labuan F.T.
5. Privacy breaches
A privacy breach involves the improper or unauthorized collection, use, disclosure, retention and/or disposal of personal information. funding™ takes seriously any information or complaint pertaining to a breach of privacy. Any complaint, allegation or information regarding possible breaches of privacy are considered and assessed in a consistent manner and investigated fairly and impartially in a manner commensurate with the nature of the alleged complaint.
5.1. Further Advice and Guidance
This section contains information on frequency of review, maintenance, and contact information should users have questions related to specific aspects of the policy.
5.2. Frequency of reviews and maintenance
Any updates and amendments to this policy and the effective date shall be determined by the General Counsel and Corporate Secretary and communicated on the funding™’s website.
5.3. Enquiries
See the Access to Information and Privacy section on the funding™’s website.
