Découvrez la Politique de Confidentialité de SabioTrade

Date d’entrée en vigueur : 24/08/2023

At SabioTrade we are committed to protecting and respecting your privacy. This privacy policy aims to give you information on how we collect and process any personal data, i.e. information about a User (as defined below) who is a natural person on the basis of which that User can be identified (hereinafter the data) in accordance with the applicable data protection legislation, including the General Data Protection Regulation, EU Regulation No. 2016/679 the (hereinafter “GDPR”).

It is important that you read this privacy policy together with any other privacy policy we may provide you on specific occasions when we are collecting or processing data about you so that you are fully aware of how and why we are using your data.

In this Privacy Policy, unless the context otherwise requires, expressions defined herein shall have the meaning ascribed to them in the Terms & Conditions. Please note that this Privacy Policy is addressed to Users and potential Users.

1. WHO WE ARE

SabioTrade, is a global brand which is operated by CODEVIL ENGINEERING LIMITED, a company registered in Ireland having its registered address at 2C, Grangegorman Lower, Smithfield, Dublin 7, Dublin D07A433 Ireland (hereinafter “We”, “Us”, “Our”, “Company” or “SabioTrade”). We are the controller and responsible for the data the User disclosed to the Company in order to register for an account and/or to purchase any services offered by SabioTrade through its website.

In SabioTrade we respect your privacy and therefore all companies within the SabioTrade group are committed to protecting your data, which it collects, uses and/or has access to.

We take measures to implement advanced data protection policies and procedures and to update them from time to time for the purpose of safeguarding the User's data. Your data is protected by the legal, administrative and technical measures that we take to ensure the privacy, integrity, and accessibility of data. To prevent security incidents with your data, we use a mixed organizational and technical approach based on the results of annual risk assessment.

The Company shall not divulge any private information of its Users and/or former Users unless the User approves in writing such disclosure or unless such disclosure is required under applicable law or is required in order to verify the User's identity, or it is required for SabioTrade to perform its contractual obligations under any agreement concluded with the User. The User’s information is processed only by the authorized representatives, associates, and third parties which provide specific services, necessary for the provision of our services. All such information shall be stored on electronic and physical storage media according to applicable law.

2. DATA USAGE

We may collect, use, store and transfer different kinds of data about you which we have grouped together as follows:

• Identity Data includes first name, last name, and patronymic (if available), date of birth, passport, ID, driver’s number.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about the transactions performed by you, details about payments, withdrawals, exchanges, deposited and withdrawal amount methods, and any other details in relation to the services you have made use of 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 technologies on the devices you use to access the Website and use of cookies stored on your device.
• Profile Data includes your User’s account details, username and password, transactions made by you, your interests, preferences, feedback and/or information received through your interaction with us within the course of providing our services and survey responses.
• Usage Data includes information about how you use the website, products and services, registration date, account category, number of complaints, number of requests filed and IP history.
• Marketing and Communication Data includes your preferences in receiving marketing from us and your communication preferences.
• Banking Data includes details of the number of payment wallets and/or information of your bank card, including information of the issuing bank, card number, cardholder name.
• Data in KYC (Know your customer) includes identity document information, including copies of recently dated Utility Bills, Identity Card, Passport and/or Driver’s License.
• Location Data includes details on your actual location when interacting with our website (for example, a set of parameters that determine regional settings of your interface, namely residency country, time zone, and the interface language)

(the above collectively referred to as “Personal Data”)

Aggregated Data includes statistical or demographic data for any purpose. Such data can be derived from your data but may not be considered personal data in 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 specific website feature and/or services/product preference. Notwithstanding the above, if SabioTrade combines Aggregate Data with data in a way that the end result can in any way identify the data subject, SabioTrade shall treat such combined data as data which will be treated as per the provisions herein contained.

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

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

1. 1. To perform its contract with you,
2. 2. To comply with its legal obligations,
3. 3. To safeguard its legitimate interest.

The User acknowledges that all or part of the data concerning the User's account and related transactions will be stored by SabioTrade and may be used by the Company in case of dispute between the User and the Company.

The User is responsible for updating any data provided to us in case of any change. Although we will strive to keep your data up to date and review and inspect any information provided by you, we may not be able to always do so without your help. The User acknowledges that SabioTrade holds neither commitment nor responsibility to the User due to any aforesaid review or inspection of information.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you, including through:

Direct Interactions. You will provide to us your Identity, Contact and Financial Data online through the Website and/or by filling in online forms and/or by corresponding with us by emails or otherwise. Data may be submitted to us by you when you:

1. A. Register for an account;
2. B. Receive updates (unless you unsubscribe);
3. C. Request marketing and promotions to be sent to you;
4. D. Enter a competition or survey;
5. E. and/or Give us feedback or contact us.

We require to collect the above data in order to be able to (i) provide our services efficiently, (ii) to comply with our ongoing legal and regulatory obligations, including, inter alia, (a) to prevent fraud and money laundering acts and/or (b) conduct the assessment of suitability and appropriateness test.

If you fail to provide the data when requested, we may not be able to perform the contract we have or try to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time. It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during your relationship with us.

Automated Technologies or Interactions. When using our services, your device automatically transmits to us its technical characteristics. Local (a set of parameters that determine regional settings of your interface, namely, residence country, time zone and the interface language) is used for the purpose of providing you with the best possible service.

Using the information about IP address, cookies files, information about browser and operating system used, the date and time of access to the site, and the requested pages addresses allows us to provide you with the optimal operation on our web application, mobile and/or desktop versions of our application 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 marketing source of users by 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 any such transmissions (to the degree this is possible and subject to any of our legal obligations) by sending your request using our details (OUR CONTACT DETAILS) below using the registered email address you disclosed and registered with us through your Account. We will address your request within 30 business days.

Social Networking Data. In the event that the Company allows you to integrate any social media function — e.g. use of Facebook, Twitter, or LinkedIn-into your use of the Company's website, the Company may collect your username associated with any such social media website you use. We may also collect any information that you make public through that website or that such website has shared with us, including, but not limited to profile information, pages you have “liked,” and friend lists.

About Cookies. The Company's website may use cookies. Cookies are small data files generally comprised of a string of text and numbers that assign your computer a unique identifier. They collect information from your computer and allow your computer to have a “dialogue” with the Company and give you a more convenient and personalized experience with the Company's website. If you do not want the Company to use cookies on your computer, then you must adjust your browser settings in order to disable them. Please note, however, that the disabling of cookies may prevent you from fully accessing all features of the Company's website. If you require any assistance in disabling cookies, please contact your browser company.

4. PURPOSE FOR WHICH WE WILL USE YOUR DATA AND ON WHAT LEGAL BASIS

1. 1. We process the aforementioned data in compliance with the provisions of the GDPR and the applicable local legislation as amended from time to time in order to (i) be able to perform our contractual obligations towards the User and offer them the best possible service, (ii) provide our Services efficiently, (iii) comply with our legal and regulatory obligations, including, inter alia, (a) to prevent fraud and money laundering acts and/ or (b) conduct the assessment of suitability and appropriateness test, and (iv) protect our legitimate interests and your vital interests.

2. 2. We process all data based on the following legal basis:

   1. For compliance with our legal obligations;
   2. For the performance of our contractual obligations towards the User;
   3. For the purposes of safeguarding our legitimate interests and your interests and fundamental rights do not override those interests; and/or
   4. On the basis of your consent.

3. 3. Indicatively, we set out below a description of all the ways we plan to use your data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process the data for more than one lawful ground, depending on the specific purpose for which we are using your data.

4. 4. If you are an existing User 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 to communicate with you in case of support and/or sending newsletters, push-messages and calls to keep you in touch with our new features, news and events and the efficient provision of the full scope of our services. We will also use your data to send you marketing information regarding our services that we believe may be of interest to you via email or otherwise.

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 your birthdate in order to confirm the Users’ age checks.

5. OPTING OUT

If you don’t want to receive any newsletters or updates or transmit your data to third-parties for marketing purposes, you can configure your preferences. You may send to the Company, at any time, an email to support@sabiotrade.com, using the registered email address you disclosed and registered with us through your Account, asking the Company to cease from sending such advertising content or sending your data to third-parties for marketing purposes.

6. DISCLOSURE OF DATA

We may share your data with the parties for the purposes set out above.

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

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

We strive to maintain discretion with respect to User related matters and assessments of which we acquire knowledge. We may disclose data that concerns you only if (i) we are legally required to do so; (ii) if required when you expressly order us to process a transaction or any other service and (iii) it is required for the provision of our services under our contractual relationship and/or (iv) protection of our legitimate interests, in accordance with the provisions of the GDPR and applicable local legislation, as amended from time to time.

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

A. Service Providers. We may share your data with our trusted third party service providers and contractors which, 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, sending newsletters, provide customer support and perform other important services for us.

B. Other related and/or affiliated entities. We may also disclose your data to other related and/or affiliated companies in order for them to provide us with the relevant services.

C. State authorities. Your details that are provided and/or that will be provided by you during your activity on the website may be disclosed by us to official authorities. We will make such disclosure only if required to be disclosed by us under the applicable law or court order and to the minimum required extent.

D. Other disclosures. In addition to where you have consented to a disclosure of the data or where disclosure is necessary to achieve the purpose(s) for which it was collected, data may also be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise, or defense of legal claims.

E. International Transfers. The use of service providers and disclosure of your data to affiliated companies and/or third parties might imply a transfer of your data to third countries, which may not fall within the ambit of the GDPR (so-called Third Countries).

In such cases, we require that all recipients of your data provide appropriate safeguards to protect your data, when it is transferred to Third Countries, through the adherence to standard data protection clauses adopted by the EU Commission (cf. the GDPR article 46(2)) and/or binding corporate rules adopted by the EU Commission (cf. GDPR article 47).

A transfer to an affiliate and/or related company and/or third party based in a Third Country would only take place where one of the following applies:

1. The individual has given consent to the transfer of information.
2. The transfer is necessary for the performance of a contract between the individual and the Company, or the implementation of pre-contractual measures taken in response to the individual’s request.
3. The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between the SabioTrade group company and a third party.
4. The transfer is necessary or legally required on important public interest grounds or for the establishment, exercise, or defense of legal claims.
5. The transfer is required by law.
6. The transfer is necessary in order to protect the vital interests of the individual.
7. The transfer is made under a data transfer agreement.
8. The transfer is otherwise legitimized by applicable law.

If you want to obtain further information on any data transfers mentioned above, please contact us using the registered email address you disclosed and registered with us through your Account through the points of contact listed in the Section OUR CONTACT DETAILS below.

7. DATA RETENTION

We store your data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, 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 there is a prospect of litigation in 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 those purposes through other means, and the applicable legal, regulatory, tax, accounting and other requirements.

By law, we have to keep your data during our business relationship and upon its termination, for a minimum period of 5 (five) years from the date of termination/expiration. The data storage period may be extended from 5 years to 7 years upon the request of any local authority.

In general, all other data is stored for a period of 30 (thirty) business days after the date of termination of the provision of our services, unless there is any other legal or regulatory reason to keep it.

At the expiration of the data retention period the data is erased by irreversible destruction, and we also inform all third parties, to whom the data was transferred, regarding such erasure and request implementation of similar actions on their part.

8. YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE

We ask you to provide us with true, accurate and updated information on your identity and not misrepresent yourself to be another individual or legal entity. Any changes in your identifying details shall be notified to the Company immediately.

Under certain circumstances, you have rights in accordance with the provisions of GDPR and the applicable local legislation as amended from time to time. These include the right to access, rectification, erasure, restriction of processing, data portability, objection, and withdrawal of consent.

A. The right to access. You have a right to obtain the confirmation as to whether or not your data is being processed by us. In addition, you have a right to obtain more detailed information about the data kept and the processing undertaken by us and under certain circumstances the right to receive a copy of this data.

B. 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.

C. 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. Please note however that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

D. The right to restriction of processing. You have the right to request the restriction of processing of your personal data (a) if it is not accurate; (b) where processing may be unlawful, but you do not want us to erase your data; (c) where you need us to hold the data even if we no longer require it; or (d) where you may have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

E. The right to data portability. To the extent 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 would adversely affect the rights and freedoms of others and/or in case it may be technically impossible to do so.

F. The right to object. Subject to the legal basis on which the processing activity is based, you may object to 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.

G. The right to withdraw consent. To the extent that the legal basis for the processing is your consent, you have the right to withdraw from that consent at any time. This may apply to marketing purposes and/or with regard to the transfer of your data to third parties. In case you withdraw from a consent given, then we will cease to process your data, unless and to the extent the continued processing is permitted or required according to the applicable data regulation or other applicable laws and regulations. The withdrawal of your consent will in no event affect the lawfulness of processing based on consent before its withdrawal.

If you want to exercise any of your rights mentioned above and/or obtain more information regarding your rights, please contact us on the email mentioned in the Section OUR CONTACT DETAILS below. Please also provide us with relevant information to take care of your request, including your full name and email address so that we can identify you.

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 has no right to receive it.

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

9. DATA SECURITY

We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your data on our instructions, and they are subject to a duty of confidentiality.

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

Your help is always valuable in ensuring that your data is kept safe. Upon registration to the Website (or its mobile version), the User will be asked to choose a username and password to be used by the User on each future login and for the performance of transactions and use of the Company's Services. In order to protect the User's privacy and operation with the Website, sharing registration details (including, without limitation, username, and password) by the User with other persons or business entities is strictly prohibited. The Company shall not be held responsible for any damage or loss caused to the User due to improper use (including prohibited and unprotected use) or storage of such username and password, including any such use made by a third party, and whether or not known to or authorized by the User.

Any use of the Website with the User's username and password is the User's sole responsibility. The Company shall not be held responsible for any such use, including for validation that the User is actually operating in his/her account.

The User is obliged to forthwith notify the Company's User service of any suspicion of unauthorized use of the User’s account. You may contact us at any time via the Section OUR CONTACT DETAILS below.

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

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

Protection of your data in our infrastructure. We make it a priority to develop services that are secure “by default”. The “default” security of our services means that every new service and feature is designed with strict security requirements in mind before we even begin development. This is the key to guaranteed protection and privacy of all data that our services handle and store, once the service or new feature is released.

To secure your data, we use the pseudonymisation which allows most of our services to operate without using your actual data. Instead of that, our services use a system ID that can't be traced back to identify you.

The Company is always vigilant about the security of your data stored in our infrastructure. Because of that, we locate all our equipment which is used for your data processing in secure data centers. Network access to this equipment is isolated from the Internet. We use network segmentation for isolation of services which need different levels of security from each other. In addition, we restrict logical access to your data for our employees on a “need to know” basis. So, only personnel who really require access to your data for the purpose of providing you with our best service will have access to it.

10. OUR CONTACT DETAILS

Who is responsible for the data processing and who you can contact:

CODEVIL ENGINEERING LIMITED, a company registered in Ireland having its registered address at 2C, Grangegorman Lower, Smithfield, Dublin 7, Dublin D07A433 Ireland.

Email: support@sabiotrade.com

11. LINKS TO OTHER WEBSITES

We may provide links to third-party websites on our Website. These linked websites are not under our control, and we therefore cannot accept responsibility or liability for the conduct of third parties linked to our websites, including without limitation to the collection or disclosure of your data.

Before disclosing your data on any other website, we encourage you to examine the terms and conditions of using that website and its privacy policies.

12. CHANGES TO THIS PRIVACY POLICY

1. This Privacy Policy was last updated on 15 November 2024. We have the right, at our discretion, to add, modify or remove portions of this Privacy Policy from time to time to ensure that the information herein provides relevant and adequate information about our collecting and processing of your data.
2. This privacy policy may be supplemented by other information received from us and other terms and conditions applicable to the Website or which you have agreed to as part of your interaction with us.
3. In case of updates, we will post the revised Privacy Policy on our website. Changes will take effect as soon as the revised version is made available on our website. Your comments and feedback are always welcome. You may contact us at any time through the points of contact listed in the Section OUR CONTACT DETAILS above.