- ABOUT EXUBERANCE ASSET MANAGEMENT
- Exuberance Asset Management (EXUBERANCE) is a registered trading name of Exuberance FX Limited, which is authorized and regulated by the Financial Services Authority of The Saint Vincent & Grenadines (SVG FSA). EXUBERANCE is authorized by SVG FSA to deal, arrange, and manage Securities. We help traders and introducing Brokers achieve their business goals and personal ambitions by offering an extensive portfolio. Our business is built on integrity and trust, offering an industry leading combination of dynamic products, competitive trading parameters and premium, one-on-one service. It is EXUBERANCE’s mission to enable the personal ambitions and business goals of FOREX traders and IBs, through underpinning dynamic products with competitive trading parameters and a premium customer experience.
- If you have any questions about this policy or how we collect and use personal information about you please contact us using the contact details provided below. We also have a dedicated Data Compliance Officer, who is responsible for data compliance issues. Postal Address: Exuberance Asset Management 1902, UBORA Tower, Business Bay, Dubai, UAE Phone number: +971 4 4569573 Email: compliance@exuberance.com
- EXUBERANCE’S COMMITMENT
- EXUBERANCE is committed to protect the privacy of your personal and financial information obtained to enable us to provide you with a secure website for you transactions. This policy confirms details how EXUBERANCE manages the information provided to us by you or a third party in connection with our provision of services to you or which we collect from your use of our services via out website(s) and app(s). EXUBERANCE will use your personal information in accordance with this Privacy and Security Policy and otherwise in accordance with The SVG Data Protection (Privacy of Personal Information) Act and the United Kingdom data protection Privacy & Security Policy.
- Data protection regulations require that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained toyou and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
- REASONS FOR COLLECTING PERSONAL INFORMATION
- EXUBERANCE collects certain personal information in order that it may meet the needs of its customers. By collecting certain personal information, EXUBERANCE is able to monitor and improve the services which it offers to its existing and potential customers.
- EXUBERANCE will use this information for the following purposes: • verifying your identity; • assessing the suitability of the products and services we provide; • establishing and maintaining your account; • providing our services to you; • improving our services; • regulatory requirements; and • marketing.
- PERSONAL INFORMATION COLLECTED FROM YOU
- EXUBERANCE will collect and hold information about you when you complete an online application or other type of form or access and trade on your account through this website or another service we provide to you. The kind of personal information you give us may include (but is not limited to) name, address, date of birth, passport number, tax identification number, email address telephone number, employment and incomeinformation,credit/debitcardinformation,transactionhistoryandfinancial statements.
- EXUBERANCE may derive information from your use of this website or another service we provide to you and may store this information with your personal profile. This information may include site areas visited, pages viewed, frequency and duration of visits, types of transactions conducted, documents downloaded and other websites which may havereferred you ortowhich youlink.
- By opening an account with EXUBERANCE and by placing Orders and entering into transactions, you acknowledge that you will be providing personal information (possibly including sensitive data) within the meaning of The SVG Data Protection (Privacy of Personal Information) Act and the United Kingdom Data Protection Act 1998 or the General Data Protection Regulation “GDPR” or any other applicable laws and regulations to us, and you consent to the processing of that information by EXUBERANCE for the purposes of performing its obligations under this Agreement and administering the relationship between you and EXUBERANCE, including the disclosure of the information to Affiliates both within and outside The SVG, EuropeanUnionorEuropeanEconomicArea.
- EXUBERANCE needs certain information to carry out an agreement with you and you must provide this in order to enter into an agreement with EXUBERANCE to provide you with products and service. If you do not, we may not be able to offer you any products or services. Mandatory information fields are generally set out in the application.
- Other correspondence or interaction (for example by email, telephone, post, SMS or via our website) between you and EXUBERANCE, will include personal information (such as names and contact details) in that correspondence. This may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organization.
- EXUBERANCE may also collect details of phone numbers used to call our company and the date, time and duration of any calls. Please note that if we record your calls to or from EXUBERANCE, we will inform you of this.
- USE OF PERSONALINFORMATION
- EXUBERANCE may keep and use such information to comply with any legal requirements or if it is necessary for our legitimateinterest orfor any one ormore ofthe following purposes:
- To provide the services to you that you have requested including processing transactions.
- To confirm your identity.
- To maintain your personal profile.
- To manage your account.
- To contact you when necessary or appropriate in relation to the services being provided to you.
- To keep you updated whilst you are a customer in relation to matters such as contracts you have traded and activities of EXUBERANCE.
- To manage and administer the products and services provided to you.
- To provide you with information regarding the products and services offered by EXUBERANCE.
- To develop an understanding of the products and services that you may be interested in obtaining from EXUBERANCE.
- To provide you with information or opportunitiesthat we believe may be relevant to you.
- To tailor the website or other service we provide to you to your needs and interests.
- To create anonymised statistical data.
- You consent to EXUBERANCE using your personal information for the above-stated purposes.
- Where we use your personal information for marketing purposes to inform you about EXUBERANCE’s products and services that might be of interest to you, you always have the right to ‘opt out’ of receiving such a communication.
- You can exercise the right at anytime by contacting us using the details provided at the start of this policy. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials you will be added to our ‘suppression list’ to ensure we do not accidentally send you further marketing. Where you unsubscribe from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns. We may still need to contact your administrative for operational purposes, but we will make sure that those communications do not include direct marketing.
- If you are an existing customer or are acting as a business we use your contact details as necessary for our legitimate interestsinmarketing toyou and maintaining alistof potential customers.
- If you are not an existing customer, and are not acting as a business, we will only contact you for marketing purposes with your consent (whether we have collected your details directly from you, or through a third party).
- EXUBERANCE will only use your personal information for the purposes for which it collected it as set out in this policy, unlessEXUBERANCE reasonably considers a need to use it for another reason and that reason is compatible with the original purpose. If EXUBERANCE needs to use your personal information for an unrelated purpose, EXUBERANCE will notify you and will explain the legal basis which allowsto doso.
- EXUBERANCE may keep and use such information to comply with any legal requirements or if it is necessary for our legitimateinterest orfor any one ormore ofthe following purposes:
- DISCLOSURE AND SHARING OF PERSONAL INFORMATION
- EXUBERANCE does not sell, license or otherwise disclose your personal information to third parties for marketing purposes. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. EXUBERANCE may be required to provide your personal information to the SVG FSA and other regulatory and government bodies from time to time in SVG, the United Kingdom and other countries. EXUBERANCE may also disclose your personal information to:
- Financial institutions and other similar organizations that it deals with in the course of its corporate activities, or those that are nominated by you.
- External service providers and professional advisers (which may be located overseas) that provide services toEXUBERANCE.
- Any organization at your request or any persons acting on your behalf, including your financial adviser, broker, solicitor or accountant.
- Any third parties where this is necessary to process a transaction or provide services which you have requested;oranyauthoritytowhomEXUBERANCEisrequiredtodisclosesuchinformationbylaw.
- In the event that EXUBERANCE is subject to negotiations for the sale of its business (whole or party of), or sold to a third party or undergo a re-organization, you agree that any of your personal information which we hold may be disclosed to such party or its advisors as part of any due diligence process for the purpose of analysing any proposed sale or re-organization or transferred to that re-organized entity or third party and used for the same purposes as you have agreed to underthis Agreement.
- EXUBERANCE does not sell, license or otherwise disclose your personal information to third parties for marketing purposes. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. EXUBERANCE may be required to provide your personal information to the SVG FSA and other regulatory and government bodies from time to time in SVG, the United Kingdom and other countries. EXUBERANCE may also disclose your personal information to:
- YOUR RIGHTS
- You are not required to provide any personal information requested by EXUBERANCE. However, without that information, EXUBERANCE may be unable to open an account for you, where the information is requested in an Application form, or to provide you with any other services, information or assistance you have sought.
- Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the SVG FSA. Under certain circumstances, by law you have the rightto:
- Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is whyEXUBERANCE is providing you with the information in this policy. If you require any further information about how we use your personal information, please let us know.
- Request an access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information EXUBERANCE holds about you and to check that EXUBERANCE is lawfully processing it. EXUBERANCE may charge a nominal fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested.
- Request a correction of the personal information that EXUBERANCE holds about you. This enables you to have any incomplete orinaccurate information we hold about youcorrected.
- Request an erasure of your personal information. This enables you to ask EXUBERANCE to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where EXUBERANCE is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to EXUBERANCE using your information on this basis and EXUBERANCE does not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where EXUBERANCE is processing your personal information for direct marketing purposes.
- Request a restriction for processing your personal information. This enables you to ask EXUBERANCE to suspend the processing of personal information about you, for example if you want EXUBERANCE to establish its accuracy or the reason for processing it.
- Request a transfer of your personal information to another party where you provided it to EXUBERANCE and EXUBERANCE is using it based on your consent, or to carry out a contract with you, and EXUBERANCE processes it uses automated means.
- Withdrawal consent. In the limited circumstances where EXUBERANCE is relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once EXUBERANCE has received notification that you have withdrawn your consent, EXUBERANCE will no longer process your information for the purpose or purposes you originally agreed to, unless EXUBERANCE has another legitimate interestin doing so.
- Lodge a complaint. If you think that EXUBERANCE is using your information in a way which breaches data protection law, please contact us in the first instance using the contact details provided in section 1.2 of this Policy. You also have the right to raise a complaint with your national data protection supervisory authority (if you are in the United Kingdom,thiswillbe the ICO).
- UPDATING YOURINFORMATION
- You may inform EXUBERANCE at any time that your personal details have changed or that you wish EXUBERANCE to review, verify, correct or request erasure of your personal information, withdraw your consent to the processing or request that we transfer a copy of your personal information to another party. Please contact us via email at compliance@exuberance.com.
- EXUBERANCE will change or delete your personal information in accordance with your instructions, except to the extent that we are required to hold your personal information for regulatory or legal purposes, to provide you with the services you have requested or to maintain adequate business records.
- ACCESSING YOURINFORMATION
- Under The SVG, South Africa, Mauritius and United Kingdom data protection legislation, you have, subject to certain exceptions, The right to obtain copies of any personal information which EXUBERANCE holds about, the purposes for which they are being or are to be processed, and the recipients or classes of recipients to whom such information is or may be disclosed. You are entitled to inform EXUBERANCE of any inaccuracy in your personal information.
- If you wish to access any personal information EXUBERANCE may hold or wish EXUBERANCE to correct any Privacy & Security Policy misinformation please notify us in writing using the address provided at the start of this policy. EXUBERANCE may charge a fee (details of which are available upon request) for providing access to the information to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested.
- EXUBERANCE may need to request specific information from you to help to understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
- Please consider your request responsibly before submitting it. EXUBERANCE will respond to your request as soon as possible. Generally, this will be within one month from the date your request was received, if the request is going to take longerto deal with, EXUBERANCE will let you know.
- If you make a written request to us, we will also correct, delete and/or block personal information from further processing if thatinformation provesto be inaccurate.
- Please note that pursuant to The SVG Data Protection (Privacy of Personal Information Act and the United Kingdom Data Protection Act 1998) or the General Data Protection Regulation or any other applicable laws and regulations, certain information may be exempt from disclosure or EXUBERANCE may be unable to disclose information you request.
- COOKIES AND WEBSITE INFORMATION
- EXUBERANCE uses cookies (and other tools such as webpage counters or other analytics tools) to gather information about your access to this website and other services we provide to you. Cookies are small pieces of information which use a unique identification tag and are stored on your device as a result of you using this website or other service we provide to you. EXUBERANCE uses this as necessary for our legitimate interests in administering ourwebsite andto ensureitoperates effectively and securely.
- We, or third party advertisers, may also use this information to serve adverts on you. Where those adverts are targeted, this may involve using website information and information we (or our third party advertisers) have obtained from third parties. This will not include information such as your name or contact details. Where our adverts are displayed to you using your information, your information is used as necessary for our legitimate interestsin marketing to you.
- We keep this website information about you until the relevant cookie expires or is removed by you.
- When cookies are used by us, they collect statistical and factual information about how you use our services. Most internet browsers are set up to accept cookies. If you do not wish to receive cookies, you maybe able to change the settings of your browser to refuse all cookies or to have your computer notify you each time a cookie is sent to it, and thereby give yourself the choice whether to accept it or not. However, this may impair the quality of the services that we provide to you in relation to your account.
- We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
- Our website includes Advertising Features by Google, you acknowledge you adhere to the Google Advertising Features Policy, including rules around sensitive categories, have the necessary privacy disclosures and rights from your end users for such association, and that such data may be accessed and/or deleted by end users via My Activity. You acknowledge that you have the necessary rights from your end users, including disclosures in your privacy policy to share this data with Google.
- Our website may, from time to time, contain links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collector share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you toread the privacy policyofeverywebsite you visit.
- CONTENT INFORMATION
- This is information about you which you provide when you post content on EXUBERANCE’s website, social media and any other EXUBERANCE’s sites. This may include reviews, photographs, videos and other content.
- We may display and publish this information on our platforms as part of our contract with you or as necessary for ourlegitimate interestsin providing content tour users.
- This information is kept for as long as you have an account with us and may be retained and displayed indefinitely after you close your account.
- INFORMATION COLLECTED AT OUR PREMISES
- VISITOR INFORMATION -EXUBERANCE collects information about visitors to our premises. EXUBERANCE may record information on your visit, including the date and time, who you are visiting, your name, employer, contact details and vehicle registration number. If you have an accident at our premises, this may include a record of your accident.
- CCTV – EXUBERANCE may operate CCTV at our premises which may record you and your activities. We display notices to make it clear what areas are subject to surveillance. We only release footage following a warrant or formal request from law enforcement, or as necessary in relation to disputes.
- EXUBERANCE uses this information as necessary for our legitimate interests in administering your visit, ensuring site security and visitorsafety, and administering parking.
- STORAGE OFINFORMATION
- EXUBERANCE’s office headquarters are based in the SVG with a main data centre located in the United Kingdom also. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the United Kingdom and the EU.
- You acknowledge and agree that your personal information may be transferred within or outside the TheSVG, United Kingdom and European Economic Area (EEA). You agree that we will be permitted, if so required, to furnish relevant information concerning or your Trading Account(s) to any person who we believe to be seeking a reference or credit reference in good faith. The information we share may affect your ability to obtain credit. Please note that EXUBERANCE only transfers personal information to organizations outside The SVG if EXUBERANCE has assessed the organization as having appropriate controls and safeguards in place to protect your personal data.
- Some countries or organizations outside of TheSVG, United Kingdom and the European Union which we may transfer your information to will have an “adequacy decision” in place, meaning The SVG considers them to have an adequate data protection regime in place. Data may be transferred to, stored and processed in countries which do not offer “adequate protection” for the purposes of Directives of the SVG FSA for any purpose related to the operation of your Account. Such purposes include the processing of instructions and generation of confirmations, the operation of control systems; the operation of management information systems; the carrying out of such credit and identity checks as we may deem necessary or desirable; and allowing staff of any of our Affiliates who share responsibility for managing your relationship from other offices to view information about you. You agree that where it is necessary for the provision of these or other Services to you, we may transfer your information to persons who provide services to EXUBERANCE, including where those persons may be outside the EEA. You consent to EXUBERANCE’s processing and disclosing such information in accordance with EXUBERANCE’s Privacy and Security Policy published on EXUBERANCE’s website(s), asmay be updated from time to time.
- If we transfer data to countries or organizations outside of The SVG that does not have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required. To obtain more details of these safeguards, please contact us.
- DATA SECURITY
- EXUBERANCE takes security very seriously and adopts industry and information security best practices to protect your personal information and ensure it is not accessed by unauthorized persons. Measures include encryption of data during transmission, strong authentication mechanisms and secure access to machines and data.
- EXUBERANCE has put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, EXUBERANCE limits access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on EXUBERANCE’s instructions and they are subjectto a duty of confidentiality.
- EXUBERANCE has 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 necessary.
- RETENTION OFINFORMATION
General retention policy
- To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Generally, EXUBERANCE will keep your information for a period of five (5) years. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- Legal Claims – Where EXUBERANCE considers there to be a risk to defend or bring legal claims, EXUBERANCE may retain your personal information as necessary for a legitimate interest in ensuring that EXUBERANCE can properly bring or defend legal claims. EXUBERANCE may also need to share this information with insurers or legal advisers. How long EXUBERANCE keeps this information for will depend on the nature of the claim and how long EXUBERANCE considers there to be arisk thatwe will need to defend or bring a claim.
- In some circumstances EXUBERANCE may anonymize your personal information so that it can no longer be associated with you, in which case EXUBERANCE may use such information without further notice to you.
- YOUR CONSENT
- Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing this website or other service we provide to you, you consent to EXUBERANCE collecting, maintaining, using and disclosing personal information about you and provided by you or by another person as described above.
- AMENDMENTS TOPOLICY
- EXUBERANCE may make changes to this Privacy and Security Policy from time to time for any reason and will notify you of such changes by posting an updated version of this policy on this website or where appropriate, by email.
- You are responsible for regularly reviewing this Privacy and Security Policy and if you use this website or other service we provide to you after any changes are published, any such use shall constitute your agreement to those changes.
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