PRIVACY POLICY

  
Terms used but not otherwise defined in this Privacy Policy shall have the same meaning as in the Business Affiliate Agreement.
  
The protection of privacy and the safeguarding personal information is our highest priority.
  
Please view the following Privacy Statement which clearly explains how the Company collects, processes, stores and protects information.
  
While providing introductory services, the Affiliate will be exposed to End Users’ personal information. The Company will be exposed to personal information of the Affiliate and the End Users during the course of the Agreement. Therefore, the Affiliate hereby confirms that while providing services the Affiliate will strictly comply with the standards in this Privacy Policy. The Affiliate grants the Company its consent to such collection, processing, storage and use of personal information by the Company as explained below. Please be advised that the Company has limited access to End Users’ information possessed by the Company and that in any way the Company information held by the Company will not be disclosed to the Affiliate, unless required by law.
  
The collection of personal information
  
The Company collects the necessary information required to open, transact and safeguard End Users’ assets and to provide the End User with the services they require. To this end, the Company gathers information from the End Users and may, in certain circumstances, gather information from relevant banks and/or credit agencies, and/or other sources which help the Company profile the End Users’ requirements and preferences in an effort to provide better services. The Company may run similar checks on the Affiliate, in order to assess the business relationship between the party, service fees and to meet its legal constraints in practicing the referral business.
  
The information that the Company collects includes information required to communicate with and identify the Affiliate. This information may be of certain demographic information about the Affiliate individuals, including birth date, banking details, domiciliation, education, occupation, etc.
  
Usage of personal information
  
The Company uses personal information only as required to provide quality service and security to the Affiliate. This information helps improve services, customize browsing experience and enables the Company to inform the Affiliate of additional products, services or promotions and the Affiliate hereby agrees using this data for such purposes by the Company.
  
Should the Affiliate do not want to receive information of this nature for any reason, it shall contact the Company at the following address: [email protected]
  
Affiliates and Partners
 
 The Company may share information with affiliates in the event that such information is reasonably required by such affiliate in order to provide the products or services to the Affiliate. The Company may share information with partners, affiliates and alliances in order to offer additional similar products and services that meet the Affiliate needs and which are delivered in a manner that is useful and relevant only where the Affiliate have authorized the Company to do so.

Non-affiliated third parties
  
The Company does not sell, license, lease or otherwise disclose personal information to third parties, except as described in this policy.
  
The Company reserves the right to disclose personal information to third parties where required by law, regulatory, law enforcement or other government authority. The Company may also disclose information as necessary to credit reporting or collection agencies as reasonably required in order to provide the services to the Affiliate.
 
To help the Company improve its services, The Company may engage third parties to help carry out certain internal functions such as Fee processing, support service, introductory satisfaction surveys or other data collection activities relevant to the Company’s business. Use of the shared information is strictly limited to the performance of the above and is not permitted for any other purpose. All third parties with which the Company shares personal information are required to protect such personal information in accordance with all relevant legislation and in a manner similar to the way the Company protects the same. The Company will not share personal information with third parties which it considers will not afford the required level of protection.
  
Where the Affiliate has been referred to the Company by another Affiliate (“Master Affiliate”), such Master Affiliate may have access to the Affiliate’s information. The Affiliate hereby unambiguously and unequivocally consents to the sharing of information with such Master Affiliate.
  
The Affiliate acknowledge that in order to provide services to the Affiliate, it may be necessary for information to be transferred outside of the European Economic Area or any other jurisdiction the Company or the Affiliate act in, and the Affiliate consent to such transfer.
 
 Restriction of responsibility
 
 The Company is not responsible for the privacy policies or the content of the websites, nor other marketing material, the Company  may publish from time to time. The Company has no control of the use or protection of information provided by the Affiliate or the End User or collected from them by those websites. Whenever the Affiliate elects to link to a co-branded website or to a linked website, it may be asked to provide registration or other information. Please note that such information is recorded by a third party and will be governed by the privacy policy of that third party.
  
Use of ‘cookies’
  
The Company uses cookies to secure the Affiliate activities and to enhance the performance of its websites. Cookies used by the Company do not contain personal information or other sensitive information.
  
The Company may share web site usage statistics with reputable advertising companies and with its affiliated marketing companies. The information collected by the advertising company is not personally identifiable.
  
To administer and improve the Company’s websites, the Company may use third parties to track and analyze usage and statistical volume information. The third party may use cookies to track behavior and may set cookies on The Company’s behalf. These cookies do not contain any personally identifiable information.
 Privacy Statement Updates
 
 From time to time, the Company may update this policy. In the event the Company materially changes this policy including how the Company collects, process or use the Affiliate’s personal information, the revised policy will be posted to the Company’s websites. The Affiliate agrees to accept posting of a revised policy electronically on the Company’s websites as actual notice to the Affiliate. Any dispute over this policy is subject to this notice, the Agreement and the Code of Conduct of conduct the Company practice with the Affiliate. The Company encourages the Affiliate to periodically check back and review this policy so that it will always know what information the Company collects, how the Company uses it, and to whom, the Company may disclose it.



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