Privacy Policy

General

By choosing to engage the services of Effort Trading Limited (“Company”), the Client fully agrees fully to the terms and conditions presented in the Company’s public documents. The same applies to the interactions between the Client and the Company, during which trading and investment operations are executed, various informational materials are used, payments and transfers are arranged, etc. Should the Client disagree with any condition of the public documents package, the Client should cease all interaction with the Company. In the event where the Client deems the conditions of the present Privacy Policy unacceptable for any reason whatsoever, they shall cease all interaction with the Company, including terminating all financial operations carried out with Company mediation.

The present Privacy Policy declares one of the important principles which the Company follows when providing the services to its Clients. The Company respects the right of every individual and legal unit for privacy irrespective of their being or not being the Clients of the Company, as well as those who only intend to interact with the Company. The conditions of the present Privacy Policy apply equally to former, present and future Clients of the Company. One of the most important priorities of the Company is the relationship between the Company and its Clients. The Company maintains loyalty and respect for every Client individually, and grants every Client perfect security and confidentiality.

Private Information

When the Client applies for or maintains a live or demo account with the Company, the Company collects personal information about the Client for business purposes, such as evaluating the Client’s financial needs, processing the Client’s requests and deals, informing the Client about products and services that may be of interest to him/her, and providing effective and quality service to the Client. Such information can be of the following types:

Transaction Information: information about deals between the Client and the Company, or between the Client and the Affiliated Partners of the Company, as well as information about communications (unilateral or bilateral) between the Client and the Company. Examples include Client account balances, trading (investing) activity, Client inquiries and the Company responses, including texts of the mails or log-files in used messaging systems. In the present Privacy Policy, the term “Affiliated Partners of the Company” refers to the organizations owned or run by the Company, as well as organizations that own part of Company property.

Registration information: information provided by the Client on application forms and other documents (including electronic documents). This includes: first name, last name, patronymic name, contact information (postal address, telephone number, e-mail, etc.), date of birth, occupation, assets and incomes.

Verification Information: information necessary to verify Client identity such as a passport or driver’s license (or articles of association in case the Client is a legal unit). Examples also include information received by the Company from public records, such as loan offices, information agencies and address bureaus or from other entities not affiliated with the Company. The Anti-Money Laundering Policy requires the Company to collect information and take the necessary action to prevent transformation and legalization (laundering) of money gained from illegal activity. In certain cases the Company has the right to require a document disclosing the sources of money.

Cookies

Cookies refer to small files containing information that a Web server (site) uses to track its visitors. The Company may set and access cookies on Client computers, to assess which advertisements and promotions draw users to the Company Web site. The Company (or any of its divisions) may use cookies to evaluate Client interest in Company products and services, and to track Client activities on its Web server (site). The information collected by the Company and shared with its Affiliated Partners is anonymous and not personally identifiable.

Sharing of Data with Third Parties

The Company does not disclose the Client’s personal information to third parties, except as described in this Privacy Policy. Third-party disclosures may include sharing such information with Non-Affiliated Partners of the Company that perform technical support services for Client accounts or facilitate Client deals with the Company, including those that provide professional, legal, or accounting advice to the Company. Non-affiliated Partners that assist the Company in providing services to the Clients are required to maintain the confidentiality of such information to the extent that they receive it, and to use this personal information only in the course of providing such services, and only for the purposes that the Company dictates.

The Company may also disclose the Client’s personal information to third parties to fulfill Client instructions or pursuant to the Client’s express consent. Company also informs its Clients that it shall never sell, place at interim disposal on a remuneration basis, distribute or disseminate the Client’s Personal information under any circumstances.

Disclosure of Client Information

Under limited circumstances, the Company may disclose the Client’s personal information to third parties as permitted by, or to comply with, applicable laws and regulations. The Company may disclose personal information to cooperate with regulatory authorities and law enforcement agencies in complying with subpoenas or other official requests, and as necessary to protect Company rights or property.

Except as described in the present Privacy Policy, the Company will not use the Client’s personal information for any other purpose unless the Company describes how such information will be used at the time the Client discloses it, or if the Company obtains the Client’s express permission.

The Company has the right to use the Client’s Personal information in cases other than described in the present Privacy Policy if clearly stated at the time the information is disclosed by the Client or when the Company receives the Client’s express permission.

Opt Out Policy

The Client may refuse to supply any of the Personal information that the Company may request. However, failure to do so may result in the Company being unable to open or maintain an account or to provide other services to the Client.

While the Company makes every effort to ensure that services, provided to its Clients are based on accurate, complete and up-to-date information about them, the Client can help considerably in this respect by promptly notifying the Company when there are changes to their personal information.

Should the Client does not wish to have their Personal information disclosed to third parties as described in the present Privacy Policy, they should contact the Company via specific contact form.

Acceptance of Privacy Policy

Being the Client of the Company, and actively using its services (including brokerage services and information services), software and/or hardware allowing to carry out professional activities in the financial markets, the Client accepts the Privacy Policy.

The Client agrees with all the provisions (clauses, sections) of all documents publicly declared by the Company during the period of use of any services of the Company, and in case of disagreement, the Client will immediately cease to use the Company’s services.