CONTENTS
- 1. Scope
- 2. What personal data do we hold about you?
- 3. No obligation to provide personal information.
- 4. What personal data we collect
- 5. Legal basis and grounds for processing personal data
- 6. Transfer of Personal Data to third parties
- 7. Cookies and third-party services.
- 8. Storage of personal data
- 9. International transfers
- 10. Security of personal data
- 11. Links to third-party websites.
- 12. Changes to this Policy
- 13. Your rights
Privacy Policy
We (also referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and privacy. The purpose of this Privacy Policy is to inform you how we collect and store the information you provide through the sirexohault website (the "Website").
We want you to be able to make an informed choice about the use and processing of your Personal Data. We use various methods and procedures to provide the necessary information. If we believe you need specific details, we will provide them at the appropriate time. We are happy to answer any questions about the limitations imposed by law.
1. Scope
1.1 This policy describes the types of Personal Data the Company collects about individuals, and how it is processed, transferred to third parties, protected and otherwise handled.
1.2 This Policy relates to information about an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or identified through a combination of additional information we hold or can access.
1.3 The Policy defines "processing" as any process related to the use or collection of Personal Data. This includes the processing, structuring and storage of Personal Data.
1.4 Our services are intended for a broad audience and not for use by persons under 18. We do not knowingly collect information from persons under 18 and do not request it. We do not knowingly allow such persons to use our services. If we become aware of any information about children, we will delete it as soon as possible.
2. What personal data do we hold about you?
2.1 When you access the service and channels or visit our website, we collect Personal Data. In certain cases we may request your Personal Data.
2.2 In other cases we collect your Personal Data by analysing how you use our Services or service channels, or by receiving your information from our third-party partners.
3. No obligation to provide personal information.
3.1 You are not obliged to provide any Personal Data to Us. Under certain circumstances you may refuse to provide any Personal Data to Us. However, this may prevent us from delivering the Services or prevent users from accessing the website.
4. What personal data we collect
4.1 This includes information about your online activity, including traffic data such as:
- IP-adres
- Date and time of access
- The language you used
- Software error logs
- The type of browser used
- Information about the device you used
4.2 This information is not personal information and cannot be used to identify you.
4.3 Personal Data we receive from you: any personal data you choose to provide to Us when you connect through Us with a third-party online trading platform.
4.4 Personal information you provide directly to third-party platforms to facilitate transactions: this includes your full name, address, phone number and email address.
5. Legal basis and grounds for processing personal data
5.1 Your Personal Data is processed by the Company for the purposes set out in this section and in accordance with the applicable legal basis.
5.2 Without a legal basis the Company may not use your Personal Data. The legal bases on which the Company may process your Personal Data are:
- You have given consent to the processing of your Personal Data for one or more reasons. This applies when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may require processing to pursue their legitimate interests. This may be necessary, for example, to improve Our Services or to defend against legal claims.
- The processing must comply with the requirements of the law.
5.3 Contact us by email for more details about processing necessary to protect legitimate interests.
5.4 Below is a list of the reasons and legal bases according to which we may use the information you provide to us:
Purpose
Legal basis
To provide your personal information to third parties at your request for access to digital trading.
At your request we may receive Personal Data from you to share it with third-party companies.
You have given consent to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions or enquiries
Personal Data is needed to answer your questions about the Services.
The legitimate interests of the Company or a third party require processing.
3. To comply with any legal, administrative or judicial obligations, Personal Data is processed in accordance with the law.
Processing is necessary to comply with legal obligations.
4. To improve Our Services. Personal
Data may be used by us to improve our Services. This includes, among other things, error reports we collect in connection with the Services.
The legitimate interests of the Company or a third party require processing.
5. To stop fraud and misuse of Our Services.
The legitimate interests of the Company or third parties require processing.
6. To carry out activities as required by Our Services
These activities include back-office functions, business development initiatives, strategic decision-making, oversight mechanisms and so on.
The legitimate interests of the Company or a third party require processing.
7. To carry out analyses, including statistical analyses
To make decisions on various matters, we use different analytical methods (including statistical methods).
The legitimate interests of the Company or third parties require processing.
8. To protect our assets, rights and interests and those of third parties
We may process Personal Data to protect our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements and any relevant terms, conditions or policies.
The legitimate interests of the Company or third parties must be taken into account.
6. Transfer of Personal Data to third parties
6.1 The Company may also transfer Personal Data to third-party companies that provide services to us, for example providers of web hosting and data storage, IP address information and user experience analysis.
6.2 You may also ask us to provide certain Personal Data about you to third-party trading platforms. In such cases we will pass the Personal Data you provided to those trading platforms. Use of your Personal Data is then governed by their privacy policies. Your Personal Data may be transferred to multiple trading platforms.
6.3 The Company may transfer Personal Data to related parties or business partners. This may give the Company the resources needed to improve the products and services it offers to its clients.
6.4 Where necessary to protect the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local or other official authorities.
6.5 We may also transfer your Personal Data to potential investors, buyers or creditors of the Company or any other company in the group if such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company in the group), or as part of any merger, restructuring, consolidation or liquidation involving the Company or any other entity in the group.
7. Cookies and third-party services.
7.1 Third-party services may be used, for example those that place advertisements on our website, or analytics companies. These companies may also use cookies or other technologies.
7.2 Cookies are small text files stored on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits, to improve the user experience, remember your preferences and tailor products and services that may be of interest to you. Cookies are also used for statistics and analysis.
7.3 Some cookies we use are session cookies. They are loaded temporarily on your device and stored only briefly before you close the browser. Other cookies are permanent. Permanent cookies remain on your device for a set period after the browser is closed. They help the Website identify you as a returning user and allow users to return to the website.
Cookie type
Strictly necessary cookies
Purpose
These cookies are needed to access the features you requested and to navigate our website. They are used to deliver the information, products and services you requested.
They are also needed so that your device can load and stream data. This allows you to move around the site, use its features and return to pages you previously visited.
Additional information
Cookies collect Personal Data, such as your username and the date of your last login, to confirm that you are signed in. They are deleted once the browser is closed (session cookies).
Cookie type
Functional cookies
Purpose
Cookies help us recognise you each time you visit our site and to preserve your preferences and settings.
Additional information
They remain valid until their expiry date and are retained even after the browser is closed.
Cookie type
Performance improvement cookies
Purpose
Cookies are used to collect statistical data about the operation of the site and to improve it. They also enable Us to analyse our website.
Additional information
Cookies store anonymous data that is not linked to any identifiable or identified natural person. They can be deleted when you close the browser. Other cookies remain valid for an indefinite period.
7.4 Cookies can be blocked or deleted. To prevent or delete cookies, you must change your browser settings. Below are links that will help you through this process for some of the most commonly used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 Please note, however, that some or all of the features and capabilities of the Website may not necessarily work as you expect in that case.
Online tracking notice: this service does not currently support "do not track" signals.
8. Storage of personal data
8.1 The Company will retain your Personal Data for as long as necessary to achieve the purpose of processing as described in this Policy, or for longer periods permitted by applicable laws, regulations, policies and orders.
8.2 We will transfer your information to third-party trading platforms within 12 months. If you agree, we will continue to transfer your data for a further 12 months.
8.3 We regularly review the Personal Data we retain to confirm it is no longer needed.
9. International transfers
9.1 Your personal information may be transferred to other countries (that is, your personal data may be transferred to a third country or international organisations). The Company takes all necessary measures to protect the Personal Data you provide and to ensure that users can enforce their rights and have access to effective remedies.
These protective measures and safeguards are available for all residents of the EEA (European Economic Area):
- Transfer to a third country or international organisation that, according to the EU Commission, offers adequate security for the Personal Data transferred to it, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer takes place pursuant to a legally binding and enforceable agreement between public authorities or bodies in the region. Article 46(2)(a)
- The transfer is carried out in accordance with the standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR.
9.3 The Company can provide information about the security measures it uses to protect your Personal Data when it is transferred to third countries or international organisations. Feel free to write by email: [email protected]
10. Security of personal data
10.1 We have put in place appropriate organisational and technical measures to protect Personal Data. This includes preventing accidental or unlawful destruction, loss or alteration of Personal Data.
10.2 We cannot guarantee that the security of your Personal Data will be flawless. We also cannot be held liable for any non-material, incidental or consequential losses arising from the use or disclosure of Personal Data. This includes, among other things, any Personal Data disclosed due to transmission errors, unauthorised access by a third party or any other cause beyond our control.
10.3 If legal or other obligations beyond our control arise, it may be necessary to provide your Personal Data to third parties, such as government authorities. In such cases we cannot control the security those third parties provide for your Personal Data.
10.4 Personal Data cannot be transferred over the internet in a completely secure manner. The Company cannot guarantee the security of Personal Data you send to Us over the internet.
11. Links to third-party websites.
11.1 The site contains links to third-party websites and applications. These websites and applications are not under the control of the Company. We are not responsible for the collection or processing of Personal Data by those websites or applications. This Policy does not apply to actions performed by such websites or applications.
11.2 When you visit third-party websites or applications, we recommend that you read their privacy policies before deciding to use or access their applications. Also be careful before providing any Personal Data to them.
12. Changes to this Policy
12.1 This Policy may be amended at any time. If we make changes to this Policy, we will notify you by posting the updated Policy on our website.
12.2 Further, when we make material changes to this Policy, we will endeavour to inform you by methods we consider appropriate, and publish a notice on our website.
12.3 Unless otherwise stated, any amendments take effect as soon as the revised Policy is published.
13. Your rights
13.1 You have the right to ask us to confirm the accuracy of the Personal Data collected about you, correct any errors and delete any Personal Data We no longer need. You may also restrict the scope of the types of processing of personal information.
13.2 If you are a resident of the EEA, go to this page. These rights are available to you with respect to the information you provide about your Personal Data. You may request the exercise of your rights by sending an email to the address below.
13.3 Right of accessThe Company can verify the accuracy of the Personal Data processed about you. In that case you may obtain access to your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be available in electronic format if you so request. The right of access to Personal Data must not conflict with the rights and freedoms of other persons. If a request harms the rights and freedoms of another person, the Company may refuse the request or limit compliance with it.
13.4 Right to rectification The Company has the right to correct inaccurate Personal Data. You have the right to demand the correction of any incomplete Personal Data about you, taking into account the purpose of the processing.
13.5 Right to erasureThe following reasons apply: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no legal basis for the processing; (c) you object at any time, for reasons particular to your circumstances, to the processing of your Personal Data based on legitimate interests pursued by Us or a third party; (e) the Personal Data is processed unlawfully; or (f) the Personal Data must be deleted to comply with the company's legal obligations. This right does not apply if the processing is necessary (a) to comply with a legal obligation that requires processing under the law of the European Union or of a Member State; or (b) to establish, exercise or defend legal rights.
13.6 Restriction of processingIf you have doubts about the accuracy of your Personal Data, you may ask the Company to restrict its processing. If you request a restriction on your Personal Data, it may only be retained with your consent, or to establish, exercise or defend legal rights, or to protect the rights of another natural person, or where there are important public interests in the European Union or a Member State.
13.7 Right to data portabilityIf the processing is carried out by an automated system and is based on your consent or on a contract to which you are a party, you have the legal right to receive the Personal Data you provided to the Company. You also have the right to demand that your Personal Data be transferred directly from the Company to another controller, if technically possible. Exercising your right to data portability does not affect your rights under the right to erasure. The right to data portability must not infringe the rights and freedoms of any other person.
13.8 Right to objectYou have the right to object at any time to any use of Personal Data about you that is based on legitimate interests of the Company or a third party. This right also applies to profiling based solely on such legitimate interests. If we can demonstrate compelling legitimate grounds for processing the Personal Data, we may continue, unless you prove that your rights, freedoms or interests outweigh those grounds, or unless the processing relates to the exercise, establishment or defence of legal rights. With regard to direct marketing, you have the right to object at any time to the processing of Personal Data about you.
13.9 Right to withdraw consentYou may withdraw your consent to our processing of your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before the withdrawal. You have the right to lodge a complaint with the authority that supervises you. You may also appeal to the supervisory authority appointed by a Member State to protect the fundamental rights of individuals with regard to the processing of Personal Data in the European Union. The laws of the European Union and of Member States may limit your rights with regard to your Personal Data, as described in this section 13.
13.10 We will provide the information about your rights that you request under section 13 of this agreement within one month of receiving your request. If necessary this period may be extended to two months, depending on the nature of the request and the number of requests. Within one month of receiving your request we will notify you of any extension and the reasons for it.
13.11 Provided that it does not conflict with the provisions of section 13 of the law, the information you request pursuant to your rights in section 13 will be provided free of charge. If a request is unfounded or excessive, especially if it is repeated, we may charge a reasonable fee to cover the administrative cost of providing the information or notifying the requested action. We may also refuse to act.
13.12 If we have doubts about the identity of the person who submitted your request, we may ask that person to provide reasonable identification.
This Privacy Policy should be read together with the Terms of Use and Risk Disclosure.
sirexohault, Level 12, 1 Macquarie Place, Sydney NSW 2000, Australia | [email protected]