Capital Market

Privacy Policy

Capital Market respects your privacy and is committed to protecting and respecting your personal data. This privacy policy aims to provide you with information on how we collect and process any personal data, i.e., information about a Customer (as defined below) who is a natural person based on 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 broker in the world. In this privacy policy, we would like to explain why you can trust us with your data and be confident that your data is protected.

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

In this Privacy Policy, unless the context requires otherwise, the expressions defined herein shall have the meanings ascribed to them in the Terms and Conditions.

Please note that this Privacy Policy is directed at Customers and prospective customers. If you are an employee of Capital Market, a contractor of Capital Market, or a 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 set out in the OUR CONTACT DETAILS section below.

If you participate in our affiliate program and/or introducing broker program, we will process the data provided under our agreement with you to exercise our rights and fulfill our obligations under the relevant agreement, and the term Customer in this Privacy Policy shall be deemed to include the term Affiliate and/or Introducing Broker (as applicable).

WHO WE ARE

Capital Market is a global brand managed by Solaris Sky LLC, a company registered at ICD Brookfield Place - Level 25 - Al Mustaqbal St - Trade Centre - DIFC - Dubai - United Arab Emirates, and/or its affiliated and/or related entities (hereinafter "We" or "Company" or "Capital Market").

We are the controller and responsible for Customer data disclosed to us for the purpose of registering for a Trading Account, Demo Account, and/or making use of any other service offered by us through the website (hereinafter "Website") (this term shall at all times include the desktop and mobile versions of the Website).

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

We take steps to implement advanced data protection policies and procedures and update them periodically in order to protect Customer data and Customer accounts. Your data is protected by legal, administrative, and technical measures that we implement to ensure the privacy, integrity, and accessibility of the data. To prevent security incidents with your data, we use a mixed organizational and technical approach based on the results of the annual risk assessment.

We will not disclose any private information of our Customers and former Customers unless the Customer approves such disclosure in writing or unless such disclosure is required by applicable law or necessary to verify the Customer's identity, or necessary for us to comply with our contractual obligations under any agreement entered into with the Customer. Customer information is processed solely by our employees and/or trusted third parties who provide specific services necessary for the provision of our services. All such information will be stored on electronic and physical storage media in accordance with applicable law.

USE OF DATA

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 middle name (if available), date of birth, gender, passport, ID, driver's license number, and photo copy.

Contact Data includes billing address, email address, and phone numbers.

Financial Data includes bank account, payment card details, and tax identification numbers (including but not limited to social security number, tax identification number, national insurance number).

Transaction Data includes details about transactions made by you, details about payments, withdrawals, exchanges, trading history, profits, balance, deposit and withdrawal amounts and methods, 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 types and versions, operating system and platform, and other technologies on the devices you use to access the Website and the use of cookies stored on your device.

Profile Data includes details of your Customer Account, 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 responses to surveys.

Usage Data includes information about how you use the Website, products, and services, date of registration, account category, trading group, number of complaints, number of requests submitted, and IP history.

Marketing and Communication Data includes your preferences for receiving marketing from us and your communication preferences.

Special Categories of Data includes details about your religious belief, annual income, biometric data, and/or convictions and criminal offenses.

Compliance Data includes details about your education, employment status, trading experience, self-assessment proof.

Banking Data includes details about the number of payment wallets and/or information of your bank card, including issuing bank information, card number, cardholder name, card expiration date, payment system, card validation code (CVV2/CVC2), and photos of both sides of the bank card.

KYC (Know Your Customer) Data includes identity document information, including copies of recent utility bills, ID card, passport, and/or driver's license.

Economic Profile Data includes details about occupation, investment purpose, annual income, net worth, expected annual investment amount, and sources of funds.

Location Data includes details about your actual location when interacting with our Website (e.g., a set of parameters determining the regional setting of your interface, country of residence, time zone, and language of the interface).

Audio Data includes full voice recordings of calls you receive from us or make to us (the foregoing collectively referred to as Personal Data).

Aggregate Data includes statistical or demographic data for any purpose. Such data may 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 Aggregate Data could be that we aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the website and/or service/product preference.

Notwithstanding the foregoing, if we combine Aggregate Data with data in a way that the end result can somehow identify the data subject, we will treat such combined data as data that will be treated in accordance with the provisions herein.

We process your data following the principles of legality, 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, we collect and process Personal Data for any of the following reasons:

To fulfill our contract with you;
To comply with our legal obligations, including, among others, applicable anti-money laundering and counter-terrorism financing laws and regulations (hereinafter referred to as anti-money laundering laws), and/or
To safeguard our legitimate interests.
The Customer acknowledges that all or part of the data related to the Customer's account and related transactions will be stored by us and may be used by us in the event of a dispute between us and the Customer.

The Customer is responsible for updating any data provided to us in case of any changes. While we will strive to keep your data up-to-date and review and inspect any information provided by you, we may not always be able to do so without your help. The Customer acknowledges that we have no obligation or liability towards the Customer due to any aforementioned review or inspection of information.

HOW YOUR PERSONAL DATA IS COLLECTED

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

Direct Interactions. You will provide us with your Identity, Contact, and Financial Data online through the Website and/or by completing online forms and/or by communicating with us by email or other means. Data may be sent to us by you when you wish to:

Register for a Trading Account;
Register for a Demo Account;
Subscribe to our newsletters and continuous updates;
Request to be sent marketing and promotions;
Participate in a contest, promotion, or survey; and/or
Give us feedback or contact us.
We require the collection of the above data in order to (i) efficiently provide our services, (ii) comply with our ongoing legal obligations, including, among other things, fraud prevention and anti-money laundering.

If you do not provide the data when requested, we may not be able to fulfill the contract we have or are trying to enter into with you (for example, providing 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 that time. It is important that the data we have about you is accurate and up-to-date. Please keep us informed if your data changes during your relationship with us.

Technologies or Automated Interactions. When you use our Services, your device automatically transmits its technical characteristics to us. The Locale (a set of parameters determining the regional setting of your interface, i.e., country of residence, time zone, and language of the interface) is used in order to provide the best possible service within our platform. The use of information about IP address, cookie files, information about the browser and operating system used, date and time of access to the site, and addresses of the requested pages allow us to provide you with the optimal operation of our web, mobile, and/or desktop versions of our application and monitor your behavior in order to improve the efficiency and usability of our Services.

We use web analytics tools to track the performance of our website and the source of marketing users through cookies to optimize our marketing costs and provide users with a better experience. At any time, you can request that we refrain from any transmission of this type (to the extent possible and subject to any of our legal obligations) by sending your request to the DPO using our details in the CONTACT DETAILS BELOW using the registered email address that you disclosed and registered with us through your Account. We will address your request within 30 business days.

ABOUT COOKIES:

A cookie is a small amount of data that often includes a unique identifier sent to your computer's or device's browser from a website's computer and stored on your device's hard drive to track website usage. A website can send its own cookie to your browser if your browser's preferences allow it, but to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent 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, among others, your browser type, your IP address, and the referring website.

Stored cookies can determine the path the Customer followed on our site and are used to anonymously identify repeat users of the website and which pages were most popular with Customers. However, we protect Customer privacy by not storing Customer names, personal details, emails, etc. of Customers. The use of stored cookies allows the Website to be more user-friendly and efficient for Customers by allowing Capital Market to learn which information is more valued by Customers versus what is not. You can configure 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 features provided by our website to the fullest extent.

Please refer to our Cookie Policy for more details.

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

We process the aforementioned data in compliance with applicable legislation amended from time to time to (i) be able to fulfill our contractual obligations towards the Customer and offer the best possible service, (ii) provide our Services efficiently, (iii) comply with our legal obligations, including, among others, preventing fraud and acts of money laundering, and (iv) protect our legitimate interests and your vital interests.

We process all data based on the following legal bases:

To comply with our legal obligations;
For the performance of our contractual obligations towards the Customer;
In order to safeguard our legitimate interests and your interests, and fundamental rights do not override those interests; and/or
Based on your consent.
Indicatively, below are described all the ways in which we plan to use your data and on what legal bases we rely to do so. We have also identified what our legitimate interests are where applicable. Please note that we may process data on more than one legal ground depending on the specific purpose for which we are using your data.

OPT-OUT DISCLAIMER

If you do not wish to receive any marketing newsletters or for us to transmit your data to third parties for marketing purposes, you can set your preferences. This setting can be done by (i) opening an account or (ii) upon receipt of such advertising content or (iii) logging in and going to My Account > Personal Details > Notification Settings. You can also email us at support@capitalmarket.com using the email address registered and disclosed with us through your Account at any time, requesting us to stop sending such advertising content or sending your data to third parties for marketing purposes. Unsubscribing as mentioned above and/or the email received by Capital Market will require us to cease sending advertising content to you within 7 (seven) business days.


DATA DISCLOSURE

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

We take all reasonable measures to ensure that our third-party service providers do not use your personal data for their own purposes, and we only allow them to process your data for specific purposes and in accordance with our instructions.

In general, your data is used by our processors.

Additionally, 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 reorganization, asset sale, consolidation, merger, or similar.

With regard to the transfer of data to recipients outside of our related and/or affiliated entities, we note that we strive to maintain discretion regarding customer-related matters and assessments that we acquire knowledge of. We may disclose data concerning you only if (i) we are legally obligated to do so; (ii) if necessary when you expressly order us to process a transaction or other service and (iii) it is necessary for the provision of our services under our contractual relationship and/or (iv) protection of our legitimate interests and legislation amended from time to time.

External Third Parties. Your data is shared with third-party organizations/entities, including, among others:

A. 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, newsletter dispatch, 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 affiliated companies of Capital Market to provide us with the relevant services.

C. State Authorities. The details you provide and/or will provide during your activity on the Website may be disclosed by us to official authorities. We will make such disclosure only if required to disclose under applicable law or court order and to the minimum extent required.

D. Other Disclosures. In addition to when you have consented to a disclosure of the data or when the disclosure is necessary to achieve the objective(s) for which it was collected, data may also be disclosed in special situations, where we have reason to believe it is necessary to identify, contact or take legal action against anyone who may harm, damage, or interfere (intentionally or unintentionally) with our rights or property, users, or any other person who may be harmed by such activities, or otherwise when it is necessary for the establishment, exercise, or defense of legal claims.

Where reasonably possible, management will ensure that third parties collecting, storing, or processing personal information on our behalf have:

a. Signed agreements to protect personal information consistently with this Privacy Policy and information security practices or implemented measures as prescribed by applicable laws;

b. Signed non-disclosure agreements or confidentiality agreements that include privacy clauses in the contract; and

c. Established procedures to comply with the terms of their agreement with third parties to protect personal information.

Corrective measures will be taken in response to misuse or unauthorized disclosure of personal information by a third party collecting, storing, or processing personal information on behalf of Capital Market.

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





DATA RETENTION

We store your data for as long as reasonably necessary to fulfill the purposes for which we collected them, including purposes of meeting any legal, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in case of a complaint or if we reasonably believe there is a possibility of litigation regarding 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, whether we can achieve those purposes through other means, and the applicable legal, tax, accounting, and other requirements.

We will retain your data (including call recordings) during our contractual relationship and for a minimum period of 7 (seven) years from the date of termination of the service used by you.

In general, all other data are stored for a period of 30 (thirty) business days after the termination date of the provision of our Services, unless there is some other legal reason to retain them.

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


YOUR RIGHTS AND HOW TO EXERCISE THEM

We ask that you provide us with truthful, accurate, and up-to-date information about your identity and that you do not impersonate another person or legal entity. Any changes to your identification details should be notified immediately and, in any case, no later than the seventh day from the date of such changes. If your data is incorrect or incomplete, please contact us at the contact details listed in the OUR CONTACT DETAILS section below to update your data.

Under certain circumstances, you have rights in accordance with applicable law and our policies amended from time to time. Some of the rights are quite complex and include exemptions; therefore, we recommend that you contact us (at the contact details listed in the OUR CONTACT DETAILS section below). You can find a summary of your rights below in this section.

A. Right of access. You have the right to obtain confirmation of whether we are processing your data. Additionally, you have the right to obtain more detailed information about the stored data and the processing carried out by us and, under certain circumstances, the right to receive a copy of this data.

To access and view your data without downloading them, go to 'Access my data' in your personal cabinet, log in to your Account, go to Personal Data, and at the bottom of the page, you can proceed with your request by selecting Access my data. Additionally, you have the right to obtain more detailed information about the stored data and the processing carried out by us and, under certain circumstances, the right to receive a copy of this data.

B. Right to rectification. You have the right to rectify inaccurate data about you and, considering the purpose of the processing, complete incomplete data.

C. Right to erasure. This allows you to request us to delete or remove personal data when there is no valid reason for us to continue processing them. To delete your Account and all personal data currently stored in our system, you can do so by logging in to your Account, going to the Personal Data section, then to Account Settings, and at the bottom of the page, you can proceed with your request by selecting - Terminate account - Delete my account and all its data. However, please note that we may 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. In case you wish to obtain complete deletion of your data (to exercise the "right to be forgotten"), please note that we may 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.

D. Right to restriction of processing. You have the right to request the restriction of processing of your personal data (a) if they are inaccurate; (b) when the processing may be unlawful, but you do not want us to delete your data; (c) when you need us to retain the data even if we no longer need them; or (d) when you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use them.

E. Right to data portability. To the extent that the legal basis for 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 when it would adversely affect the rights and freedoms of others, and/or if it is technically impossible to do so.

F. 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 that we must comply with.

G. 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 to marketing purposes and/or with respect to the transfer of your data to third parties. In case you withdraw a given consent, we will stop processing your data, unless and to the extent that continued processing is permitted or required according to the applicable data regulation or other applicable laws and regulations. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before that withdrawal.

DATA SECURITY

We have implemented appropriate security measures to prevent your data from being lost, used, or accessed unauthorized, altered, or disclosed accidentally. Additionally, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know them. They will only process your data following our instructions and are subject to a duty of confidentiality.

We have established procedures to handle any suspicion of data breach and will notify you of a breach if we are legally required to do so.

Your help is always valuable to ensure that your data remain secure. Upon registration on the Website (or its mobile version), you will be asked to choose a username and password that will be used by you at each subsequent login and for transactions and the use of the Services. To protect the privacy of the Client and their operation with the Website, it is strictly prohibited to share registration details (including, without limitation, username and password) with other individuals or business entities. We will not be responsible for any damage or loss caused to the Client due to misuse (including unauthorized and unprotected use) or storage of such username and password, including any use by a third party, whether known or authorized by the Client.

The Company's public live chat feature is not an official communication channel between the Company and you. We will never communicate with you through the public live chat feature, and we will never request any information, including personal data, through the public live chat feature. The public live chat feature is designed for public conversations and as a tool to allow users to communicate and interact with each other in real-time on the topic or topics they are interested in. Please note that the public live chat feature presents non-private communication channels, and the information communicated through the public live chat feature may be accessed by anyone. We do not control the content shared through the public live chat feature, and we will not be liable in any way and for any action taken or information shared through the public live chat feature. You can find more information on how the public live chat feature operates here.

Any use of the Website with the Client's username and password is the sole responsibility of the Client. We will not be responsible for such use, including verifying that the Client is indeed operating on their account.

You are required to immediately notify us of any suspicion of 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 confidence and security, we use Extended Validation (EV) digital certificates issued by trusted Certification Authorities. You can see the "Green Bar" on supported browser versions confirming that all transmitted data is secure.

Protection of your data in our infrastructure. We prioritize the development of services that are secure "by default." The "by default" security of our services means that all new services and features are designed with strict security requirements in mind before development begins. This is the secret to ensuring the protection and privacy of all data our services handle and store once the service or new feature is launched.

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

We are always vigilant about the security of your data stored in our infrastructure. Therefore, we place all our equipment used for processing your data in secure data centers. Access to the network of this equipment is isolated from the Internet. We use network segmentation for service isolation that requires different levels of security among themselves. Additionally, we restrict logical access to your data for our employees based on a "need to know" basis. Therefore, only staff who truly require access to your data to provide you with our best service will have access to them.

Protection against threats. We have extensive knowledge about modern threats to data security and privacy, and we are well-prepared to combat them. All events occurring in our infrastructure are continuously monitored, analyzed, and responded to, allowing us to ensure the adequate protection of your data, keeping them safe from threats, vulnerabilities, and the effects of malware.

In case of a failure affecting the accessibility of your data, we have backup and data recovery procedures that will help us restore your data quickly. To ensure swift recovery, we use high availability mode enabled for the most critical databases, allowing us to minimize downtime.

Employee awareness of data security. Our employees handle your data to provide you with first-class service. To ensure the security and confidentiality of your data, we monitor all actions of employees with access to your data in our systems and strictly grant access on a "need to know" basis: only employees who need access will receive it. We conduct regular training sessions to ensure that every employee understands the principles we follow to achieve strong 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, we are, in principle, not in a position to

OUR CONTACT DETAILS

We have appointed a data protection officer (hereinafter DPO) who is responsible for supervising inquiries related to this Privacy Policy. If you have any questions about this privacy policy, including data-related requests, please contact the DPO using the details provided below:

Address: ICD Brookfield Place - Level 25 - Al Mustaqbal St - Trade Centre - DIFC - Dubai - United Arab Emirates

Email: support@capitalmarket-en.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 Client Account. We may ask you to provide us with evidence of your identity, such as providing us with a copy of a valid identification document. This is to ensure that we adequately protect the personal data we hold from unauthorized access requests and comply with our security obligations.

If you have any questions or want more details about how we use your data, you can contact us at the above contact details, and we will be happy to provide you with more details.

LINKS TO OTHER WEBSITES

We may provide links to third-party websites on our Website. These linked websites are not under our control; therefore, we cannot accept responsibility for the conduct of third parties linked to our websites, including, among other things, the collection or disclosure of your data. Before disclosing your data on any other website, we recommend that you review the terms and conditions of use of that website and its privacy policies.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy was last updated on October 16, 2023. We reserve the right, at our discretion, to add, modify, or remove parts of this Privacy Policy in the future to ensure that the information provided here provides relevant and adequate information about our collection and processing of your data.

This privacy policy may be supplemented with other information received from us and other terms and conditions applicable to the Website or that you have accepted as part of your interaction with us.

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 available on our website. Your comments and suggestions are always welcome. You can contact us at any time through the contact points listed in the OUR CONTACT DETAILS section above.