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Privacy Policy

Introduction

This Policy aligns with Article 24 GDPR (EU) 2016/679, considering the nature, scope, context, and purposes of processing, as well as the risks to the rights and freedoms of natural persons. UNC Markets has implemented appropriate technical and organizational measures to ensure adherence to the General Data Protection Regulation (GDPR). This policy serves as the cornerstone of UNC Markets’ compliance with GDPR and is reviewed and updated accordingly.

This Policy provides data subjects with information on how UNC Markets collects personal data, what we do with it, and with whom it may be shared. This privacy notice has been drafted in compliance with the requirements of the General Data Protection Regulation, Regulation (EU) 2016/679 (the “GDPR”), and based on the Information Commissioner’s Code of Practice on “Privacy Notices, Transparency, and Control” and the Article 29 European Commission Guidelines on transparency under the GDPR.

We ask that you read this privacy notice carefully as your privacy on the internet is of crucial importance to us. It contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information, and how to contact us and supervisory authorities in the event you have a complaint.

Who we are?

UNC Markets Ltd (“us,” “our,” or “we”) collects, uses, and is responsible for certain personal information about you. When we do so, we are regulated under the General Data Protection Regulation, which applies across the European Union, and we are responsible as the “controller” of that personal information for the purposes of those laws.

Data Controllers and Contracting Parties

Regardless of whether you reside inside or outside the “Designated Countries,” UNC Markets will be the controller of your personal data provided to, or collected by or for, or processed in connection with our services and regulated activities.

Whether information has to be provided by you, and if so why

The provision of “Your Data” is required from you to enable us to provide our services. We will inform you at the point of collecting information from you whether you are required to provide the information to us.

Information collected by us

In the course of your registration as a client, signing up for a demo or live account with UNC Markets, or filling in any form on our website, subscribing to our services, news or offers, marketing communications, or posting material, the following information about you (“Your Data”) will be collected and stored for administrative, service-related, and/or legal purposes.

We will limit the collection of personal information to what is necessary to administer our business and carry out our regulated activities to provide you with superior service.

Information that you provide to us directly:

  • Personal information, such as names, addresses, personal registration number, national identification number, passport number, and email addresses, etc. (“Personal Information”), and
  • Financial information, trading experience, and employment information for appropriateness assessment will also be collected.

However, the meaning of data “provided to” UNC Markets is not limited to this. It is also personal data resulting from observation of your activities (i.e., when using a device or service).

This may include:

  • History of website usage or search activities, details of your visits to our website, including communication data;
  • Traffic and location data;
  • Website traffic pattern information, including IP address, operating system, and browser type, for system administration and to report aggregate information to our advertisers. This kind of information is only used in masked or aggregated form, meaning that the individual user will not be recognizable. These data do not identify any individual.
  • Communications between you and UNC Markets via live chat, email, or telephone call.

Your email address may be used by UNC Markets in relation to its products and services (including any marketing campaigns related to these products or services). If you do not wish to receive such marketing material and marketing communications, you can opt-out at any time by clicking on “unsubscribe” or by sending an email stating so to support@3.120.189.127.

How we use your personal information

We use information held about you in the following ways:

  • To ensure that the content on our website is presented to you in the most effective manner and to improve the content of our website;
  • To communicate with you and contact you and to provide you with products and services that you request from us, or, where you have considered to be contacted, for products and services that we feel may be of interest to you;
  • Managing and administering the products and services provided to you;
  • Keeping you updated as a client regarding changes to our services and relevant matters;
  • Provide, improve, test, and monitor the effectiveness of our services;
  • Develop and test new products and features;
  • Monitor metrics such as the total number of visitors, traffic, and demographic patterns;
  • Diagnose or fix technology problems;
  • To carry out our obligations arising from any contracts entered between you and us.

We may also use your data or permit selected third parties and our processors to use your data to provide you with information about goods and services which may be of interest to you, and we or they may contact you about these by email.

  • To notify you about updates to the website;
  • To send out newsletters or information about other opportunities that we believe will be of interest to you. We will only send this to you if you have indicated that you wish to receive such information, and we will respect your wish not to do so if you communicate such a wish to us. You can opt-out of receiving marketing communications at any time if you do not wish to receive such marketing material by clicking on “unsubscribe” or by sending an email request to support@3.120.189.127.
  • To promote safety and security. We use the information we have to help verify accounts and activity and to promote safety and security on our regulated services, such as by investigating suspicious activity or violations of our terms or policies. We work hard to protect your account using teams of IT specialists, automated systems, and advanced technology such as encryption.

Who we share your personal information with

We will not rent or sell your information to third parties outside of UNC Markets (or the group of companies of which UNC Markets is part of) without your consent. We also impose strict restrictions on how our processors can use and disclose the data we provide. Here are the types of third parties we share information with:

  • Service providers and other partners: We transfer information to service providers (processors) and other partners who support our business globally, such as providing technical infrastructure services, trading platforms, analyzing how our services are used (such as measuring the effectiveness of ads and services), providing client service and support, client on-boarding, client identity verification (including PEPs and sanctions), conducting marketing communications and design, services related to our website management, services related to software, and business development services.

  • We need to transfer personal data to recipients outside the European Union; these activities can include dealings with foreign public entities (only when necessary and under request), the outsourcing of services to external providers located outside the EU, and/or processing the data outside the EU (e.g., cloud computing, client identity verification, and individuals from outside the EEA accessing our web services).

  • Measurement and Analytics Services: Partners who use our analytics services like Google Analytics (Non-Personally Identifiable Information Only). We do not share information that personally identifies you (personally identifiable information is information like your name or email address that can by itself be used to contact you or identify who you are) with advertising, measurement, or analytics partners.

UNC Markets conducts extensive due diligence before choosing processors to ensure they provide sufficient safeguards, particularly in terms of expert knowledge, data governance, data security, cyber resilience, reliability, and resources to implement technical and organizational measures in a way that processing will meet the requirements of General Data Protection Regulation and ensure the protection of the rights of the data subject.

Adherence to the processor to an SLA Contract is used as an element to demonstrate compliance with the obligations of the controller.

The carrying-out of processing by our processor is governed by a contract or other legal act under Union or Member State law, binding the processor to the controller.

This data sharing with our processor enables us to proceed with our regulated activities and duties for KYC to meet our regulatory obligations regarding assessing the appropriateness of our products and services, providing support to clients, etc. Some of those third-party recipients (processors) may be based outside the European Economic Area; if the third-party recipient is located outside the EU/EEA in a country not ensuring an adequate level of data protection, the transfer will only be completed if a written agreement has been entered into between UNC Markets and the third party. The written agreement shall be based on the Standard Contractual Clauses approved by the European Commission (and any updated versions). For further information including how we safeguard your personal data when these cases occur, see the paragraph ‘Transfer of your information out of the EEA.

We will share personal information with law enforcement or other authorities if required by applicable law.

Cookie Data We use cookies and similar technologies to provide and support our services. When you use our website, we will use cookies to distinguish you from other users of our website.

For more information about cookies and how we use them, please read our Cookies Policy.

How our global services operate Transfer of your information out of the EEA

Information collected within the European Economic Area (“EEA”) will be transferred to countries outside the EEA for the purposes described in this policy, relying on the lawful basis of contractual necessity and compliance with our legal obligations.

We and our processors, when data is transferred outside the EEA, utilize standard contract clauses approved by the European Commission and adopt other means under European Union law and may obtain your consent to legitimize data transfers from the EEA to other countries.

How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others by request:

  • We can respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognised standards.
  • When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorised use of the services or products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-parties about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.

Information we receive about you (including financial transaction as data related to deposits and withdrawals) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.

Your rights

Under the General Data Protection Regulation you have a number of important rights if you are resident within the European Union. In summary, those include rights to:

  • Fair processing of information and transparency over how we use your use personal information,
  • The right to access personal data: via a Subject Access Request. Your request should be made in writing to support@3.120.189.127
  • We may ask you for proof of identity before providing you with the data. There is usually no charge for such requests, however in limited circumstances we may be able to charge an administrative fee (and we will inform you in response to your request if that is the case).
  • The right to request that your personal data is corrected if it is found to be inaccurate: require us to correct any mistakes in your information which we hold.
  • The right to request that your personal data is erased where it is no longer necessary. In some circumstances this right may not apply e.g. if there is some other compelling reason for us to keep or process your data (and we will inform you in response to your request if that is the case).
  • Right to data portability: to receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party (another controller) in certain situations.
  • The right to withdraw consent to processing at any time, where relevant i.e. where we are relying on your consent to process the data and not another legal reason for processing.
  • The right to object at any time to processing of personal information concerning you for direct marketing.
  • The right not to be subject to a decision which is based solely on automated processing, including profiling which produces legal effects concerning them or significantly affects them.
  • The right to object in certain other situations to our continued processing of your personal information.
  • Otherwise restrict our processing of your personal information in certain circumstances.

If you would like to exercise any of those rights, please:

  • email to us at support@3.120.189.127
  • let us have enough information to identify you (eg account number, username, registration details),
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let us know the information to which your request relates, including any account or reference numbers, if you have them.

If you would like to unsubscribe from any emailing or any marketing communications you can also click on the ‘unsubscribe’ button at the bottom of the email or by sending an email at support@3.120.189.127 stating so.

How long your personal information will be kept

Data retention:

You can close your account any time, but for audit trail purposes, UNC Markets shall hold personal data for a period of at least five years after closing the account in order for us to comply with our record keeping obligations under the Money Laundering Regulations 2020.

At the end of that period, we will delete all personal data relating to you, unless a legal requirement requires them to keep the data for a prolonged period of time, or Data Subject has expressly consented to their data being held for an extended period of time.

What happens in the event of a change of control?

If we sell or otherwise transfer part or the whole of UNC Markets or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address and any other information collected through the Service may be among the items sold or transferred. You will continue to own your User Content. The buyer or transferee will have to honour the commitments we have made in this Privacy Policy.

How to complain?

We hope that our Data Protection Officer, client support or compliance team can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority.

How to contact us?

If you wish to contact us with any queries, concerns or complaints, you can email us at support@3.120.189.127.

Changes to this privacy notice

This privacy notice was published in April 2024.

We may change this privacy policy from time to time, when we will inform you via our Website or via email.

Do you need extra help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us(see ‘How to contact us’ above).