SPN Securities LLC (hereinafter the “Company” or “we” or SPN or “us”). This Privacy Policy explains the way SPN collects, uses, and manages personal information from its active clients and potential clients. SPN is committed to safeguarding your privacy. By opening a trading account with us, the consumer gives consent to such collection, processing, storage, and use of personal information by SPN as illustrated below.
It is the Company’s policy to consider the confidentiality of the data and the privacy of individuals.
This Privacy Policy intends to give you information on how we handle and process your data, including any data you may provide through our website when you sign up.
You must read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy extends the other policies, and it is not intended to revoke them.
At SPN we understand the importance of keeping the confidentiality of our customer's personal information and are dedicated to securing the security of any information provided by our users through this website.
SPN's Privacy Policy Statement will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices, and to make sure it remains fit to the changing environment. Any information we hold will be governed by the most current Privacy Policy Statement. The revised Privacy Policy will be uploaded to the SPN website. In this respect, clients agree to accept the posting of a revised Privacy Policy electronically on the website as the actual notice of SPN to its clients. If any of the changes made are of material importance then we will notify you by email or using a notice on the home page. Any debate over SPN Privacy Policy is subject to this notice and the Client Agreement. SPN supports its clients to regularly review this Privacy Policy so that they are always aware of what information SPN collects, how it uses it and to whom it may disclose it by the provisions of this policy.
To provide financial products and services to our clients efficiently and accurately, when you apply to register to use one or more of our services we will ask you for personal information. SPN holds the right and the duty by the business activity performed, to check the accuracy of the data reserved in the databases by occasionally asking you for updated data provided or for a confirmation of the accuracy of the aforementioned.
The type of personal information we may collect can include (but is not limited to):
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used following this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic, and biometric data).
We may also gather certain information about your use of our services. This may include information from which you and/or your company can be identified such as the times you log on, your volume of use of the services, the types of data, systems, and reports you access, the locations from which you log on, duration of sessions and other similar data. The information collected may be also lawfully obtained from third parties, such as public authorities, companies that have introduced you to SPN card processing companies, as well as publicly available sources that we are lawfully permitted to process.
Your electronic and/or telephone communication with us is recorded and it is the sole property of FXCC SPN and constitutes proof of communication between us.
You have a choice to provide any or all of the personal information required. However, missing information may result in our being unable to open or maintain your account and /or to provide you with our services.
We gather processes and manage the information which allows us to perform our contractual obligations with you and to be compliant with our legal obligations.
We process your data to provide you with our services and products, and to be able to complete our acceptance procedure to enter into a contractual relationship with our clients. To complete our client onboarding we need to verify your identity, perform the customer due diligence as per the regulatory obligations, and we need to use the acquired details to effectively manage your trading account with us.
Several legal obligations are imposed by relevant laws to which we are subject, as well as statutory requirements, e.g. anti-money laundering laws, financial services laws, corporation laws, privacy laws, and tax laws. In addition, there are various supervisory authorities whose laws and regulations apply to us, which impose necessary personal data processing activities for credit card checks, payment processing, identity verification, and compliance with court orders.
SPN processes personal data to safeguard the legitimate interests pursued by us or by a third party, where the legitimate interest is when we have a business or commercial reason to use your information. Nevertheless, it must not go unfairly against you and what is best for you. Examples of such processing activities include:
Initiating court proceedings and preparing our defense in litigation procedures; means and processes we undertake to provide for the Company’s IT and system security, preventing potential crime, asset security, admittance controls, and anti-trespassing measures; measures to manage the business and for further developing products and services; Risk management.
It may be required to process your data for internal business and record-keeping purposes, which is in our legitimate interest and is required to comply with our legal obligations. We will also keep records to ensure that you comply with your contractual obligations according to the agreement governing our relationship with you.
Occasionally, the law requires us to advise you of certain changes to products and/or services or laws. We may need to inform you of the changes related to our products and services, therefore we will be obliged to process your personal information to send you the legal notifications. You will continue to receive this information even if you opt not to receive direct marketing information from us.
We may use your data for research and analysis purposes, and your trading history to deliver any analysis, reports, campaigns that may interest you to your registered email address. Please note that you always have the right to change your option in case that you do not wish to receive such communications any longer.
If you do not want us to use your personal information in this way, please send an email to [email protected] asking not to be contacted for any marketing purposes.
We may use the personal information provided by you to ensure the highest standards when providing our products and services.
The main purpose we use your personal information for is to enable us to understand your financial objectives and ensure that relevant services are appropriate to your profile. Further, this information helps us to provide quality services. While we may send you marketing material (including but not limited to SMS or email communication for you to view, margin calls, or other information) from time to time that we think will be useful to you, we are conscious of the need to respect your privacy. Unless you are informed otherwise, the personal information we hold is used for establishing and managing your account, reviewing your ongoing needs, enhancing customer service and products, and giving you ongoing information or opportunities that we believe may be relevant to you.
SPN will not disclose your personal information without your prior consent. However, depending on the product or service concerned and particular restrictions on sensitive information, this means that personal information may be disclosed to:
Service providers and specialist advisers to SPN who have been contracted to provide us with administrative, financial, insurance, research, or other services.
Introducing brokers or partners with whom we have a mutual relationship (any of whom may be within or outside the European Economic Area) Credit providers, courts, tribunals, and regulatory authorities as agreed or authorized by law Credit reporting or reference agencies, third authentication service providers, fraud prevention, anti-money laundering purposes, identification or due diligence checks of the client Anyone authorized by an individual, as specified by that individual or the contract To an Affiliate of the Company or any other company in the same group of the Company.
In case such disclosure is required to be made by law or any regulatory authority, it will be made for SPN to comply with any legal obligations, protect itself from potential fraud, and maintain service provider agreements. In case such disclosure is required, it will be made on a need-to-know basis unless otherwise instructed by the regulatory authority. Generally, we require that organizations not under SPN who handle or obtain personal information as service providers to SPN acknowledge the confidentiality of this information, undertake to respect any individual's right to privacy and comply with the Data Protection Principles and this policy.
In some circumstances, we may pass on information to third parties if we are legally required to do so or if we are authorized under our contractual and statutory obligations, or if we have been provided your consent.
We may also disclose your personal information to third parties if we are under a duty to disclose or share your data to comply with any legal obligation or to enforce or apply our Site Terms and Conditions.
By submitting your information, you consent to the use by SPN of that information, as set out in this policy. By accessing and using this you are acknowledging that you have read, understood, and agree with this privacy policy. We reserve the right to change our privacy policy from time to time and will update this page accordingly. Please review our policy as often as possible – your continued use of the Site will signify that you agree to any such changes.
The Site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites may have their privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You can withdraw your consent at any time. However, any processing of personal data before the receipt of your revocation will not be affected.
By legislation, we are required to respond to any personal data requests within 30 days, unless the type of request requires more time for investigation and assessment. The rights that might be available to you concerning the personal information we hold about you are outlined below:
Receive access to your data. This enables you to receive a copy of the personal data we hold about you. Request rectification/correction of the personal data we hold about you. This enables you to correct any incomplete or inaccurate data we hold about you. We may request additional information and documentation required to validate the need for the requested change of data.
Request erasure of your personal information. You can ask us to erase your data, exercising your right “to be forgotten”, where there is no good reason for us continuing to process it. This request to erase your data will result in the closure of your account and the termination of the client relationship.
Request to ‘block’ or suppress the processing of your data in certain circumstances, such as if you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information. We will inform you before we decide not to agree with any requested restriction. If we have disclosed your personal information to others, we will inform you about the restriction if possible. If you ask us, if possible and lawful to do so, we will also tell you with whom we have shared your personal information so that you can contact them directly.
Have the right to object to your data being processed for direct marketing purposes. This also includes profiling as much as it is related to direct marketing. If you object to processing for direct marketing purposes, then we shall stop the processing of your data for such purposes. Object, at any time, to any decisions that we may take that are purely based on automated processing (including profiling). Profiling involves the use of technology that helps us make decisions automatically, based on the personal data that we collect from you or third parties.
You will not have to pay a fee to access your data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within 24 hours. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
We endeavor to ensure the protection of the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical, and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection, and other access and authentication controls.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us.
SPN may store your information in its databases for reference to answer queries or resolve problems, provide improved and new services and meet any legal data retention requirements. This means we may retain your information after you stop using the Site or our services or otherwise interacting with us.