Privacy Policy
Last modified on: 19/07/2024
The Privacy Policy govern the utilization of the independent platform (referred to as “Platform”) linked to www.VTFXtrading.com (“Website”) under the VTFX brand (“We, “Us” “Ours”), by any User (referred to as “You” or “Your”). We operate as an independent platform and website under the VTFX brand. For the purposes of this document, “VTFX” refers to:
- VTFX :Executive Suites, Upper Floor, Novo House building, Port Vila – Republic of Vanuatu.
This Policy is of utmost importance. We want to ensure that You feel secure when visiting Our Website and using Our services, as well as in all Your interactions with us. When You use Our products and services, You trust Us with Your personal information. Our aim is to provide you with the best experience on Our platform and to continuously improve it. To do this, We need to understand how You interact with Our Platform.
In this Policy, we aim to be transparent about what personal data We collect from You, why We collect it, and who might have access to it. We’ll also explain the measures we take to safeguard Your personal information, outline Your rights in this context, and provide information on who You can contact for data protection concerns.
This Policy covers the collection, processing and other use of personal data under the applicable data protection regulations. This Policy is available in English language.
We are fully compliant with all relevant data protection laws and regulations. We are committed to handling Your personal data with integrity, ensuring that Our processing of Your information is fair, lawful, and transparent.
Our Policy together with our Terms and Conditions and any other documents referred to in it details how we protect and process Your data. By using our Platform, registering with us or submitting information to us You signify that You have read and understood Our collection, use and disclosure of Your personal data in accordance with this Policy. If You do not agree with this Policy, You must not use our Platform, access our services or submit information to us.
1. Applicability: To whom does this Policy apply?
1.
1 This Policy applies to anybody who visits
the Platform, who may or may not use our dedicated services.
1.2 If You started registration for use of
our products and services available in our Platform (created Account) and You are using
them, this Policy is applicable to You, regardless of if You are:
1.2.1 Individual user (“Individual
Users”)
1.2.2 Individual whose Personal Data is
processed within the scope of activity of legal entity (e.g., authorized representatives,
ultimate beneficial owners) (“Corporate Users”).
1.2.3 Term “User” refers to both Corporate
Users and Individual Users.
2. Collection and use of information
2.1 When You open an account via Our Platform, we require You to provide Your personal information in the account opening form. This may involve personal details such as your name, address, email address, phone number, and date of birth. In every case, it is essential for you to provide us with this information to establish a contract with us, allow us to deliver our services to you, and meet our legal responsibilities. If You do not provide us with the required information, we shall not be able to offer You, our services.
2.2 When using Our Platform’s services or interacting with our Platform, the following personal data might be processed:
2.2.1 Contact and general account creation data: when
creating a new User account or communicating with the Platform, we might process for
example: name, address, telephone number, email, date of birth, photo for the account,
etc.
2.2.2 Marketing data: if You visit our
Website, we might process statistical and marketing data for example: the number of
visitors, frequency, clicks, time, places, target groups, data from cookies and similar
technologies, consumer’s behavior, interests and preferences, data about market research and
target groups surveys, etc.;
2.2.3 Log data on the Website: e.g.: IP
address, transaction data, deposit and withdrawal address, computer or mobile device
information, frequency, time, operating system, browser type, device type, unique device
identification number, identification cookies optionally form data, crash reports,
performance data, third-party cookies, etc.
2.2.4 Any other information we consider
necessary to our functions and activities.
2.3 We utilize Your personal information for the following purposes:
2.3.1. Processing Your account registration and
helping You manage Your account.
2.3.2. Processing Your trades and
transactions.
2.3.2.1. To facilitate transactions (Your
information, whether public or private, will not be sold, exchanged, transferred, or
otherwise provided to any other company on any grounds without Your consent, except for were
doing so is expressly for the purpose of completing the transaction) You require or
performing any contract or our legitimate interests.
2.3.2.2. Assisting You with any queries about
our products and services
2.3.2.3. Providing You with advertising
communications and notifications about Your account and our services.
2.3.2.4. Fill in all the legal and regulatory
obligations that we have, including licensing requirements, anti-fraud requirements, and
anti-money laundering laws.
2.3.2.5. Analyzing user trends to identify
how we can improve our products and services.
2.3.2.6. Verifying that You are the
legitimate account owner and proper recipient of withdrawal payments.
2.4 Any other relevant requirement that comes under contractual necessity and legitimate interests needs.
2.4.1. We reserve the right to ask You for further
information whenever needed. For example, we may ask You to send us additional acceptable
documents to confirm the authenticity of Your account details or any withdrawal
request.
2.4.2. You agree that when You use the Live
Chat feature on Platform and other relevant applications, all personal information that You
enter in the chat channel, including but not limited to Your first name and email address,
is processed by us and stored in our databases.
2.4.3. We hold all the personal data that we
collect from You with due diligence and only process it for purposes that are required or
allowed by law. This includes, but is not limited to, obtaining, and sharing certain
information with third parties for credit or identity checks to follow legal and regulatory
obligations. In some cases, we may process Your data so that we can carry out our
obligations to You.
2.4.4. You may update Your personal
information at any time by logging in to the Settings section of Your account. It is Your
responsibility to make sure that we are immediately informed of any changes to Your personal
information. Please be aware that providing Us with inaccurate information or failing to
update Your information may impact the quality or availability of Our services offered to
You.
2.4.5. We utilize your personal data to
communicate with you regarding our services, including administrative or account-related
information. These communications may include updates on relevant security issues, service
updates, or transaction-related details. These updates are crucial for keeping you informed
about developments that may affect your account usage. Please note that you cannot opt out
of receiving essential service communications, such as emails or mobile notifications
necessary for legal or security reasons.
2.4.6. We shall Process Your data when it is
necessary for the performance of a contract of which You are a party. Processing personal
data might be necessary for the performance of the contract with You or in order to take
steps at Your request prior to entering into a contract. The following data processing
operations, including but not limited to, for example, are covered by such contractual
obligations:
- 2.4.6.1. general performance of our services, all tasks necessary for Our operation, performance and administration and Platform.
- 2.4.6.2. account management (e.g., continuous updating of User data);
- 2.4.6.3. Users service and support request; (e.g., contacting because of complications) analysis and improvement of the Platform’s quality and the general User.
2.4.7. We process Your personal data to enhance
security, monitor and verify identity or service access, combat malware or security risks
and to comply with applicable security laws and regulations. We process your personal data
to authenticate accounts and associated activities, identify and address breaches of our
Terms and Conditions, investigate suspicious activities, prevent and combat unlawful
behavior, detect fraud, and safeguard the integrity of our services
2.4.8. We may transfer relevant personal and
financial data to anyone with Our company where it is necessary for the performance of a
contract with You related to our services. We shall also use or transfer Your personal data
to pursue our legitimate interests.
3. Profiling and categorization
3.1 We retain the right to utilize the data we collect and evaluate from You for profiling purposes related to our products. We do this manually with the assistance of automated processing. In this way, We shall be able to provide You with the most appropriate products and services.
4. Transfer of data
4.1
We may transfer relevant personal data to within the company
where it is necessary for the performance of a contract with You related to our
services.
4.2 We may need to transfer your personal
data to our business associates, servers, or payment providers within or outside the
European Economic Area (EEA). This includes countries that may not provide an equivalent
level of personal data protection, for the purpose of processing by third
parties
4.3 We may also transfer Your data to
third parties outside the EEA for content delivery services, server services, customer
relationship management services, and communication and marketing services.
4.4 In all the aforementioned cases, we
undertake all reasonably necessary measures to ensure that your personal data is handled
securely and in accordance with this Policy, and in compliance with applicable data
protection laws. These steps may include placing a contractual obligation on third parties
or ensuring that third parties receiving Your data are certified under an approved
certification mechanism.
5. Access to data
5.1 If a legal requirement, court order, or directive from a governmental or law enforcement agency mandates the disclosure of Your personal or financial details, we will promptly inform You when appropriate unless any applicable law prevents such disclosure. Such a disclosure will not be considered a violation of these terms and conditions.
6. Data retention
6.1 We’ll keep Your data on file for as long as Your Platform account remains active. Following account closure, we may hold onto Your data for the relevant period to fulfill legal and regulatory requirements or legitimate business needs. This time limit will not exceed the longest of the following:
- 6.1.1. Retention periods mandated by relevant laws, such as tax, financial, anti-money laundering regulations, etc.
- 6.1.2. The time needed to fulfill any contractual obligations we have with You.
- 6.1.3. The period necessary to satisfy our legitimate business interests, such as defending potential legal claims, etc.
- 6.1.4. Once the aforementioned retention period expires, Your data will be securely deleted.
- 6.1.5. We’re committed to transparency regarding Your data. If You have any questions about data retention or wish to inquire about the deletion of Your information, please don’t hesitate to contact us.
7. Your rights
7.1 Listed below are Your legal rights pertaining to Your personal data. However, please note that not all of these rights may be relevant to You at all times:
7.1.1 Right of Access: You can request and obtain a copy of the personal data we have about You.
7.1.2 Right of Rectification: You have the right to ask for the correction of any inaccurate or incomplete personal data we hold about You.
7.1.3 Right to Erasure: You have the right to request the deletion of your personal data once it is no longer required for the purposes for which it was collected. However, please note that the right to erasure is not absolute. We have to comply with retention requirements set out in any applicable laws, including financial regulations and anti-money laundering laws. We must also retain Your data to ensure contractual necessity and our legitimate interests.
7.1.4 Right to Restriction and Objection: You can limit or object to our processing of Your personal data subject to our rights under applicable data protection laws.
7.1.5 Right to Data Portability: You can request Your personal data in a digital format and, if feasible, have it transferred to another organization. We may impose a “reasonable fee” to cover administrative expenses associated with fulfilling requests deemed manifestly unfounded or excessive.
7.1.6 Right to withdraw: You have the right to at any time withdraw Your consent for processing, upon which we will stop processing Your personal data based on this legal basis unless a different legal basis is applicable. The withdrawal does not affect the lawfulness of processing Your personal data based on any other applicable legal basis like legitimate interests, contractual necessity, etc.
7.1.7 Right to not to be subject to automated decision-making: We do not use personal data for automated decision-making prohibited in data protection legislations including unlawful profiling (e.g., decisions producing legal effects concerning data subjects, or otherwise, significantly affecting them, based solely on automated processing of personal data, including profiling).
7.1.8 Right to Lodge a Complaint with a Supervisory Authority: You have the right to complain with a supervisory authority if You believe we have not processed Your personal data in accordance with the law.
7.1.9 Requests and Complaints
- 7.1.9.1 You can make any of the requests set out by contacting us at
- 7.1.9.2 If You are not satisfied with how we have handled Your personal data, You may file a complaint with us. If You are not satisfied with the outcome of our internal complaint procedure, or if You consider that Your complaint has not been handled correctly, You may lodge a complaint with our Data Protection Officer at
- 7.1.9.3 We shall try to respond to all legitimate requests from Users within 1 (one) month. Occasionally, it may take us longer than 1 (one) month if Your request is particularly complex or You have made a number of requests. In this case, we will send you a notification within 1 (one) month of the receipt of Your request citing the reason for the delay and we will action Your request within 1 (one) month of issuing the said notification.
- 7.1.9.4 If Your request is clearly unfounded, repetitive or excessive we may charge a reasonable fee or refuse to comply with Your request.
8. Marketing
8.1 You can choose not to receive marketing materials from us. You can do this by either declining to give consent when creating an account or by withdrawing Your consent at any time while Your account is active. In either situation, we will stop sending You any marketing materials.
9. Security Statement
9.1 Your personal data and transactions are secured by Us through the implementation of the following measures:
9.1.1 Your password and login ID are unique, and passwords are hashed to prevent access by unauthorized personnel, including our staff. Therefore, we are unable to retrieve your password if forgotten. Instead, we will provide you with a link to reset your password independently.
9.1.2 All credit card details are securely transmitted directly to the Visa/Mastercard network using current SSL encryption technology, adhering to bank policies.
9.1.3 Access to Your personal data is strictly prohibited for all Our staff, except for key personnel only in circumstances where this is required for the proper performance of their duties.
9.1.4 Our information security policies are based on industry best practices in access control and business continuity.
9.1.5 On a best-effort basis, we try to verify Your identity and implement measures to detect fraud to help protect You from unauthorized access to Your account. Further We monitor Your account for signs of unusual activity that might indicate fraud. We work with collection and law-enforcement agencies in case of fraud issues.
9.1.6 It is Your responsibility to maintain the security of Your login details, any linked email address, and any personal computer or device on which Your account is accessible (for example, by password protection, or screen locking). We are not liable for any unauthorized use of Your account when we are not at fault.
9.1.7 Whether You use a shared device or Your device in a public place either offline or on public Wi-Fi, doing so might put the information that You enter or receive in danger of being captured. To protect Your data in such cases, it is solely Your responsibility to take the following precautions and educate Yourself on other security measures You can take:
- 9.1.7.1 Please refrain from sending or receiving private information unless you are using a secure webpage, ideally through a secure and encrypted Virtual Private Network (VPN).
- 9.1.7.2 Make sure that You have effective and updated antivirus/antispyware software and firewall running before You use public Wi-Fi.
- 9.1.7.3 Do not leave Your device unattended.
- 9.1.7.4 Avoid using financial transactions that might disclose passwords or personal information such as credit card numbers.
- 9.1.7.5 Use the browser tools to erase files and cookies and regularly clear Your browsing history.
- 9.1.7.6 Avoid saving Your login credentials on a shared device.
- 9.1.7.7 Log out of account-based Websites at the end of the session.
- 9.1.7.8 You must notify us as soon as You become aware that Your login details have been compromised (lost, stolen etc) or otherwise disclosed to third parties.
10. Cookies and related technologies
10.1 Cookies are small text files stored on computer drives and are widely used to improve Website functionality and user experience. All recent versions of browsers give You a level of control over cookies. Our Website uses cookies as detailed under our Cookie Policy, You may delete cookies that are already on Your computer, and the browser can be set to prevent them from being placed. You can adjust the cookie preferences and also choose not to accept our cookies. Choosing not to accept our Cookies may affect the quality and usability of the products and services that We offer to You. You can read more about our Cookie Policy on Our Website .
10.2 In addition to cookies, we may also use other similar technologies on our Websites, such as web beacons and pixels to help us customize our Websites and improve Your experience. Web beacons and pixels usually take the form of a small, transparent image that is embedded on the Website or in an email. They are used to track the number of users who have visited pages and acquire other statistical data. They collect only a limited set of data, such as cookie number, time, and data of the page viewed, and a description of the page on which they reside.
10.3 To provide You with a better experience, some of our services may require permission to access Your cloud storage services, such as Google Drive, to save or load bot trading strategies. In such instances
10.3.1 Data related to Your cloud storage service
are not stored by Us on any servers. All files are downloaded on Your local
machines.
10.3.2 We do not share any data related to
Your cloud storage service with anyone.
10.3.3 We only access Your cloud storage when
Your action initiates it. You can disconnect Your cloud storage service at any
time.
11. Links to other Websites
11.1 Our website includes links to other websites and may feature banner or icon advertisements linked to third-party websites. These Websites and their advertisements may submit cookies to Your web browser, which is beyond our control. We are not responsible for the content or privacy practices of such Websites. We encourage You to read the Privacy Policies or Cookie Policies of these Websites because their practices may differ from ours.
12. Amendment
12.1 We may amend this Policy sometimes. When we amend this Policy, we will modify the date listed on this Agreement or we may contact You. You will have to agree to the amendments as a condition for Your continued use of our Platform. If You do not agree, You must immediately cease using our Platform and notify us of Your refusal to agree by contacting us at
13. Policy Review
13.1 This Policy is subject to periodic review and may be updated sometimes. We will notify You and staff of any significant changes.
14. Accessing, Editing, and Removing Your Information
14.1 Upon creating an account, You will be able to access and edit Your information through the login dashboard. Please be aware that although You will be able to access and edit Your information, You will not be able to opt out of our data collection practices unless the same is mandated by law or as per the requirements identified in this Policy.
14.2 We retain Your Personal Information as long as You maintain an Account on the Platform. We shall cease to retain Your Personal Information, or remove the means by which Your Personal Information can be associated with you, as soon as it is reasonable to assume that;
- 14.2.1 the reason for which Your Personal Information was collected is no longer being served by its retention,
- 14.2.2 retention is no longer necessary for legal, accounting for business purposes and
- 14.2.3 no legal basis for processing the data exists including legitimate interests, contractual necessity, legal compliance, etc.
14.3 Please be aware that specific laws may mandate us to retain records of transactions or accounts for a designated period.
15. Staff Training
15.1 We are committed to:
15.1.1
Familiarizing our staff with our internal policies on the
collection and processing of confidential information and;
15.1.2
Our staff members are prohibited from sharing confidential
information within the company or with any other entities unless it is necessary for
conducting activities or providing services related to such confidential
information.
16. Contact Us
16.1 For any other questions or concerns regarding this Policy, please contact: