What personal data do we collect and process

We may collect, use, store and share different kinds of your personal data, such us:

• Your name, username or similar identifier, title, date and place of birth, gender, country of residence and citizenship;

• Your contact information and billing address, delivery address, email address, telephone number(s);

• Information about you that are stored in different documents in various forms or copies of them, including your passport, identity card, driver license as well as documents for the proof of you address, utility bill, payslip/tax return as proof of source of funds, credit checks; 

• Your economic profile including assets, income, financial position/ source of wealth, employment status, profession and industry, bank account and bank statement, e-wallet and credit card details;

• Your education, profession and/or details about your work, nationality;

• Contractual Data: such as details about the services and or products offering;

• Trading information Data: reason for opening the account, experience in trading, risk tolerance and risk profile;

• Details about payments to and from you, information on products and services you have purchased from us, deposit methods, purpose of transactions with us;

• National identifier Data: such as tax identification number, country of tax residence;

• Profile Data: such as your username and password, purchases or orders made by you, historical data about the trades and investments you have made, your preference for certain types of products and services, products you trade with us, your interests, preferences, feedback, and survey responses;

• Details about you that are available online, are in public records or other open available sources;

• Your consents, any permission or preferences given to Valmentra;

• Marketing and Communications Data: such as details about you from letter, email and conversation, chats between us and your preference in receiving marketing from us and any third-party companies on our behalf;

• Technical Data: such as internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and mobile app and electronic services;

• Usage Data: such as information about how you use our website, mobile app, products, and services.

We obtain this information in a number of ways through your use of our services and website, the account opening applications, our demo sign up forms, and from information provided in the course of ongoing customer service correspondence. We may also collect this information about you from third parties either through bought-in third party marketing lists, publicly available sources, social media platform, introducers brokers and affiliates, bankers and credit card processors, subscription-based intelligence databases, credit references agencies, fraud prevention agencies, third authentication service providers, other financial institutions and the providers of registers, and other third party associates.

We also process personal data generated by us in the course of providing you with our services such as Transaction Data.

We may ask for other personal data from time to time (for example, through market research, surveys or special offers). If you choose not to provide the information we need to fulfill your request for a specific product or service, we may not be able to provide you with the requested product or service.

We also use cookies on our website to ensure that our website works effectively, for fraud prevention, security and to support your trading activities. Cookies are small text files sent from our web server to your computer.

We may enlist outside organizations to help us manage the website and collect and analyze statistical data. These outside organizations may install and use their own cookies on our behalf.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. This Privacy Policy is valid only for our website and does not cover other websites, including but not limited to websites that you go to using links on our website. We recommend that you review the privacy policy of each website whose use involves transferring personal data.

We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our business relationship with you. These recordings will be our sole property and will constitute evidence of the communications between us for the purpose of complying with our regulatory obligations. Such telephone conversation may be recorded without a prior warning tone or any other further notice. 

How we collect your personal data and purpose

By registering a Personal Area, you agree to have your personal data processed and specifically consent to the collection, systemization, aggregation, storage, revision (updating, changing), usage, anonymization, blocking, deletion, and distribution (transfer) of said personal data to third parties in accordance with the conditions set forth in this Privacy Policy.

We ask you for the data necessary for registering a Personal Area, providing functional service, and using this data if a dispute arises between you and Valmentra. Providing this data is required for client identification and thus allows you to perform various operations in your Personal Area and trading accounts.

We may also collect data to improve our understanding of your needs and preferences by communicating through Live Chat, conducting brief surveys in your Personal Area on our official website, and communicating with you over the phone. You provide this data to us voluntarily.

We use the data that you directly provide when communicating with us.

We use your personal data to provide secure high-quality service.

The personal data you provide us with is used to verify contact information and identity. We also use personal data to register Personal Areas, open and configure trading accounts, and issue activation codes and passwords. By providing contact information, you help us improve our services and promptly communicate the availability of additional services, features, and promotions we may be offering.

We may review, store and delete your personal information, including without limitation physical records of transactions and correspondence from you in accordance with the relevant legislation.

Who we share your personal data with and in what circumstances

We may disclose your personal information to our entities part of the same group of Valmentra companies, service providers who are involved in the delivery of products or services to you, e.g. payment service providers; other third parties we use to help us run our business, eg. outsourced compliance services, website hosts and website analytics providers, our banks.

We or the third parties mentioned above occasionally may also share personal data with: our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations; our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations; 

We may pass your personal data on to third party authentication service providers https://sumsub.com/privacy-notice/ when you use our system to perform identity checks and documents verification- we do this in order to comply with our legal obligations. When transferring your information to third parties, we maintain the confidentiality and security of the information being transferred.

We reserve the right to provide personal data to third parties if required by law or if we receive formal requests from law enforcement and other government agencies and as envisaged by the agreement with you.

We may also provide your personal data to tax authorities or organizations that require the data to be provided in order to comply with laws against money laundering and financing terrorism, or when necessary to protect our rights or property

In order to give you comprehensive, state-of-the-art high-quality service, we may exchange your personal data with our partners. At your request, we can provide information about the services that our partners provide for us.

We monitor the usage of data from agents or third parties to ensure that they comply with our confidentiality and data protection policies, ensuring that no misuse of information and data takes place. The Company has access at all times to the data used by agents or third parties.

Security and protection

Valmentra complies with the Payment Card Industry Data Security Standard (PCI DSS) to ensure your security and privacy. We conduct regular vulnerability scans and penetration tests in accordance with the PCI DSS requirements for our business model.

We have put in place appropriate and reasonable security measures to prevent your personal data from being accidentally lost, used, collected, disclosed, altered, disposed or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those who have a genuine need to access it. They will only process your personal data on our instructions, and they are subject to confidentiality obligations. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 

Use of cookies

We use cookies to ensure that our website works effectively, for fraud prevention, security and to support your trading activities. Cookies are small text files sent from our web server to your computer.

We may enlist outside organizations to help us manage the website and collect and analyze statistical data. These outside organizations may install and use their own cookies on our behalf.

How we store your personal data and for how long

Valmentra will process personal data for as long as we have a business relationship with you, in a combination of secure computer storage facilities and paper-based files and other records and we will take the necessary measures to protect the personal data we hold about you from misuse, loss, unauthorized access, modification or disclosure.

If you instruct us to cease using or processing your personal data, we have the right to terminate any existing services to you within a reasonable time or immediately, as determined by the Company.

When we consider that personal data is no longer needed for the purpose for which it was collected, we may remove any details that may identify you or we may securely destroy the records. However, we may need to maintain records for a significant period of time (after you cease to be our client) subject to certain AML laws that require us to retain a copy of the documents we used in order to comply with our customer due diligence obligations as well as supporting evidence and records of transactions with you and your relationship with us.

For the personal data held in the form of an email, telephone, electronic, in person or otherwise recorded communication, the information will be retained in line with the requirements of our Regulatory Authority.

If you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications.

We may keep your data for a longer time than the retention period if for legal, regulatory or technical reasons we cannot delete it.