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    PRIVACY POLICY

    Last Updated: [2023/12/12]

    Introduction

    Welcome to NeolinFX ("we," "us," or "our"). This Privacy Policy outlines how we collect, use, disclose, and protect the personal information of users on our forex broker website ("Website"). By using our Website, you agree to the terms outlined in this Privacy Policy.

    As part of our daily business operations we need to collect personal information from our clients and prospective clients in order to provide them with our products and services and ensure that we can meet their needs when providing these products and services as well as when providing them with the respective information.

    Your privacy is of utmost importance to us and it is our policy to safeguard and respect the confidentiality of information and the privacy of individuals. This Privacy Policy sets out how Neolin Capital Markets Ltd (the “Company”) collects, uses and manages your personal information we receive by you or a third party in connection with our provision of services to you or which we collect from your use of our services and/or our website (i.e., www.neolinfx.com) and/or any other related websites and applications including, among others, the Company’s Members Area. The Privacy Policy also informs you of your rights with respect to the processing of your personal information.

    Our Privacy Policy is reviewed regularly to ensure that any new obligations and technologies, changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment. Any personal information we hold will be governed by our most recent Privacy Policy.

    Please note that if you are an existing and/or former employee of the Company, a job applicant, a contractor to the Company or a third-party service provider, your personal information will be used in connection with your employment contract, or your contractual relationship.

    This Privacy Policy applies to the processing activities performed by NeolinFX to the personal data of its clients/potential clients, website visitors and employees. This Privacy Policy does not apply to websites operated by any other organizations and/or other third parties.

    Who We Are

    Neolin Capital Markets Limited, a company incorporated with limited liability in Saint Lucia under the federal law of the Saint Lucia, under registration number - 2023-00397 with registered address at Ground Floor, The South Bay Building, Rodney Bay, Gross-Islet Saint Lucia, P.O. box 838, Castries, Saint Lucia.

    Neolin Capital Markets Limited is part of the Neolin Group. Each entity of the Neolin Group has its own separate Privacy Policy. Such entities operate their own websites and as such, if you are interested in learning about how such entities process your personal data, please refer to their corresponding privacy statements which may be found on their specific websites.

    1. Information We Collect

    1.1 Personal Information

    We may collect personal information provided by users during the account registration process, including names, addresses, email addresses, phone numbers, and identification documents. This information is necessary to create and manage user accounts.

    What kind of personal information do we collect and store?

    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 and gender

  • Information about your income and wealth including details about your assets and liabilities, account balances, trading statements, tax and financial statements

  • 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.

    • We use cookies to store and collect information about your use of our Website. Cookies are small text files stored by the browser on your equipment’s hard drive. They send information stored on them back to our web server when you access our Website. These cookies enable us to put in place personal settings and load your personal preferences to improve your experience. You can find out more about our cookies on our “Cookies Policy” available on our Website.

    We also keep records of your trading behavior, including a record of:

  • Products you trade with us

  • Historical data about the trades and investments you have made, including the amount invested

  • Your preference for certain types of products and services

    • We are required by law to identify you if you are opening a new account or adding a new signatory to an existing account. Anti-money laundering laws require us to sight and record details of certain documents (i.e. photographic and non-photographic documents) to meet the standards, set under those laws. Identification documentation, as required under anti-money laundering legislation or other legislation relevant to the services we provide to you includes:

  • (a) passport;

  • (b) driver’s license;

  • (c) national identity card (if applicable);

  • (d) utility bills;

  • (e) trust deed (if applicable);

  • (f) a credit check on the individual; or

  • (g) other information we consider necessary to our functions and activities.

    • If you are a corporate client we are required to collect additional information such as corporate documents of address, shareholders, directors, officers including additional personal information on the Shareholders and Directors. We have the right to ask any additional information we deem necessary to be compliant with our legal and regulatory requirements.

    We obtain this information in a number of ways through your use of our services and websites, the account opening applications, our demo sign up forms, webinar sign up forms, website cookies and similar tracking technology built into our Websites and Apps, subscribing to news updates and from information provided in the course of our ongoing relationship.

    We may also collect this information about you from third parties either through bought-in third party marketing lists, publicly available sources, social media platforms, introducing brokers and affiliates, bankers and credit card processors, subscription-based intelligence databases and other third-party associates.

    We may ask for other personal information voluntarily from time to time (for example, through market research, surveys or special offers). If you choose not to provide the information we need to fulfil your request for a specific product or service, we may not be able to provide you with the requested product or service.

    We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and will constitute evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or any other further notice.

    Further, if you visit any of our offices or premises, we may have CCTV which will record your image.

    1.2 Who may we disclose personal information to?

    As part of using your personal information for the purposes set out above, we may disclose your information to:

  • other companies within the Neolin group who provide financial and other services;

  • third party apps providers when you use our apps, communication systems and trading platforms which are provided to us by third parties;

  • service providers and specialist advisers who have been contracted to provide us with services such as administrative, IT, analytics and online marketing optimization, financial, regulatory, compliance, insurance, research or other services;

  • introducing brokers and affiliates with whom we have a mutual relationship;

  • Payment service providers and banks processing your transactions;

  • auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;

  • courts, tribunals and applicable regulatory authorities as agreed or authorized by law or our agreement with you

  • government bodies and law enforcement agencies where required by law and in response to other legal and regulatory requests;

  • any third-party where such disclosure is required in order to enforce or apply our Terms and Conditions of Service or other relevant agreements;

  • anyone authorized by you.

    • We endeavor to disclose to these third parties only the minimum personal data that is required to perform their contractual obligations to us. Our third-party service providers are not permitted to share or use personal data we make available to them for any other purpose than to provide services to us.

    Our websites or our apps may have links to external third-party websites. Please note, however, that third party websites are not covered by this privacy notice and those sites are not subject to our privacy standards and procedures. Please check with each third party as to their privacy practices and procedures.

    1.3 When and how do we obtain your consent?

    We may process your personal data for one or more lawful bases of processing (“Lawful Basis”) depending on the specific purpose for which we are using your data.

    The Lawful basis are the following:

  • to perform our contractual obligations towards you

  • to be compliant with the legal and regulatory requirements

  • to pursue our legitimate interests

    • Where our use of your personal information does not fall under one of these three Lawful basis we require your consent. Such consent shall be freely given by you and you have the right to withdraw your consent at any time by contacting us using the contact details set out in this privacy notice or by unsubscribing from email lists.

    We may use personal data provided by you through our website or otherwise and personal data provided during our business relationship to communicate with you for marketing promotional purposes as well as to provide you with market news and analytical reports. The channels used for such communications may include calling you, sending emails, notifications through your online account portal and sms notifications including push notifications. You have the right to opt out by using your online account portal or by sending an email, at dpo@neolinfx.com using the registered email address you disclosed to us, in case you do not have access to your online portal account, or one has not been provided to you for any reason.

    1.4 Management of personal information

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

    We have appointed a Data Protection Officer to ensure that our management of personal information is in accordance with this privacy notice and the applicable legislation.

    We require organizations outside the Neolin Capital Markets limited 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.

    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 two-factor 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 encrypting 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 unauthorized persons and viruses entering our systems;

  • using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;

  • practicing a clean desk policy in all premises occupied by us and our related bodies corporate and providing secure storage for physical records; and

  • employing physical and electronic means such as access cards, cameras and guards to protect against unauthorized access.

    • 1.5 How do we store personal information and for how long?

    We hold personal information in a combination of secure computer storage facilities and paper-based files and other records and take steps to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure.

    When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.

    However, we may need to maintain records for a significant period of time. For example, we are subject to investment services and anti-money laundering laws which require us to retain copies and evidence of the actions taken by us in regard to your identity verification, sources of incomes and wealth, monitoring of your transactions, telephone, chat and email communications, orders and trades history, handling of your complaints and records that can demonstrate that we have acted in line with regulatory code of conduct throughout the business relationship. These records must be maintained for a period of five years after our business relationship with you has ended or even longer if we are asked by our Regulators.

    Personal data provided by you as a prospective client during account opening registration in case the registration was never completed or your account opening application was rejected, will be maintained for six months unless there is a regulatory reason requiring us to keep it for a longer period of time.

    Where you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications.

    The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or Affiliate companies. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

    When we transfer your data to other third parties outside the EEA, we may in some cases rely on applicable standard contractual clauses, binding corporate rules, the EU-US Privacy Shield or any other equivalent applicable arrangements

    If you would like a copy of such arrangements, please contact us using the contact details below

    1.6 Your Legal Rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data:

    Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information we hold about you so as to check that we are lawfully processing such.

    Request correction of your Personal Information. This enables you to have any incomplete or inaccurate information completed and or amended accordingly.

    Request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable 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.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of data is unlawful but you do not want us to erase 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 data portability allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from us to another service provider in a safe and secure way.

    If you wish to exercise any of the rights set out above, please send an email to dpo@neolinfx.com

    You will not have to pay a fee to access your personal data or exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or exercise any of your other rights. This is a security measure to ensure that your personal data is not disclosed to any person other than you. We may contact you to ask for information in relation to your request to speed up our response.

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is complex or you made a number of requests. In this case, we will notify you and keep you updated.

    2. Data Security

    2.2 Security Measures

    We implement industry-standard security measures to protect the confidentiality and integrity of personal information collected on our Website. These measures include encryption, secure socket layer (SSL) technology, and access controls.

    Data Security

    The Internet is not a secure medium. Please be aware that communications over the Internet, such as emails/webmail’s, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered. This is the nature of the Internet. The protection of your personal data is extremely important to us and we have put in place a range of security procedures to protect it, as set out in this Privacy Policy. Where you have been allocated a trading account, this area is protected by your user name and password, which you should never divulge to anyone else. We will use reasonable endeavors to implement appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss.

    For instance, our security measures include, but are not limited to:

    (a) educating our employees about their obligations regarding your personal data;

    (b) requiring our employees to use passwords and two-factor authentication when accessing our systems;

    (c) encrypting data sent from your computer to our systems during internet transactions and client access codes transmitted across networks;

    (d) employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorized persons and viruses entering our systems;

    (e) using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;

    (f) practicing a clean desk policy in all premises occupied by us and our related bodies corporate and providing secure storage for physical records; and

    (g) employing physical and electronic means such as alarms, cameras and guards (as required) to protect against unauthorized access to buildings. We will ensure that your information will not be disclosed to government institutions or authorities except if required by law (e.g. when requested by regulatory bodies or law enforcement organizations in accordance with applicable legislation). Certain services may include social networking, chat room or forum features. When using these features please ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users.

    3. No Guarantees

    While we strive to protect your personal information, we cannot guarantee the security of data transmitted over the internet or stored electronically. Users should take appropriate steps to secure their account credentials and devices.

    4. Cookies and Tracking Technologies

    4.1 Cookies

    We use cookies and similar tracking technologies to enhance user experience and gather information about user interactions with our Website. Users can adjust browser settings to reject cookies, but this may affect certain features.

    USE OF "COOKIES"

    4.1.1 We use cookies to assist us in securing your trading activities and to enhance the performance of our Web site. (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. 4.1.2 We may share Web site usage information about visitors to the Web site 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 have visited. The information collected by the advertising company through the use of these pixel tags is not personally identifiable

    5. Opt-Out

    Users can opt-out of certain tracking technologies through their browser preferences. However, opting out may impact the functionality of certain features on our Website.

    If you do not want us to use your personal information, you must inform the Company by sending an email to dpo@neolin.com .If you decide to do so, we may not be able to continue to provide information, services and/or products requested by you and we will have no liability to you in this respect.

    6. Changes to Privacy Policy

    6.1 Updates

    We reserve the right to update this Privacy Policy to reflect changes in our practices or legal requirements. Users will be notified of significant changes, and we recommend reviewing the policy periodically.

    7. Contact Information

    If you would like to let us know about something we have done or failed to do in relation to your personal data, whether positive or negative, please let us know. Your comments enable us as an organization to learn and continuously improve our services. If you think there is a problem with the way we are handling your data, you have the right to complain to the DIFC Commissioner of Data Protection. Questions, comments and requests regarding this Privacy Policy should be addressed to:

    8. User Rights and Choices

    Users can access and update their personal information through their account settings. They may also request corrections or deletion of inaccuracies.

    Users can close their accounts at any time. Closing an account will result in the deletion of personal information, subject to retention requirements under applicable laws.

    Users can manage their marketing communication preferences through their account settings or by contacting us.

    LEGAL DISCLAIMER

    The Company may disclose your personally identifiable information as required by rules and regulations and if the Company believes that disclosure is necessary to protect our rights or to comply with other proceedings, court order, legal process served or pursuant to governmental, intergovernmental or other regulatory bodies. The Company is not liable for misuse or loss of personal information or otherwise on the Company’s website(s) that the Company does not have access to or control over. The Company will not be liable for unlawful or unauthorized use of your personal information due to misuse or misplacement of your passwords, negligent or malicious intervention or otherwise by you or due to your acts or omissions or a person authorized by you (whether or to that authorization is permitted by the terms of our legal relationship with you).