This Policy will be reviewed from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the business environment. Any information held will be governed by our most current Policy.
Using the Smart Trading Software’s platform is acceptance by you of our Policy.
By accessing our website including using any of the communication channels to contact us, we consider that you have read, understood and accepted the terms of this Policy and how we process any information you disclose to us. Moreover, you agree that this Policy, including any amendments will govern how we collect, store, use, share and in any other form process your personal data and your rights during our relationship and after its termination.
Application of this Policy
For the purposes of applicable international data protection laws, Smart Trading Software is the “controller” of personal information collected through the website, and Smart Trading Software is the company to contact if you have questions about the use of your personal information. The Policy also applies to personal data about each authorized representative of a client and about other persons or entities collected in the course of providing our services (such as directors of corporate clients if any).
What information do we collect?
If you sign up for an account or services, we will collect basic information about you including your name and email address. We will use the information that we collect about you to:
⇒ create and maintain your account;
⇒ allow you to log in to your account;
⇒ contact you about your account and/or the services that Smart Trading Software offers.
How do we use it?
We use information about you in the following ways:
⇒ We use your personal details and information obtained from other sources for the purpose of satisfying regulatory and legal requirements, for marketing, administration and customer services, to ensure that the content and services that we offer are tailored to your needs and interests. We keep your information for a reasonable period for these purposes. We may need to share your information with our service providers and agents. Generally, we require that third party organizations who handle or obtain personal information as service providers acknowledge its confidentiality and undertake to respect an individual's right to privacy and comply with Data Protection principles including this Policy.
⇒ We or agents acting on our behalf may perform identity, money laundering and fraud prevention checks and may pass your details onto other organizations (including law enforcement agencies) involved in fraud prevention and detection who may use your information in the same way.
⇒ By providing us with your personal information you consent to our processing your personal data for the above purposes. You also consent to us transferring your information, for the above purposes, to countries or jurisdictions which may not provide the same level of data protection as Republic of Bulgaria.
Confidentiality and Personal Data Protection
⇒ We may collect client information directly from you or from other persons including, for example, the credit reference agencies, fraud prevention agencies, banks, other financial institutions, third authentication service providers and the providers of public registers.
⇒ Client information which we hold is to be treated by us as confidential and will not be used for any purpose other than in connection with the provision, administration and improvement of the services on the website, anti-money laundering and due diligence checks, for research and statistical purposes and for marketing purposes. Information already in the public domain, or already possessed by Smart Trading Software without a duty of confidentiality will not be regarded as confidential.
⇒ Smart Trading Software has the right to disclose client information (including recordings and documents of a confidential nature) in the following circumstances:
⟩ Where required by law or a court order by a competent court.
⟩ Where requested by regulatory authority having control or jurisdiction over Smart Trading Software or the client or their associates or in whose territory Smart Trading Software has clients.
⟩ To relevant authorities to investigate or prevent fraud, money laundering or other illegal activity.
⟩ To credit reference and fraud prevention agencies, third authentication service providers, banks and other financial institutions for credit checking, fraud prevention, anti-money laundering purposes, identification or due diligence checks of the client. To do so they may check the details the client supplied against any particulars on any database (public or otherwise) to which they have access. They may also use client details in the future to assist other companies for verification purposes. A record of the search will be retained by Smart Trading Software.
⟩ To our professional advisors provided that in each case the relevant professional shall be informed about the confidential nature of such information and commit to the confidentiality herein obligations as well.
⟩ To other service providers who create, maintain or process databases (whether electronic or not), offer record keeping services, email transmission services, messaging services or similar services which aim to assist Smart Trading Software collect, store, process and use client information or get in touch with the client or improve the provision of the services on the platform.
⟩ To other service providers for statistical purposes in order to improve Smart Trading Software’s marketing, in such a case the data will be provided in an aggregate form.
⟩ To market research call centers that provide telephone or email surveys with the purpose to improve the services of Smart Trading Software, in such a case only the contact details data will be provided.
⟩ Where necessary in order for Smart Trading Software to defend or exercise its legal rights to any court or tribunal or arbitrator or Ombudsman or governmental authority.
⟩ At the client’s request or with the client’s consent.
⟩ To successors or assignees or transferees or buyers, within ten business days prior written notice to the client.
⟩ If the client is a natural person, Smart Trading Software will use, store, process and handle personal information provided by the client in connection with the provision of the services, in accordance of the GDPR and the Bulgarian Data Protection Act and Smart Trading Software is obliged to supply the client, on request, with a copy of personal data which it holds about the client (if any).
⇒ By entering into this Agreement, the client will be consenting to the transmittal of the client’s personal data outside the European Economic Area, according to the provisions of GDPR for the reasons specified above.
⇒ Telephone conversations (if any) between the client and Smart Trading Software may be recorded and kept by Smart Trading Software and recordings will be the sole property of Smart Trading Software.
⇒ The Client accepts that the Company may, for the purpose of administering the terms of the Agreement, from time to time, make direct contact with the client by telephone, fax, email, or post.
LEGAL BASE OF THE PROCESSING OF PERSONAL DATA:
When we process your personal data we will only do so in the following situations:
⇒ Entering into and performing the services on the website: If you have an account or have registered on the website, our legal basis for processing your personal information is that it is necessary for the performance of service to you. With respect to an account, this includes facilitating access to our platform, processing payments, etc.
⇒ For other justifiable grounds, including legal obligation and legitimate interests: We process your personal information where necessary to comply with legal and regulatory obligations we are under, and also where it is necessary for legitimate interests we have in conducting our business. These include without limitation:
⟩ Learning about your interests and preferences to contact you with information that is relevant to you and helping us target marketing communication and advertisements for our products and services so that they are more relevant to you.
⟩ Using your pseudonymised details to show you advertising for our products and services on social media platforms, such as Facebook or via other third-party advertising that may appear on other websites you use. The information shared with these platforms is pseudonymised to protect your personal data.
⟩ Analyzing and continually improving the Site and our services and helping us pilot test versions of the Site internally to develop new features and ensure the efficient running of website’s services.
⟩ Detecting and reducing fraud and credit risk.
USE AND MANAGEMENT OF COOKIES
We may obtain information about you by accessing cookies (text files which are stored by your computer or other access device) when you visit our website or use our services. Cookies store small pieces of information, such as names and email addresses. We are able to do this by using web beacons (also known as clear GIFS or web bugs). Web beacons do not store additional information on your computer but, by communicating with our cookies on your computer, they can remember things about our website which we use to improve your user experience.
We use functionality cookies to analyze how visitors use our website and to monitor website performance and function. This allows us to provide a high quality customer experience by quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular and which method of linking between website pages is most effective.
Functionality cookies are used by the platform to allow us to remember your preferences and identify you as a user, ensure your information is secure and to operate more reliably and efficiently. For example, cookies save you the trouble of typing in your username every time you access the platform, and recall your preferences, such as which language you wish to see when you log in.
Further information on deleting or controlling cookies is available at www.AboutCookies.org.
This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "analytical cookies" placed on your computer, to help the website analyze a user's use of the site. The information generated by the cookie about your use of the website (including your IP address) may be transmitted to and stored by Google on their servers. Google may use this information for evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
HOW DO WE PROTECT YOUR INFORMATION?
We take appropriate measures to ensure that the information you disclose to us is secure, accurate, up to date and kept only for so long as is necessary for the purposes stated, and in accordance with any statute of limitations. It is held in secure computer storage facilities and is subject to procedures to prevent accidental loss, destruction or damage.
You are entitled to ask for a copy of the information we hold about you (for which we may charge a small fee) and to have any inaccuracies in your information corrected. Please notify us of any changes of address or any other personal circumstances to enable us to maintain a correct record.
WHEN AND HOW TO CONTACT US
If your personal details change, if you have any queries about how we use your information, or wish to help us improve this Policy, please notify us by contacting us at: firstname.lastname@example.org. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
QUESTIONS OR COMPLAINTS:
If you have a concern about our processing of personal data that we are not able to resolve, you may have the right to lodge a complaint with the relevant authority where you reside or directly to the Bulgarian Commission for Protection of Personal Data, as follows:
To the attention of: Commission for Protection of Personal Data
Address: 2 Prof. Tsvetan Lazarov boulevard, Sofia – 1592, Bulgaria
Telephone: 02 915 3 518
You may opt out of receiving promotional emails or text messages from Smart Trading Software by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
The platform is not available for users under the age of 18 (or the age of legal consent for the jurisdiction the user is located in) (a “Minor”). We do not knowingly collect personal information from or about Minors. If you are a Minor, you should not download or use any of our services nor provide any personal information to us. If we become aware that a Minor has shared any information with us, we will delete such information. If you have any reason to believe that a minor has shared any information with us, please contact us immediately.
UPDATES TO THIS POLICY