Gromcapitals LLC respects your privacy and is committed to protecting and respecting your personal data. This privacy policy aims to give you information on how we collect and process any personal data i.e. information about a Client (as defined below) who is a natural person on the basis of which that Client can be identified (hereinafter the data) in accordance with the applicable data protection legislation and best practice.

We strive to create the most secure infrastructure of any broker in the world. In this privacy policy we would like to tell why you can trust us with your data and rest assured that your data is safe.

It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing your data about you so that you are fully aware of how and why we are using your data.

In this Privacy Policy, unless the context otherwise requires, expressions defined herein shall have the meaning ascribed to them in the Terms & Conditions.

Please note that this Privacy Policy is addressed to Clients and potential customers. If you are an Gromcapitals employee, a contractor to Gromcapitals or a third-party service provider, your personal information will be used in connection with your employment contract, your contractual relationship or in accordance with our separate policies which are available by contacting us at the contact details listed in the section OUR CONTACT DETAILS below.

1. WHO WE ARE

Gromcapitals LLC, is a company registered in St. Vincent and the Grenadines and having its registered address at Hinds Building, Kingstown, St. Vincent and the Grenadines (hereinafter Gromcapitals). Gromcapitals is the controller and responsible for the data of the Client disclosed to us in order to register for a Trading Account, Demo Account and/or to make use of any other services offered by the Gromcapitals Group (as defined in Appendix A) through the website (hereinafter “Website”) (this term shall at all times include Website’s desktop and mobile versions).

This Privacy Policy is issued on behalf of Gromcapitals Group so when we mention “Gromcapitals”, “Company”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Gromcapitals group responsible for collecting and/or processing your data when you use the Trading Platform through the Website, either for a Trading Account or a Demo Account (or their mobile/desktop versions) (hereinafter the Service(s)). In Gromcapitals we respect your privacy and therefore all companies within the Gromcapitals group are committed to protect your data, which it collects, uses and/or has access to.

If you are participating in our affiliate and/or introducing broker programs, we will process the data provided under our agreement with you to exercise our rights and perform our obligations under or in connection with the relevant agreement and the term Client in this Privacy Policy shall be read to include the term Affiliate and/or Introducing Broker (as applicable).

The Company takes measures to implement advanced data protection policies and procedures and to update them from time to time for the purpose of safeguarding the Client's data and the Client’s account. Your data is protected by the legal, administrative and technical measures that we take to ensure the privacy, integrity and accessibility of data. To prevent security incidents with your data, we use a mixed organizational and technical approach based on the results of annual risk assessment.

The Company shall not divulge any private information of its Clients and former Clients unless the Client approves in writing such disclosure or unless such disclosure is required under applicable law or is required in order to verify the Client's identity or it is required for Gromcapitals to perform its contractual obligations under any agreement concluded with the Client. The Clients' information is processed only by the employees of the Company and/or employees of the Gromcapitals group and/or trusted third parties which provide specific support services, dealing with the specific Client's Accounts and necessary for the provision of our services. All such information shall be stored on electronic and physical storage media according to applicable law.

2. DATA USAGE

1. 1. We may collect, use, store and transfer different kinds of data about you which we have grouped together as follows:
      • Identity Data includes first name, last name, and patronymic (if available), date of birth gender, passport, ID, Driver’s number, and copy of photo.
      • Contact Data includes billing address, email address and telephone numbers.
      • Financial Data includes bank account, payment card details and tax identification number (including but not limited to social security number, income tax identification number, national insurance number).
      • Transaction Data includes details about the transactions performed by you, details about payments, withdrawals, exchanges, trading history, profit, balance, deposited and withdrawal amount methods, and any other details in relation to the services you have made use of through our Website.
      • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, and other technologies on the devices you use to access the Website and use of cookies stored on your device.
      • Profile Data includes your Client’s account details, username and password, transactions made by you, your interests, preferences, feedback and/or information received through your interaction with us within the course of providing our services and survey responses.
      • Usage Data includes information about how you use the Website, products and services, registration date, account category, trading cluster, number of complaints, number of requests filed and IP history.
      • Marketing and Communication Data includes your preferences in receiving marketing from us and your communication preferences.
      • Special Categories of Data/ ‘Sensitive’ Data includes details about your religious belief, annual income, biometric data, and/or criminal convictions and offences.
      • Conformity Data includes details about your education, employment status, trading experience, self-assessment test.
      • Banking Data includes details of the number of payment wallets and/or information of your bank card, including information of the issuing bank, card number, cardholder name, card expiration date, payment system, card validation code (CVV2 / CVC2), and photos of both sides of the bank card.
      • Data in KYC (Know your customer) includes identity document information, including copies of recent dated Utility Bills, Identity Card, Passport, and/or Driver’s License.
      • Economic Profile Data includes details on occupation, purpose of investment, annual income, net wealth, expected annual amount of investment and sources of funds.
      • Location Data includes details on your actual location when interacting with our Website (for example, a set of parameters that determine regional settings of your interface, namely residency country, time zone, and the interface language).
      • Audio Data includes full voice recordings of calls that you receive from us or make to us.
        (the above collectively referred to as “Personal Data”)
   2. Aggregated Data includes statistical or demographic data for any purpose. Such data can be derived from your data but may not be considered personal data in law as it will not directly or indirectly reveal your identity. An example of such Aggregated Data could be that we aggregate your Usage Data to calculate the percentage of users accessing a specific website feature and/or services/product preference.
      Notwithstanding the above, if Gromcapitals combines Aggregate Data with data in a way that the end result can in any way identify the data subject, Gromcapitals shall treat such combined data as data which will be treated as per the provisions herein contained.
   3. Processing of your data is carried out by Gromcapitals following the principles of lawfulness, fairness, transparency, and always adhering to the intended purpose of data processing, the principle of data minimization, accuracy, limited data storage, data integrity, confidentiality and accountability.
   4. In general Gromcapitals collects and process the Personal Data, for any of the following reasons:
      1. To perform its contract with you,
      2. To comply with its legal obligations including without limitation to applicable anti-money laundering and terrorist financing laws and regulations (hereby referred to as Money-Laundering Law), and/or
      3. To safeguard its legitimate interest
   5. The Client acknowledges that all or part of the data concerning the Client's account and related transactions will be stored by the Gromcapitals and may be used by the Company in case of dispute between the Client and the Company.
   6. The Client is responsible for updating any data provided to us in case of any change. Although we will strive to keep your data up to date and review and inspect any information provided by you, we may not be able to always do so without your help. The Client acknowledges that Gromcapitals holds neither commitment nor responsibility to the Client due to any aforesaid review or inspection of information.

3. HOW IS YOU PERSONAL DATA COLLECTED?

1. We use different methods to collect data from and about you including through:
   1. Direct Interactions. You will provide to us your Identity, Contact and Financial Data online through the Website and/or by filling in online forms and/or by corresponding with us by emails or otherwise. Data may be submitted to us by you when you wish to:
      1. Register for a Trading Account;
      2. Register for a Demo Account;
      3. Subscribe to our publications and ongoing updates;
      4. Request marketing and promotions to be sent to you;
      5. Enter a competition, promotion or survey; and/or
      6. Give us feedback or contact us.
   2. We require to collect the above data in order that we are able to (i) provide our services efficiently, (ii) to comply with our ongoing legal obligations, including, inter alia, to prevent fraud and money laundering acts.
   3. If you fail to provide the data when requested we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during your relationship with us.
   4. Automated Technologies or Interactions.
      When using our services, your device automatically transmits to us its technical characteristics. Locale (a set of parameters that determine regional settings of your interface, namely, residence country, time zone and the interface language) is used for the purpose of providing you with the best possible service within our platform.
      Using the information about IP address, cookies files, information about browser and operating system used, the date and time of access to the site, and the requested pages addresses allows us to provide you with the optimal operation on our web application, mobile and/or desktop versions of our application and monitor your behaviour for the purpose of improving the efficiency and usability of our Services.
      We use web analytics tools to track performance of our website and marketing source of user by cookies in order to optimize our marketing costs and provide users with better experience.
      You may at any time request that we refrain from any such transmissions (to the degree this is possible and subject to any of our legal obligations) by sending your request to the DPO using our details in the OUR CONTACT DETAILS below using the registered email address you disclosed and registered with us through your Account. We will address your request within 30 business days.
   5. About Cookies.
      A cookie is a small amount of data that often includes a unique identifier that is sent to your computer or device browser from a website's computer and is stored on your device's hard drive for tracking site usage. A website may send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows. When you visit our Website, our system automatically collects information about your visit, such as your Technical Data, including inter alia to, your browser type, your IP address and the referring website.
      Cookies stored may determine the path the Client took on our site and used to anonymously identify repeat users of the website and what pages were most popular for Clients. However, the Company protects the Client’s privacy by not storing the Client’s names, personal details, emails, etc. Using cookies is an industry standard and is currently used by most major websites. Stored cookies allow the Website to be more user-friendly and efficient for Clients by allowing Gromcapitals to learn what information is more valued by Clients versus what isn’t. You can set your browser not to save any cookies of this website and you may also delete cookies automatically or manually. However, please note that by doing so you may not be able to use all the provided functions of our website in full.
      Please see our Cookies Policy for further details.

4. PURPOSE FOR WHICH WE WILL USE YOUR DATA AND ON WHAT LEGAL BASIS

1. 1. We process the aforementioned data in compliance with the applicable legislation as amended from time to time in order to (i) be able to perform our contractual obligations towards the Client and offer them the best possible service, (ii) provide our Services efficiently, (iii) comply with our legal obligations, including, inter alia, to prevent fraud and money laundering acts, and (iv) protect our legitimate interests and your vital interests.
   2. We process all data based on the following legal basis:
      1. For compliance with our legal obligations;
      2. For the performance of our contractual obligations towards the Client;
      3. For the purposes of safeguarding our legitimate interests and your interests and fundamental rights do not override those interests; and/or
      4. On the basis of your consent.
   3. Indicatively we set out below a description of all the ways we plan to use your data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process the data for more than one lawful ground depending on the specific purpose for which we are using your data.

-	PURPOSE ACTIVITY	TYPE OF DATA	LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
a.	1. To accept to register you as a Client 2. To notify you about changes to our terms or privacy policy 3. To communicate with you and provide you with secure identifications, authentication and support services 4. To confirm you are at age of majority as recognized and declared by the laws of your jurisdiction	1. Identity Data 2. Profile Data 3. Contact Data 4. Data in KYC 5. Financial Data 6. Economic Profile Data	1. Necessary to perform our contract with you 2. Necessary to comply with our legal obligations
b.	1. To perform our Scoring Processing under which a Client is scored on a scale basis with regard to the level of risk he is to Gromcapitals	1. Banking Data 2. Economic Profile Data	1. Necessary to perform our contract with you 2. Necessary to comply with our legal obligations
c.	1. To confirm the information provided by You under (a) above in relation to your location.	1. Location Data	1. Necessary to perform our contract with you 2. Necessary to comply with our legal obligations
d.	1. To secure authentication, identification and support services via social networks protocols and use the links to your accounts in social networks for these purposes.	1. Technical Data	1. Necessary to perform our contract with you 2. Necessary to comply with our legal obligations
e.	1. To process and deliver your transactions and requests (Deposits; Trades; Withdrawals) 2. Manage payments, fees and charges; 3. To collect and recover money owed to us.	1. Banking Data 2. Transaction Data	1. Necessary to perform our contract with you 2. Necessary for our legitimate interest (recover charges owed to us, make a withdrawal in case of breach of our contract)
f.	1. To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	1. Identity Data 2. Contact Data 3. Technical Data	1. Performance of our contract with you 2. Necessary to comply with our legal obligations 3. Necessary for our legitimate interests (take reasonable steps to confirm that you do not use any ways to manipulate our platform & for running our business, provision of administration and IT services, network security, to prevent fraud)
g.	1. To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you 2. To provide you with an optimal operation on our web application, mobile and/or desktop versions of our application and monitor your behavior for the purpose of improving the efficiency and usability of our services.	1. Identity Data 2. Contact Data 3. Profile Data 4. Usage Data Technical Data 5. Marketing and Communication Data	1. Necessary to perform our contract with you 2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business)
h.	1. to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy; 2. statutory limitations	1. Transaction Data	1. Necessary for our legitimate interests (including statutory limitations provisions by applicable laws)
i.	1. To inform you about any of the following: — new services and/or products we may offer; — Any new development and/or features of the current products/services we offer	1. Identity Data 2. Profile Data 3. Contact Data 4. Technical Data 5. Usage Data 6. Transactions 7. Marketing and Communication Data	1. Necessary to perform our contract with you 2. Necessary for our legitimate interests (to study how customers use our products/services, to develop our products/services and grow our business)
j.	1. To send direct marketing of our services to you always within the boundaries of our legitimate interests. 2. To send to you newsletters, push-messages and calls to keep you in touch with our new feature and new development of the current products/services we offer, news and events and the efficient provision of the full scope of our services. Please note that we will never use your data to communicate to you and/or promote any third party marketing material.	1. Identity Data 2. Profile Data 3. Contact Data 4. Data that may be provided by you during your activity at the Website. Marketing and Communication Data	1. Necessary to perform our contract with you 2. Necessary for our legitimate interests (to provide effective and personalized customer services to you and to update you in relation to our services that are available to you.
k.	1. To allow us to provide you with the optimal operation on our Website, mobile and desktop versions of our application and monitor your behavior for the purpose of improving the efficiency and usability of our Services. 2. To use analytics tools to track performance of the Website and marketing source of our Clients in order to optimize our marketing costs and provide you with better experience.	1. Location Data 2. Technical Data 3. Usage Data 4. Marketing and Communication Data	1. Necessary to perform our contract with you 2. Necessary for our legitimate interests (to provide effective and personalized customer services to you and to update you in relation to our services that are available to you).
l.	1. to allow us to monitor and train our employees for your benefit 2. to safeguard your or our interests in case of a dispute 3. to take steps for fraud prevention 4. to improve the services provided to you	Audio Data	1. Necessary to perform our contract with you 2. Necessary to comply with our legal obligations 3. Necessary for our legitimate interests
m.	1. To confirm that your annual income corresponds with your employment status 2. To confirm that you have no criminal history.	Sensitive Data	1. Necessary to comply with our legal obligations 2. Necessary to protect your vital interests.

4. If you are an existing Client of the Website where we have a legitimate interest in communicating with you, or if you have given us your consent we will collect and process your personal data to communicate with you in case of support and/or sending newsletters, push-messages and calls to keep you in touch with our new features, news and events and the efficient provision of the full scope of our services. We will also use your data to send you marketing information regarding our services that we believe may be of interest to you via email or otherwise.
5. Our Website is not intended for children and we do not knowingly collect data relating to children. As we do not allow users under the age of 18 to use our services, we need to obtain your birth date in order to confirm the Clients’ age checks.

5. OPTING OUT

If you do not want to receive any marketing newsletters or transmit your data to the third-parties for marketing purposes, you can configure your preferences. Such configuring can be done when (i) opening an account or (ii) when receiving such advertising content or (iii) by logging in and going to My Account > Personal Details > Notification Settings. You may also send to the Company, at any time, an email to