Privacy Policy

TopTradeGroup > Conditions > Privacy Policy

Introduction

This Policy applies to TopTradeGroup and extends to and covers all operations and functions of TopTradeGroup.

This website is owned and operated by Widdershins Group LTD, company registration number: 2020/IBC00080 and registered address 8 Copthall, Roseau Valley, 00152 Commonwealth of Dominica.

All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by TopTradeGroup must abide by this Privacy Policy. TopTradeGroup makes this Policy available free of charge.

‘Credit information’ is personal information (other than sensitive information) that relates to an individual’s credit history or creditworthiness, and is further defined in the Privacy Act;
‘Disclosing’ information means providing information to persons outside TopTradeGroup’s ‘Individual’ means any persons whose personal information we collect, use or disclose;
‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
‘Privacy Officer’ means the contact person within TopTradeGroup for questions or complaints regarding TopTradeGroup’s handling of personal information;
‘Sensitive information’ is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences, and criminal record, and also includes health information;
‘Use’ of information means the use of information within TopTradeGroup.

What kind of personal information do we gather?

We collect and hold the following kinds of personal information about individuals:

name;
address;
contact details;
date of birth;
employment details;
bank account details;
trading history;
identification information (such as passport, utility bills, or drivers’ licenses) required to be collected and verified following the Anti-Money Laundering and Counter-Terrorism Financing Act 2006;
credit information (if expressly authorized by the individual); and
any other information that is relevant to the services that we provide.

How we collect personal information

We for the most part gather individual data straightforwardly from the person. For instance, when an individual presents a record application structure on the web, visits our site, calls us, or sends us correspondence we will gather individual data. Once in a while, we may gather individual data about the person from an outsider. At the point when we are furnished with individual data from an outsider, we will find a way to guarantee that the individual is or has been made mindful of the issues set out in this Privacy Policy. We may likewise gather credit data about a person from credit detailing bodies to help us in evaluating a person’s application to open a record.

TopTradeGroup won’t gather delicate data except if the individual has assented or an exclusion under the Privacy Act applies. These exemptions incorporate if the assortment is required or approved by law or is important to make a proper move according to suspected unlawful action or genuine offense.

On the off chance that the individual data we demand isn’t given by an individual, we will be unable to furnish the person with the advantage of our administrations or address their issues suitably.

Your right to complain about the relevant data protection supervisory authority; and if we intend to use automated decision making, including profiling to process your personal information, and a description of the automated decision-making process and consequences.

Unsolicited personal information

TopTradeGroup may receive unsolicited personal information about individuals. TopTradeGroup’s employees are required to notify the Privacy Officer of all unsolicited personal information received by them. We destroy all unsolicited personal information unless the personal information is relevant to TopTradeGroup’s purposes for collecting personal information.

About whom do we collect personal information?

The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals:

clients;
potential clients;
introducing brokers, affiliates, and money managers;
service providers or suppliers;
prospective employees, employees, and contractors; and
other third parties with whom we come into contact.

If necessary, we will also collect information about individuals such as:

trustees;
partners of legal partnerships;
company directors and officeholders;
agents nominated by the individual; and
other third parties dealing with us on a ‘one-off’ basis.

Why does TTG collect and hold personal information?

We may collect and hold the information about an individual for the following purposes:

to consider and assess an individual’s application to open a trading account;
assist TopTradeGroup in establishing and managing the individual’s trading account;
to notify individuals of margin calls;
to provide an individual with information about our services, market trends, or special offers;
to protect our business and other clients from fraudulent or unlawful activity;
to conduct our business and perform other management and administration tasks;

How might we use and disclose personal information?

TopTradeGroup may use and disclose personal information for the primary purposes for which it is collected for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorized by the Privacy Act.

TopTradeGroup will use your personal information for any of the following purposes:

planning, performing, managing, and administering your (or a third parties to whom you are related) contractual business relationship with us, e.g. providing support services or providing you with other services or things you may have requested;
maintaining and protecting the security of our products, services and websites or other systems, preventing and detecting security threats, fraud, or other criminal or malicious activities;
ensuring compliance with our legal and regulatory obligations. This may include sales record-keeping obligations for tax or other purposes and sending required notices or other disclosures, compliance screening or recording obligations (e.g. under antitrust laws, export laws, trade sanction and embargo laws or to prevent white-collar or money laundering crimes). In this context, we may be required to conduct automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists and to contact you to confirm your identity in case of a potential match, to record interaction with you which may be relevant for antitrust purposes and to report to or support investigations by competent supervisory, law enforcement or other public authorities;
solving disputes, enforcing our contractual agreements, and to establish, exercise, or defend legal claims.
where you have expressly given us your consent or otherwise legally permitted, we may process your data also for the following purposes:
communicating with you through the channels you have approved to keep you up to date on the latest announcements, special offers, and other information about TopTradeGroup’s products, technologies, and services (including marketing-related newsletters) as well as events and projects which we are pursuing.

Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or permitted by law.

We engage other people to perform services for us, which may involve that person handling the personal information we hold. In these situations, we prohibit that person from using personal information about the individual except for the specific purpose for which we supply it. We prohibit that person from using the individual’s information for direct marketing their products or services.

TopTradeGroup will attempt to destroy or de-identify sensitive information wherever possible. We also undertake to take reasonable steps to destroy or de-identify all personal information about an individual when it is no longer needed.

Who may obtain your information?

We may disclose personal information to:

a related entity of TopTradeGroup;
an agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, debt collectors, or marketing agencies;
organizations involved in a transfer or sale of all or part of our assets or business;
organizations involved in managing payments, including payment merchants and other financial institutions such as banks;
regulatory bodies, government agencies, law enforcement bodies, and courts;
liquidity providers;
trade repositories;
the individual’s introducing broker, co-account holder, or another authorized agent; and
anyone else to whom the individual authorizes us to disclose it or is required by law.
it is necessary for the performance of a contract with you or to take steps at your request before entering into such a contract;
it is necessary for our or a third party’s legitimate interests, always provided that such interests are not overridden by your interests or fundamental rights and freedoms. Our “legitimate interests” include our commercial interests in operating our business in a professional, sustainable manner, following all relevant legal and regulatory requirements (and bearing in mind our global presence);
it is necessary to protect your or another person’s vital interests;
it is necessary for the establishment, exercise or defense of legal claims (for example, to protect and defend our rights or property, and/or the rights or property of our clients);
for our compliance with our legal obligations; and
where we have obtained your specific or, where necessary, explicit consent to do so. We will in each case inform you about the processing of your data and your related rights before obtaining your consent.

As a general principle, you will provide us with your data entirely voluntarily; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which TopTradeGroup cannot take action without certain of your data, for example, because this personal data is required to process your orders, provide you with access to a web offering or newsletter, or to carry out a legally required compliance screening. In these cases, it will unfortunately not be possible for TopTradeGroup to provide you with what you request without the relevant personal data.

Sending information overseas

We are likely to disclose personal information to an individual’s introducing broker. It is impracticable to specify the countries in which these introducing brokers may be located, as this depends on the introducing broker the individual chooses to use. If an individual is unsure of the location of their introducing broker, they should contact their introducing broker or TopTradeGroup for further information. We also use cloud data storage providers, and the servers which store individuals’ personal information are located in the United States of America. TopTradeGroup may disclose personal information to other overseas recipients in the future, and the countries in which such recipients are likely to be located will be specified in this Privacy Policy (unless it is impracticable to do so).

We will not send personal information to recipients unless:

we have taken reasonable steps to ensure that the recipient does not breach the Act;
he recipient is subject to an information privacy scheme similar to the Privacy Act; or
the individual has consented to the disclosure.

Management of personal information

TopTradeGroup recognizes how important the security of personal information is to our clients. We will at all times seek to ensure that the personal information we collect and hold is protected from inference, misuse or loss, unauthorized access, modification, or disclosure. TopTradeGroup’s employees must respect the confidentiality of the personal information we collect.

We hold all of your personal information in secure computer storage facilities and paper-based files. About our computer storage facilities, we apply the following guidelines:

passwords are routinely checked;
we change employees’ access capabilities when they are assigned to a new position;
employees have restricted access to certain sections of the system;
the system automatically logs and reviews all external unauthorized access attempts;
the system automatically limits the amount of personal information appearing on any one screen;
unauthorized employees are barred from updating and editing personal information;
all personal computers which contain personal information are secured, physically and electronically;
data is encrypted during transmission over external networks; and
print reporting of data containing personal information is limited.

We will hold your personal information as long as required to provide you with the products or services, products, or information you have requested and to execute and administer your business relationship with us. We are also required to keep certain information (e.g. relating to the business or tax relevant transactions) for certain retention periods under applicable law. Your personal information will be promptly deleted when it is no longer required for these purposes.

How do we keep personal information accurate and up to date?

TopTradeGroup is committed to ensuring that the personal information it collects, holds, uses, and discloses is relevant, accurate, complete, and up-to-date. We encourage individuals to contact us to update any personal information we hold about them. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days unless the individual agrees otherwise. We do not charge individuals for correcting the information.

Access to personal information

Subject to the exceptions set out in the Privacy Act, individuals may gain access to the personal information that we hold about them by contacting the TopTradeGroup’s Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide the information, we will provide reasons for the refusal. An individual’s request for access to his or her personal information will be dealt with by allowing the individual to look at his or her personal information at the offices of TopTradeGroup, or by providing copies of the information requested. We will require identity verification and specification of the information required. An administrative fee for search and photocopying costs may be charged for providing access.

Updates to this policy

This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.

Responsibilities

It is the responsibility of management to inform employees and other relevant third parties about TopTradeGroup’s Privacy Policy, including any changes to the Privacy Policy. It is the responsibility of all employees and other relevant parties to ensure that they understand and comply with this Privacy Policy.

Privacy training

All new employees are provided with timely and appropriate access to TopTradeGroup’s Privacy Policy. All employees are provided with opportunities to attend privacy training, which covers TopTradeGroup’s obligations under the Privacy Act.

Non-compliance and disciplinary actions

Privacy breaches must be reported to management by employees and relevant third parties. Ignorance of TopTradeGroup’s Privacy Policy will not be an acceptable excuse for non-compliance. Employees or other relevant third parties that do not comply with TopTradeGroup’s Privacy Policy may be subject to disciplinary action.

Arrangements with third parties

TopTradeGroup should guarantee that all legally binding courses of action with outsiders enough location security issues. TopTradeGroup will make outsiders mindful of this Privacy Policy.

Outsiders will be needed to actualize approaches comparable to the administration of a person’s very own data as per the Privacy Act. These arrangements include:

regulating the assortment, use, and exposure of individual and touchy data;
de-distinguishing individual and touchy data at every possible opportunity;
ensuring that individual and delicate data is kept safely, with admittance to it simply by approved representatives or specialists of the outsiders; and
ensuring that the individual and delicate data is simply unveiled to associations that are endorsed by TopTradeGroup.

Electronic Verification Terms and Conditions

TopTradeGroup is required by St. Vincent & the Grenadines Anti-Money Laundering and Terrorist Financing Regulations 2014, as amended to verify your identity before we can provide you with financial products and services. Electronic verification allows us to verify your identity by using electronic tools and external data sources.

Electronic verification process

To verify your identity electronically, we will ask you for your details (such as your name, address, date of birth) and details of your identification documents. This information will be passed on to external organizations to electronically match your information with information on their databases. These organizations will assess and advise us whether all or some of the information you provided matches their records.

The external data sources used to verify your identity include:

Publicly available information such as the electoral roll and white pages
Information held by the official record holder via third party systems

Your agreement

By agreeing to our terms and conditions you affirm that:

The information you are providing us your personal information and you have the authority to provide it to us, and
We may use and disclose your personal information for electronic verification as described above.

Complaints handling

Should you wish to make a complaint we ask that you follow the process outlined below, this will aid us in resolving your complaint in the most efficient manner possible to regain your confidence.

Firstly, gather all supporting documents that relate to your complaint, think about the questions you want to be answered, and decide what you want us to do. Next, contact your account manager directly. Remember, if the problem is current a call at the earliest possible time will allow us to resolve your complaint immediately. If your account manager is unable to satisfactorily resolve your complaint, please ask them to refer the complaint to their manager. If your complaint is about your account manager, please ask to speak to our Compliance department.

If your complaint cannot be resolved then you may refer the matter to our Compliance department if we have not already done so. They will review your complaint and contact you directly.

You can also contact our Compliance team directly by sending an email to: [email protected]

We aim to resolve most matters within 21 days. However, some complaints are more complex and may take longer to resolve. If this is the case, we will keep you informed of our progress.