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Privacy Policy

  1. OPTINARY respects your privacy and is committed to protecting and respecting your personal data. This privacy policy is intended to provide you with information about how we collect and process any personal data, i.e. information about a Customer (as defined below) who is a natural person on the basis of which that Customer can be identified (hereinafter the data) in accordance with applicable data protection legislation and best practices. We strive to create the most secure infrastructure of any exchange in the world. In this privacy policy, we would like to explain why you can trust us with your data and be sure that your data is safe. It is important that you read this privacy policy alongside any other privacy policy that we may provide on specific occasions when we are collecting or processing your data, so that you are fully aware of how and why we are using your data. In this Privacy Policy, unless the context otherwise requires, the expressions defined herein shall have the meaning given to them in the T&C. Please note that this Privacy Policy is addressed to current and prospective Customers. If you are an employee, contractor or third-party service provider, your personal information will be used in connection with your employment contract, your contractual relationship or in accordance with our separate policies which are available by contacting us at the contact details listed in the OUR CONTACT DETAILS section below. If you are participating in our affiliate program and/or introducing a brokerage program, we will process the data provided under our contract with you to exercise our rights and perform our obligations under or in connection with the relevant agreement and the term Customer in this Privacy Policy. should be read to include the term affiliate and/or introductory broker (as applicable).

      1. WHO WE AREOPTINARY is the controller and responsible for the Client’s data that is disclosed to us for the registration of a Trading Account, Demo Account and/or to make use of any other services offered by OPTINARY through the https://www.fxoption .com/ (hereinafter “Website”) (this term will always include the desktop and mobile versions of the Website).

This Privacy Policy is issued on behalf of OPTINARY, the company responsible for the collection and/or processing of your data when you use the Trading Platform through the Website, whether for a Trading Account or a Demo Account (or its mobile/desktop versions) (hereinafter the Services). At OPTINARY we respect your privacy and are committed to protecting your data, which we collect, use and/or have access to.

The Company takes steps to implement advanced data protection policies and procedures and to update them periodically for the purpose of protecting the Client’s data and the Client’s account. Your data is protected by the legal, administrative, and technical measures we take to ensure data privacy, integrity, and accessibility. To prevent security incidents with your data, we use a mixed organisational and technical approach based on the results of the annual risk assessment.

The Company will not disclose any private information of its Clients and former Clients unless the Client approves such disclosure in writing or unless such disclosure is required by applicable law or is required to verify the Client’s identity or is required in order for OPTINARY to perform its contractual obligations arising from any agreement entered into with the Client. Clients’ information is processed only by the Company’s employees and/or trusted third parties who provide specific support services, dealing with specific Client Accounts and necessary for the provision of our services. All such information will be stored on electronic and physical storage media in accordance with applicable law.

      1. DATA USAGE
      2. We may collect, use, store, and transfer different types of data about you, which we have grouped as follows:
        • Identity data includes first name, last name and patronymic (if available), date of birth, gender, passport, identity document, driver number and copy of photo.
        • Contact data includes billing address, email address, and phone numbers.
        • Financial Data includes bank account, payment card details and tax identification number (including but not limited to social security number, income tax identification number, national insurance number).
        • Transaction Data includes details about the transactions carried out by you, details about payments, withdrawals, exchanges, trading history, profit, balance, methods of deposited amounts and withdrawals and any other details in relation to the services you have used through our Website.
        • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, and other technology on the devices you use to access the Site. and use of cookies stored on your device.
        • Profile Data includes your Customer’s account details, username and password, transactions made by you, your interests, preferences, feedback and/or information received through your interaction with us in the course of providing our services and survey responses.
        • Usage Data includes information about how you use the Site, products and services, date of registration, account category, business cluster, number of complaints, number of requests logged, and IP history.
        • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
        • Special Categories of Data/’Sensitive’ Data include details about your religious belief, annual income, biometric data and/or criminal convictions and offences.
        • Compliance Data includes details about your education, employment status, trading experience, and self-assessment test.
        • Bank Details include details of the number of payment wallets and/or your bank card information, including issuing bank information, card number, cardholder name, card expiry date, payment system, card validation code (CVV2/CVC2) and photos of both sides of the bank card.
        • Data in KYC (Know Your Customer) includes information from identity documents, including copies of recently dated utility bills, ID card, passport, and/or driver’s license.
        • Economic profile data includes details on occupancy, purpose of investment, annual return, net wealth, expected annual amount of investment, and sources of funds.
        • Location Data includes details about your actual location when interacting with our Site (e.g., a set of parameters that determine the regional settings of your interface, such as country of residence, time zone, and interface language).
        • Audio Data includes full voice recordings of calls you receive from us or make to us. (referred to collectively as Personal Data)
      3. Aggregated Data includes statistical or demographic data for any purpose. This data may be derived from your data, but it cannot be considered personal data by law, as it will not directly or indirectly reveal your identity. An example of such Aggregated Data could be that we aggregate your Usage Data to calculate the percentage of users accessing a particular site feature and/or service/product preference. Notwithstanding the foregoing, if OPTINARY combines Aggregated Data with data in such a way that the end result can somehow identify the data subject, OPTINARY will treat such combined data as data that will be treated in accordance with the provisions contained herein.

The processing of your data is carried out by OPTINARY following the principles of lawfulness, equity, transparency, and always adhering to the intended purpose of the data processing, the principle of data minimization, accuracy, limited data storage, data integrity, confidentiality and accountability.

In general, OPTINARY collects and processes Personal Data for any of the following reasons:


      1.  
        1. To perform the contract with you,
        2. To comply with its legal obligations, including, without limitation, applicable anti-money laundering and countering the financing of terrorism laws and regulations (hereinafter referred to as the Anti-Money Laundering Act) and/or
        3. o safeguarding its legitimate interest The Client acknowledges that all or part of the data relating to the Client’s account and related transactions will be stored by Digital Smart and may be used by the Company in the event of a dispute between the Client and the Company.

You are responsible for updating any data you provide to us in the event of any change. While we strive to keep your data up-to-date and review and inspect any information you provide, we may not always be able to do this without your help. The Customer acknowledges that Digital Smart assumes no commitment or liability to the Customer due to any review or inspection of information referred to above.


      1.  
        1. HOW IS PERSONAL DATA COLLECTED? We use different methods to collect data from and about you, including through:

Direct interactions. You will provide us with your identity, contact and financial details online through the Website and/or by filling out online forms and/or corresponding with us by email or otherwise. The data can be sent to us by you at any time you wish:

          1. Register for a trading account;
          2. Register for a demo account;
          3. Subscribe to our publications and ongoing updates;
          4. Request that marketing and promotions be sent to you;5. Participate in a competition, promotion, or survey; and/or
          5. Give us feedback or contact us.

We require the collection of the above data so that we can (i) provide our services efficiently, (ii) comply with our ongoing legal obligations, including, among other things, preventing acts of fraud and money laundering. If you do not provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may need to cancel a service you have with us, but we will notify you at that time if this is the case. It is important that the data we hold about you is accurate and current. Please keep us informed if your details change during your relationship with us. Automated technologies or interactions. When you use our services, your device automatically transmits its technical characteristics to us. Locale (a set of parameters that determine the regional settings of your interface, namely the country of residence, time zone and language of the interface) is used for the purpose of providing you with the best possible service within our platform. The use of information about IP address, cookie files, information about the browser and operating system used, the date and time of access to the website and the addresses of the pages requested allows us to provide you with optimal functioning in our web, mobile and/or mobile application. or desktop versions of our app and monitor your behavior for the purpose of improving the efficiency and usability of our Services. We use web analytics tools to track the performance of our website and users’ marketing source through cookies in order to optimize our marketing costs and provide users with a better experience. You may, at any time, request that we refrain from such transmissions (to the extent this is possible and subject to any of our legal obligations) by sending your request to the support team using our details at OUR CONTACT DETAILS below, using the registered email address that you have disclosed and registered with us through your account. We will respond to your request within 30 business days. About Cookies: A cookie is a small amount of data that usually includes a unique identifier that is sent to your computer or device browser from a website’s computer and is stored on your device’s hard drive to track your use of the website. A website may send its own cookie to your browser if your browser preferences allow it, but to protect your privacy, your browser only allows a website to access the cookies it has already sent to you, and not the cookies sent to you by other websites. . Many websites do this whenever a user visits their website to track online traffic flows. When you visit our website, our system automatically collects information about your visit, such as your technical data, including, but not limited to, your browser type, your IP address, and the referring website. Stored cookies can determine the path the Customer has taken on our website and are used to anonymously identify repeat users of the website and which pages were most popular with Customers. However, the Company protects the Client’s privacy by not storing the Client’s names, personal details, emails, etc. The use of cookies is an industry standard and is currently used by most major websites. Stored cookies allow the Site to be more user-friendly and efficient for Customers, allowing OPTINARY to know which information is most valued by Customers versus which is not. You can set your browser not to save any cookies from this website and you can also delete cookies automatically or manually. However, please note that by doing so, you may not be able to use all of the functions provided on our website in full. Please see our Cookie Policy for more details.

    1. We process the above-mentioned data in accordance with applicable law, as amended from time to time, in order to (i) be able to fulfill our contractual obligations to you and provide you with the best possible service, (ii) provide our Services efficiently, (iii) comply with our legal obligations, including but not limited to preventing fraud and money laundering,  and (iv) protect our legitimate interests and your vital interests.
    2. We process all data on the basis of the following legal basis:
      1. To comply with our legal obligations;
      2. For the fulfilment of our contractual obligations to you;
      3. For the purposes of safeguarding our legitimate interests and your interests and fundamental rights do not override those interests; and/or
      4. Based on your consent.
    3. For your indication, below is a description of all the ways in which we plan to use your data and which of the legal bases we rely on to do so. We also identify what our legitimate interests are, where appropriate. Please note that we may process the data for more than one lawful reason, depending on the specific purpose for which we are using your data.

PURPOSE ACTIVITY

DATA TYPE

LEGAL BASIS FOR PROCESSING, INCLUDING LEGITIMATE INTEREST BASIS

the

1. Agree to register you as a Customer

2. To notify you about changes to our terms or privacy policy

3. To communicate with you and provide you with secure identifications, authentication, and support services

4. To confirm that you are of legal age as recognized and declared by the laws of your jurisdiction

1. Identity data

2. Profile data

3. Contact details

4. Data in KYC

5. Financial data

6. Economic profile data

1. Necessary to perform our contract with you

2. Necessary to comply with our legal obligations

b

1. To carry out our Score Processing under which a Customer is scored on a scale in relation to the level of risk they pose to Digital Smart

1. Bank details

2. Economic Profile Data

1. Necessary to perform our contract with you

2. Necessary to comply with our legal obligations

c

1. To confirm the information provided by You in (a) above in relation to Your location.

1. Location data

1. Necessary to perform our contract with you

2. Necessary to comply with our legal obligations

d

1. Protect authentication, identification and support services through social media protocols and use the links to your social media accounts for these purposes.

1. Technical Data

1. Necessary to perform our contract with you

2. Necessary to comply with our legal obligations

and

1. To process and deliver your transactions and requests (Deposits; Negotiations; Withdrawals)

2. Manage payments, fees, and charges;

3. To collect and recover money owed to us.

1. Bank details

2. Transaction data

1. Necessary to perform our contract with you

2. Necessary for our legitimate interest (to recover charges owed to us, to make a withdrawal in case of breach of our contract)

f

1. To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting)

1. Identity data

2. Contact details

3. Technical Data

1. Performance of our contract with you

2. Necessary to comply with our legal obligations

3. Necessary for our legitimate interests (to take reasonable steps to confirm that you do not use any form of manipulation of our platform and to administer our business, provision of administration and IT services, network security, to prevent fraud)

g

1. To deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we serve to you

2. To provide you with optimal operation on our web application, mobile and/or desktop versions of our application and to monitor your behavior with the aim of improving the efficiency and usability of our services.

1. Identity data

2. Contact details

3. Profile data

4. Usage Data Technical Data

5. Marketing and communication data

1. Necessary to perform our contract with you

2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business)

h

1. study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy;

2. LEGAL LIMITATIONS

1. Transaction data

1. Necessary for our legitimate interests (including legal limitation provisions by applicable laws)

I

1. To inform you of any of the following:

— new services and/or products that we may offer;

— Any new development and/or features of the current products/services we offer

1. Identity data

2. Profile data

3. Contact details

4. Technical Data

5. Usage Data

6. Transactions

7. Marketing and communication data

1. Necessary to perform our contract with you

2. Necessary for our legitimate interests (to study how customers use our products/services, to develop our products/services, and to grow our business)

j

1. To send you direct marketing of our services always within the limits of our legitimate interests.

2. To send you newsletters, push messages and calls to keep you informed about our new features and new developments of the current products/services we offer, news and events and the efficient delivery of the full scope of our services. Please note that we will never use your data to communicate with you and/or promote any third-party marketing materials.

1. Identity data

2. Profile data

3. Contact details Data that may be provided by you during your activity on the Site. Marketing & Data Communications

1. Necessary to perform our contract with you

2. Necessary for our legitimate interests (to provide you with effective and personalised customer services and to update you in relation to our services available to you).

k

1. To enable us to provide you with optimal operation on our Site, mobile and desktop versions of our app and to monitor your behavior with the aim of improving the efficiency and usability of our Services.

2. Use analytical tools to monitor the performance of the Site and our Clients’ marketing source in order to optimize our marketing costs and provide you with a better experience.

1. Location data

2. Technical Data

3. Usage Data

4. Marketing and communication data

1. Necessary to perform our contract with you

2. Necessary for our legitimate interests (to provide you with effective and personalised customer services and to update you in relation to our services available to you).

I

1. To enable us to monitor and train our employees for your benefit

2. To safeguard your or our interests in the event of a dispute

3. To take measures to prevent fraud4. to improve the services provided to you

Audio data

1. Necessary to perform our contract with you

2. Necessary to comply with our legal obligations

3. Necessary for our legitimate interests

I

1. To confirm that your annual income corresponds to your employment situation.

2. To confirm that you have no criminal record.

Sensitive data

1. Necessary to comply with our legal obligations.

2. Necessary to protect your vital interests.

    1. If you are already a Customer of the Website where we have a legitimate interest in communicating with you, or if you have given us your consent, we will collect and process your personal data in order to communicate with you in case of support and/or sending you newsletters, push messages and calls to keep you in touch with our new features,  news and events and the efficient delivery of the full scope of our services. We will also use your data to send you marketing information about our services that we believe may be of interest to you by email or otherwise.
    2. Our website is not intended for children and we do not knowingly collect data relating to children. As we do not allow users under the age of 18 to use our services, we need to obtain their date of birth to confirm the verification of the age of Customers.
    3. OPT-OUTIf you do not want to receive any marketing newsletters or pass on your data to third parties for marketing purposes, you can configure your preferences. Such setting can be done by (i) opening an account or (ii) receiving such advertising content or (iii) logging in and accessing My Account > Personal Data > Notification Settings. You may also send the Company, at any time, an email to support@www.optinary.com using the registered email address that you have disclosed and registered with us through your Account, requesting the Company to stop sending you such advertising content or from sending your data to the third party for marketing purposes. Such removal of the trademark and/or e-mail received by OPTINARY will oblige us to cease sending advertising content to you within 7 (seven) business days.
    4. DATA DISCLOSUREWe may share your data with the parties for the purposes set out above.

We require all OPTINARY affiliated and/or related companies and any third parties processing data on our behalf to respect your data and treat it in accordance with the provisions of the General Data Protection Regulation and applicable local legislation, as amended from time to time. We take all reasonable steps to ensure that our third-party service providers do not use your personal data for their own purposes and only allow them to process your data for specified purposes and in accordance with our instructions.

In general, your data is used by OPTINARY’s processors.

    1. In addition, a transfer of your data to another legal entity may occur as part of a transfer of our business or parts of it in the form of a reorganization, asset sale, consolidation, merger or similar.

With regard to the transfer of data to recipients outside of the Company’s related entities and/or affiliates, we note that we strive to maintain discretion with respect to customer-related matters and assessments of which we have acquired knowledge. We may disclose data about you only if (i) we are legally required to do so; (ii) if necessary where you expressly order us to process a transaction or any other service and (iii) is necessary for the provision of our services under our contractual relationship and/or (iv) protection of our legitimate interests and applicable law as amended from time to time.

External Third Parties. Your data is shared with third-party organizations/entities, including but not limited to:

      1. Service Providers. We may share your data with our trusted third-party service providers, who, on our behalf, operate, maintain and/or support our IT systems and IT infrastructure, our websites, manage our payment solutions, perform statistical analysis, marketing and advertising purposes, send newsletters, provide customer support and perform other services important to us.
      2. Other OPTINARY affiliates/related companies. We may also disclose your data to other OPTINARY affiliates and/or related companies in order to provide us with the relevant services.
      3. State authorities. The Client’s data that is provided and/or that will be provided by the Client during his/her activity on the website may be disclosed by the Company to the official authorities. The Company will make such disclosure only if required by the Company by applicable law or court order and to the minimum extent required.
      4. Other Disclosures. In addition to you having consented to the disclosure of the data or where disclosure is necessary to achieve the purpose(s) for which it was collected, the data may also be disclosed in special situations where we have reason to believe that doing so is necessary to identify, contact or initiate legal action against any person who harms it,  harms or interferes (intentionally or unintentionally) with our rights or property, users, or any other person who may be harmed by such activities, or otherwise where necessary for the establishment, exercise, or defense of legal claims.

Where reasonably possible, management will ensure that third parties who collect, store or process personal information on behalf of the Company have:


      1. Agreements signed to protect personal information consistent with this Privacy Policy and information security practices or measures implemented as prescribed by applicable laws;
      2. Signed non-disclosure agreements or confidentiality agreements that include privacy clauses in the contract; and
      3. Procedures set forth to comply with the terms of your agreement with third parties to protect personal information.

Corrective actions will be taken in response to misuse or unauthorized disclosure of personal information by third parties collecting, storing or processing personal information on behalf of OPTINARY.

If you would like further information about any data transfers mentioned above, please contact us using the registered email address you disclosed and registered with us through your account through the contact points listed in the OUR CONTACT DETAILS section below.

    1. DATA RETENTIONWe keep your data for as long as reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for your data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your data, and whether we can achieve them. purposes through other means, and applicable legal, tax, accounting, and other requirements.

We will retain your data (including call recordings) for the duration of our contractual relationship and for a minimum period of 7 (seven) years from the date of termination of the Platform/Service used by the Client.

In general, all other data is stored for a period of 30 (thirty) working days after the date of cessation of the provision of our services, unless there is any other legal reason for its retention.

At the end of the data retention period, the data is erased by irreversible destruction and we also inform all third parties to whom the data has been transferred about such deletion and request the implementation of similar actions on their part.

    1. YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBEWe must provide us with true, accurate and up-to-date information about your identity and not falsely represent yourself as another person or entity. Any changes to your identification data will be notified to the Company immediately and in any event no later than the 7th day from the date of such changes. If your details are incorrect or incomplete, please contact our support services using the contact details in the OUR CONTACT DETAILS section below to change your details.

Under certain circumstances, you have rights under applicable law and our policies, as amended from time to time. Some of the rights are quite complex and include exemptions, so we strongly advise you to contact us (via the contact details listed in the OUR CONTACT DETAILS section below). You can find a summary of your rights below in this section.

      1. The right of access. You have the right to obtain confirmation as to whether or not your data is being processed by us. In addition, you have the right to obtain more detailed information about the data held and the processing carried out by us and, in certain circumstances, the right to receive a copy of that data. To access and view your data without downloading it, please go to ‘Access my data’ in your personal area, accessing your Account, access Personal Data and at the bottom of the page you can proceed with your request, selection – Access my data. In addition, you have the right to obtain more detailed information about the data held and the processing carried out by us and, in certain circumstances, the right to receive a copy of that data.
      2. The right to rectification. You have the right to have inaccurate data about you rectified and, taking into account the purpose of the processing, to have incomplete data completed.
      3. The right to erasure. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. To delete your account and all personal data currently stored in our system, you can do so by logging into your account, go to – Personal Data section and then Account Settings and at the bottom of the page you can proceed with your request by selecting- Close Account – Delete my account and all your data. Please note, however, that we will not always be able to comply with your deletion request for specific legal reasons that will be notified to you, if applicable, at the time of your request. If you wish to obtain complete erasure of your data (to enforce the “right to be forgotten”), please note that we may not always be able to comply with your erasure request for specific legal reasons which will be notified to you, if applicable, at the time of your request.
      4. The right to restriction of processing. You have the right to request the restriction of the processing of your personal data (a) if it is not accurate; (b) where the processing may be unlawful but you do not want us to erase your data; (c) where you need us to keep the data, even if we no longer need it; or (d) where you may have objected to our use of your data but we need to verify that we have legitimate grounds to use it.
      5. The right to data portability. To the extent that the legal basis for the processing is your consent, and such processing is carried out by automated means, you have the right to receive your data in a structured, commonly used and machine-readable format. However, this right does not apply where it may adversely affect the rights and freedoms of others and/or where it is technically impossible to do so.
      6. The right to object. Subject to the legal basis on which the processing activity is based, you may object to the processing of your personal data. Please note that in some cases, we may have compelling legitimate grounds to process your information, which we need to comply with.
      7. The right to withdraw consent. To the extent that the legal basis for processing is your consent, you have the right to withdraw that consent at any time. This may apply for marketing purposes and/or with regard to the transfer of your data to third parties. In the event that you withdraw the consent you have given, we will cease processing your data unless and to the extent that continued processing is permitted or required under the applicable data regulation or other applicable laws and regulations. The withdrawal of your consent will in no case affect the lawfulness of the processing based on consent prior to its withdrawal.
      8. The right to complain to the data protection supervisory authority. We do our best to ensure the protection of your data, keep you informed about how we process your data, and comply with applicable data protection regulations. If you are not satisfied with the treatment and protection of your data or the information you have received from us, we ask you to inform us so that we can improve. Please also do not hesitate to contact us if you want to make use of your rights.

If you wish to exercise any of your rights mentioned above and/or obtain further information about your rights and/or our policies and procedures, please contact us via the contact points listed in the OUR CONTACT DETAILS section below. Please also provide us with relevant information to fulfill your request, including your full name and email address so that we can identify you. We will respond to your request without undue delay.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who does not have a right to receive it. We may also contact you to request further information in relation to your request in order to expedite our response.

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

We may charge you a reasonable administrative fee for any unwarranted or excessive requests we may receive and for any additional copies of the data you may request.

    1. DATA SECURITYI have implemented appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your data to those employees, agents, service providers and other third parties who have a business need to know it. They will only process your data in accordance with our instructions and are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you of a breach where we are legally required to do so.

Your help is always invaluable to ensure that your data is kept safe. When registering on the Site (or its mobile version), the Client will be asked to choose a username and password to be used by the Client for each future login and for carrying out transactions and using the Company’s Services. In order to protect the Customer’s privacy and operation with the Site, it is strictly prohibited to share registration details (including, without limitation, username and password) by the Customer with other persons or business entities. The Company shall not be liable for any damage or loss caused to the Client due to the misuse (including prohibited and unprotected use) or storage of such username and password, including any use made by any third party, and whether known or not known or authorized by the Client.

Any use of the Site with the Customer’s username and password is the sole responsibility of the Customer. The Company shall not be held liable for such use, including validation that the Client is actually operating on their account.

The Client is obliged to immediately notify the Company’s customer service of any suspected unauthorized use of the Client’s account. You can contact us at any time through the contact points listed in the OUR CONTACT DETAILS section below.

Encryption of your data in transit. Encryption provides a high level of security and privacy for your data. When you enter your data into our platform, we use strong encryption technologies (such as Transport Layer Security) to protect your data during transmission from your devices to our servers.

To provide more trust and security, we use digital Extended Validation (EV) Certificates issued by trusted Certificate Authorities. You can see the ‘Green Bar’ on supported browser versions, which confirms that all transmitted data is secure.

Protection of your data in our infrastructure. We prioritize developing services that are secure “by default.” The “standard” security of our services means that all new services and features are designed with strict security requirements in mind before we even start development. This is the key to ensuring the protection and privacy of all the data that our services process and store once the service or new feature is launched.

To protect your data, we use pseudonymization which allows most of our services to function without using your actual data. Instead, our services use a system ID that cannot be traced to identify you.

The Company is always attentive to the security of your data stored in our infrastructure. That is why we locate all our equipment that is used for the processing of your data in secure data centers. This machine’s network access is isolated from the Internet. We use network segmentation to isolate services that require different levels of security from each other. In addition, we restrict logical access to your data to our employees on a “need-to-know” basis. Thus, only those personnel who really need access to your data in order to provide you with the best service will have access to them.

Threat protection. Our Company has great knowledge about modern threats to data security and privacy and we are well prepared to combat them. All events that occur in our infrastructure are continuously monitored, analysed and responded to, which allows us to ensure the proper protection of your data, keeping it safe from threats, vulnerabilities and the effects of malware.

In the event of a failure that affects the accessibility of your data, we have data backup and recovery procedures that will help us restore your data in a short time. To ensure fast recovery, we use high availability mode enabled for most critical databases, which allows us to minimize downtime.

Employee awareness of data security. Our employees will be able to process your data to provide you with a first-class service. To ensure the security and confidentiality of your data, we monitor all actions of employees with access to your data on our systems and grant access strictly on a “need to know” basis: only employees who need access will receive it. We conduct regular training sessions to ensure that each employee understands the principles the Company follows to achieve robust data security and privacy.

If you choose not to provide your personal information. In the context of our business relationship, we may need to collect data by law or under the terms of a contract we have with you. Without this data, in principle, we will not be in a position to enter into or perform a contract with you.

If you choose not to provide us with this data, it may delay or prevent us from fulfilling our obligations. It may also mean that we are unable to perform the services necessary to administer your accounts or policies.

The extent to which we carry out automated decision-making and profiling. When establishing and conducting a business relationship, we generally do not use automated decision-making. If we use this procedure in individual cases, we will inform you about this separately. In some cases, we may create profiles to evaluate certain personal aspects. We will inform you accordingly if we carry out any profiling. In general, any optional data collection would be clarified at the time of collection.

    1. OUR CONTACT DATAWhen you have any questions about this privacy policy, including data-related requests, please contact our support team using the details below.

The entity responsible for the processing of your data is OPTINARY and you can contact us using the details below.

Email: support@optinary.com. In order for us to process your request, please contact us using the registered email address you disclosed and registered with us through your account. We may require you to provide us with proof of your identity, such as a copy of a valid ID. This is to ensure that we adequately protect the personal data we hold against requests for unauthorised access and comply with our security obligations. If you have any questions or would like more details about how we use your data, you can contact us using the contact details above and we will be happy to provide you with further details.

    1. LINKS TO OTHER SITESWe may provide links to third-party websites on our Site. These linked sites are not under our control and therefore cannot accept responsibility or liability for the conduct of third parties linked to our sites, including, without limitation, the collection or disclosure of your data. Before disclosing your data on any other website, we encourage you to review that website’s terms and conditions of use and its privacy policies.
    2. CHANGES TO THIS PRIVACY POLICY
    3. This Privacy Policy was last updated on October 16, 2023. We reserve the right, at our discretion, to add, modify or remove portions of this Privacy Policy in the future to ensure that the information contained herein provides relevant and adequate information about our collection and processing. of your data.
    4. This privacy policy may be supplemented by other information received from the OPTINARY group and other terms and conditions applicable to the Site or to which you have agreed as part of your interaction with us.
    5. In case of updates, we will post the revised Privacy Policy on our website. The changes will be effective as soon as the revised version is made available on our website. Your comments and feedback are always welcome. You can contact us at any time through the contact points listed in the OUR CONTACT DETAILS section above.

 

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