AceTrade Tech
AceTrade Tech - PRIVACY POLICY
Data protection is of a particularly high priority for Online Fintech Group of Companies and its brand name
(collectively "AceTrade Tech"). In this Privacy Policy, we would like to disclose the nature, scope, and
purpose of the personal data we collect, use and process.
Furthermore, data subjects are informed, by means of this Privacy Policy of the rights to which they are
entitled. This Privacy Policy embodies our commitment to you on protection of your data.
1. Definitions
The data protection declaration of AceTrade Tech is based on the terms used by the European Union for
the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration is for the
general public, as well as our customers, employees, agents and business partners. In this Privacy Policy,
AceTrade Tech uses, inter alia, the following terms:
A. Personal data
Personal data means any information relating to an identified or identifiable natural person ("data
subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by
reference to an identifier such as a name, an identification number, location data, an online identifier or
to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social
identity of that natural person.
B. Data subject
Data subject is any identifed or identifable natural person, whose personal data is processed by the
controller responsible for the processing.
C. Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal
data, whether or not by automated means, such as collection, recording, organization, structuring, storage,
adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or destruction.
D. Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data
to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects
concerning that natural person's performance at work, economic situation, health, personal preferences,
interests, reliability, behavior, location or movements.
AceTrade Tech
Online Fintech FZ LLC - (Registration No: 16396/2020) with registered address Office 1309, 13th Floor, Creative Tower, Fujairah, United Arab Emirates
Online Fintech Pty Ltd - (Registration No: 2020/038412/07) with registered address 202 Beyers Naude Drive, Risidale, Randburg, 2195, South Africa
Online Fintech Private Limited - (Registration No: 0118138) with registered address 405 Royal Suit Plaza, E-11/2 Islamabad 44000, Pakistan.
Email – support@[base_title] | info@[base_title]
E. Controller
Controller or controller responsible for the processing is the natural or legal person, public authority,
agency or other body which, alone or jointly with others, determines the purposes and means of the
processing of personal data; where the purposes and means of such processing are determined by
applicable law, the controller or the specific criteria for its nomination may be provided for by applicable
law.
F. Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data
on behalf of the controller.
G. Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data
are disclosed, whether a third party or not. However, public authorities which may receive personal data
in the framework of a particular inquiry in accordance with Union or Member State law shall not be
regarded as recipients; the processing of those data by those public authorities shall be in compliance with
the applicable data protection rules according to the purposes of the processing.
H. Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject,
controller, processor and persons who, under the direct authority of the controller or processor, are
authorised to process personal data.
I. Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data
subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to
the processing of personal data relating to him or her.
2. Name and Address of the Controller/Processor
The Controller or Processor for the purposes of this Privacy Policy pursuant to the European Union General
Data Protection Regulation (EUGDPR) and other data protection laws applicable to AceTrade Tech is:
- Online Fintech FZ LLC (Registration No: 16396/2020) with registered address Office 1309, 13th
Floor, Creative Tower, Fujairah, United Arab Emirates
- Online Fintech Pty Ltd (Registration No: 2020/038412/07) with registered address 202 Beyers
Naude Drive, Risidale, Randburg, 2195, South Africa
- Online Fintech Private Limited (Registration No: 0118138) with registered address 405 Royal Suit
Plaza, E-11/2 Islamabad 44000, Pakistan.
AceTrade Tech
Online Fintech FZ LLC - (Registration No: 16396/2020) with registered address Office 1309, 13th Floor, Creative Tower, Fujairah, United Arab Emirates
Online Fintech Pty Ltd - (Registration No: 2020/038412/07) with registered address 202 Beyers Naude Drive, Risidale, Randburg, 2195, South Africa
Online Fintech Private Limited - (Registration No: 0118138) with registered address 405 Royal Suit Plaza, E-11/2 Islamabad 44000, Pakistan.
Email – support@[base_title] | info@[base_title]
3. Collection of Information
A. Why AceTrade Tech collects information including Personal Data.
In order to better serve your particular needs, AceTrade Tech (and third parties working on behalf of
AceTrade Tech) may collect confidential information from and/or about you during the course of your
relationship with AceTrade Tech. Some of this information may be Personal Data. This confidential
information is collected through various methods including, but not limited to AceTrade Tech 's
platform(s), applications and websites. AceTrade Tech may also obtain information directly from you and
from third party sources. We may also use the standard "cookie" feature of major browser applications
and other data capture mechanisms that allow us to store data about you including, without limitation,
your visit to our platforms, applications and websites.
B. Specific information AceTrade Tech collects and how it is collected
i. General
AceTrade Tech collects several types of information when a data subject or automated system interacts
with AceTrade Tech, its platforms, applications, websites and service offerings. This information includes,
for example:
- Contact information including name, email, phone, fax and address of individual users of Broker
Solutions 's platforms, applications and websites
- Organization/Company name and customer type of individual users of AceTrade Tech 's
platforms, applications and websites
- National ID (e.g., driving license, Passport, CONCAT, tax Id) of users of AceTrade Tech 's platforms
where required by applicable law, for example by MIFID II.
- The browser types and versions used,
- System information related to the accessing of AceTrade Tech' platforms, applications, websites
and services including, without limitation, the website from which an accessing system reaches our website
(so-called referrers), the sub-websites, the date and time of access to the Internet site, an Internet protocol
address (IP address), the Internet service provider of the accessing system, and any other similar data
- Personal data of employees and agents relevant to their employment or work on behalf of Broker
Solutions including, name, email, phone, address, passport information, date of birth, photo, marital
status, spouse and dependent information, NIC#, bank account details, emergency contact information,
salary information, ethnic information (self- identifed) and past employment history.
ii. Cookies
The Internet pages of AceTrade Tech use cookies. Cookies are text files that are stored in a computer
system via an Internet browser. Many Internet sites and servers use cookies. Many cookies contain a so-
called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through
which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was
stored. This allows visited Internet sites and servers to differentiate the individual browser of the dates
subject from other Internet browsers that contain other cookies. A specific Internet browser can be
recognized and identifed using the unique cookie ID. Through the use of cookies, AceTrade Tech can
provide the users of this website with more user-friendly services that would not be possible without the
cookie setting. By means of a cookie, the information and offers on our website can be optimized with the
user in mind. Cookies allow AceTrade Tech to recognize our website users. The purpose of this recognition
is to make it easier for users to utilize AceTrade Tech 's website. The website user that uses cookies, e.g.,
does not have to enter access data each time the website is accessed, because this is taken over by the
website, and the cookie is thus stored on the user's computer system. The data subject may, at any time,
prevent the setting of cookies through the AceTrade Tech website by means of a corresponding setting
of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already
set cookies may be deleted at any time via an Internet browser or other software programs. This is possible
in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet
browser used, not all functions of our website may be entirely usable.
iii. Information about data subjects from third parties
AceTrade Tech obtains information including personal data from third parties. This occurs in two
contexts:
- Personal data about data subjects that are individuals that are employees or agents of Broker
Solutions 's institutional customers.
- Service providers to AceTrade Tech related to employment or retention of AceTrade Tech 's
employees or agents.
In such cases, AceTrade Tech is a Processor and not a Controller and AceTrade Tech processes the
information on behalf of or for the benefit of the Controller and relies on the Controller for obtaining
consent or other lawful purpose for processing the information.
4. What AceTrade Tech Does with the Information it collects
AceTrade Tech uses confidential information including Personal Data in: (i) authenticating and verifying
authorized use of our platforms, applications, websites, and services, and (ii) improving, offering and
administering platforms, applications, websites, and services. We may also use and disclose confidential
information and Personal Data in aggregate or statistical form which is not identifable with the submitter,
or as permitted/required by law. AceTrade Tech may also give information about the submitter, such as
AceTrade Tech
Online Fintech FZ LLC - (Registration No: 16396/2020) with registered address Office 1309, 13th Floor, Creative Tower, Fujairah, United Arab Emirates
Online Fintech Pty Ltd - (Registration No: 2020/038412/07) with registered address 202 Beyers Naude Drive, Risidale, Randburg, 2195, South Africa
Online Fintech Private Limited - (Registration No: 0118138) with registered address 405 Royal Suit Plaza, E-11/2 Islamabad 44000, Pakistan.
Email – support@[base_title] | info@[base_title]
name and address, to persons or organizations that may wish to provide you with information about their
or related products or services. These organizations may include affiliates of AceTrade Tech.
5. What is the lawful basis for AceTrade Tech controlling or processing the information:
AceTrade Tech will ensure that one of the following lawful bases exist for all confidential information
collected, including, Personal Data:
A. Information is required to be collected by contract – where the processing is necessary for the
performance of a contract. An example of this is when AceTrade Tech collects individual representative
information on customer contracts.
B. Compliance with legal/regulatory obligation: where the processing is necessary for Broker
Solutions to comply with a legal obligation under applicable law. An example of this is where Broker
Solutions collects identifying information, including National ID numbers, from traders using its platform
under MIFID II.
C. Legitimate interest: Examples of legitimate interests include fraud prevention and transferring
personal data within a group of companies or processing of personal data strictly necessary and
proportionate for the purposes of ensuring network and information security.
D. Consent: where the individual has given consent for their personal data to be processed for a
specific purpose. An example of this is where customers who are natural persons agree to use our website
applications, or when an employee of AceTrade Tech submits their personal information to our Human
Resources department.
E. Vital interests of individual. An example of this is if AceTrade Tech needed to process Personal
Data because it is necessary to protect the individual's or someone else's life.
F. The processing is in the interest of the relevant public.
6. What is the Period which AceTrade Tech will keep the information
The criteria used to determine the period of storage of confidential information including personal data is
the relevant lawful purpose for which it is held or 10 years, whichever is later. If the storage of the data is
no longer required as previously stated then the confidential information including personal data is blocked
or erased.
7. Rights of the data subject for information it collects
A. Right of confirmation
Each data subject shall have the right to obtain from the controller the confirmation as to whether or not
personal data concerning him or her are being processed. If a data subject wishes to avail himself of this
AceTrade Tech
Online Fintech FZ LLC - (Registration No: 16396/2020)
AceTrade Tech
Online Fintech FZ LLC - (Registration No: 16396/2020) with registered address Office 1309, 13th Floor, Creative Tower, Fujairah, United Arab Emirates
Online Fintech Pty Ltd - (Registration No: 2020/038412/07) with registered address 202 Beyers Naude Drive, Risidale, Randburg, 2195, South Africa
Online Fintech Private Limited - (Registration No: 0118138) with registered address 405 Royal Suit Plaza, E-11/2 Islamabad 44000, Pakistan.
Email – support@[base_title] | info@[base_title]
right of confirmation, he or she may, at any time, contact AceTrade Tech 's Data Protection staff at the
contact information stated herein.
B. Right of access
Each data subject shall have the right to obtain from the controller free information about his or her
personal data stored at any time and a copy of this information. Furthermore, the data subject may have
access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed,
in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible,
the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data,
or restriction of processing of personal data concerning the data subject, or to object to such
processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to
their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4)
of the GDPR and, at least in those cases, meaningful information about the logic involved, as well
as the significance and envisaged consequences of such processing for the data subject.
- Furthermore, the data subject shall have a right to obtain information as to whether personal data
are transferred to a third country or to an international organization. Where this is the case, the
data subject shall have the right to be informed of the appropriate safeguards relating to the
transfer.
C. Right to rectification
Each data subject shall have the right to obtain from the controller without undue delay the rectification
of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the
data subject shall have the right to have incomplete personal data completed, including by means of
providing a supplementary statement.
D. Right to erasure (Right to be forgotten)
Each data subject shall have the right to obtain from the controller the erasure of personal data concerning
him or her without undue delay, and the controller shall have the obligation to erase personal data without
undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected
or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of
Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal
ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no
overriding legitimate grounds for the processing, or the data subject objects to the processing
pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with applicable law.
- The personal data have been collected in relation to the offer of information society services
referred to in Article 8(1) of the GDPR. Where the controller has made personal data public and is
obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of
available technology and the cost of implementation, shall take reasonable steps, including
technical measures, to inform other controllers processing the personal data that the data subject
has requested erasure by such controllers of any links to, or copy or replication of, those personal
data, as far as processing is not required.
E. Right of restriction of processing
Each data subject shall have the right to obtain from the controller restriction of processing where
one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the
controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and
requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are
required by the data subject for the establishment, exercise or defense of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the
verification whether the legitimate grounds of the controller override those of the data subject.
F. Right to data portability
Each data subject shall have the right to receive the personal data concerning him or her, which was
provided to AceTrade Tech, in a structured, commonly used and machine-readable format. He or she
shall have the right to transmit that data to another controller without hindrance from AceTrade Tech ,
as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a)
of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the
processing is carried out by automated means, as long as the processing is not necessary for the
performance of a task carried out in the public interest or in the exercise of official authority vested in
AceTrade Tech. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of
AceTrade Tech
Online Fintech FZ LLC - (Registration No: 16396/2020) with registered address Office 1309, 13th Floor, Creative Tower, Fujairah, United Arab Emirates
Online Fintech Pty Ltd - (Registration No: 2020/038412/07) with registered address 202 Beyers Naude Drive, Risidale, Randburg, 2195, South Africa
Online Fintech Private Limited - (Registration No: 0118138) with registered address 405 Royal Suit Plaza, E-11/2 Islamabad 44000, Pakistan.
Email – support@[base_title] | info@[base_title]
the GDPR, the data subject shall have the right to have personal data transmitted directly from Broker
Solutions to another controller, where technically feasible and when doing so does not adversely affect the
rights and freedoms of others.
G. Right to object
Each data subject shall have the right to object, on grounds relating to his or her particular situation, at any
time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1)
of the GDPR. This also applies to profiling based on these provisions. AceTrade Tech shall no longer
process the personal data in the event of the objection, unless it can demonstrate compelling legitimate
grounds for the processing which override the interests, rights and freedoms of the data subject, or for the
establishment, exercise or defense of legal claims. If AceTrade Tech processes personal data for direct
marketing purposes, the data subject shall have the right to object at any time to processing of personal
data concerning him or her for such marketing. This applies to profiling to the extent that it is related to
such direct marketing. If the data subject objects to AceTrade Tech to the processing for direct marketing
purposes, AceTrade Tech will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object
to processing of personal data concerning him or her by AceTrade Tech for scientific or historical research
purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is
necessary for the performance of a task carried out for reasons of public interest.
H. Automated individual decision-making, including profiling
Each data subject shall have the right not to be subject to a decision based solely on automated processing,
including profiling, which produces legal effects concerning him or her, or similarly significantly affects him
or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract
between the data subject and a data controller, or (2) is not authorised by applicable law and which also
lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests,
or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject
and a data controller, or (2) it is based on the data subject's explicit consent, AceTrade Tech shall
implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests,
at least the right to obtain human intervention on the part of the controller, to express his or her point of
view and contest the decision.
I. Right to withdraw data protection consent
Each data subject shall have the right to withdraw his or her consent to processing of his or her personal
data at any time. If a data subject wishes to exercise the rights stated herein, he or she may, at any time,
contact AceTrade Tech 's privacy staff in writing at the contact information provided above.
8. Security — Data protection for applications and the application procedures
To help ensure the security of your confidential information that you submit to us via our platforms or Sites
that use HTTPS, we use security software to encrypt the information before and during its transmission
through the Internet. We allow information to be submitted for transmission only if your browser is
compatible with our security software. If your browser is not compatible, you will receive a message
indicating your transaction cannot be completed because of the security risk.
E-mail messages are not secure. Our security software does not encrypt e-mail messages. Please keep in
mind that transmitting information via the Internet is never completely secure and that, therefore, any
information submitted may be intercepted, viewed, collected, used, altered, copied or disclosed by others.
We are not responsible for the security or confidentiality of communications you send to us (or that we
send to you) through the Internet.
9. Links to Other Web Sites
AceTrade Tech 's applications and websites may contain links to other websites and applications of third
parties. Please note that when you click on one of these links, you will be accessing a website or application
that AceTrade Tech does not control and which may be governed by privacy policies and practices that
differ from AceTrade Tech'. AceTrade Tech is not, and will not be, responsible for the privacy policies
or practices of third parties or the content or security of any third-party websites and applications.