Data controller: Spotware Systems Ltd, a limited liability company incorporated in the Republic of Cyprus, with a registered address at 78 Spyrou Kyprianou, Magnum House, 3rd Floor, 3076 Limassol, Cyprus and incorporation number HE301668, owner of the Website spotware.com (hereinafter "Spotware" or "we").
Spotware, through its Website and other products listed below, collects and processes certain personal data relating to its users ("you" or the "user").
Personal data are any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more specific elements such as his or her physical, economic, cultural, or social identity (the "personal data").
Our Privacy Policy applies to all information and data relating to living, physical persons (“data subjects”) that are collected from various channels and sources, including our Website and through our products (cTrader Platform). Our Privacy Policy covers the different forms of interaction you can have with Spotware and classifies you in the following ways:
1) Brokers (direct clients), prospective or actual, contacting Spotware in the context of onboarding cTrader;
2) Traders (end users) opening demo cTrader accounts with Spotware;
3) Traders (end users) using Spotware products (cTrader) with a live and/or demo account via a broker offering the cTrader platform; and
4) Website’s visitors.
In accordance with the General Regulation of the European Parliament and of the Council on Data Protection No. 2016/679 of 27 April 2016 (the "GDPR"), in its current version, the purpose of this Privacy Policy (the "Policy") is to inform you about the data we collect about you, the processing we carry out and its purpose, the periods of retention of your data, the recipients of your data, as well as the rights you have.
The Policy complements the contractual conditions which govern the Website and which you accept by using the Website (as well as the other conditions which you accept for specific services or according to your status, hereafter jointly the "Terms").
Modification of the Policy
The Policy can be modified at any time. The current version is the one available on the Website. In the event of a significant change to the Policy, we will inform you within a reasonable period of time (by email or by banner ("push") on the Website).
Spotware may ask you at any time and by any means that can be recorded to confirm that you have read and understood the Policy.
Personal data collected on the Website
We collect your data mainly from you directly, but also from third parties who want you to benefit from our services, advertising partners and social networks, depending on the authorisations you provide them directly.
On our Website, the mandatory nature of the data to be provided is indicated to you at the time of collection (e.g., by an asterisk). If you do not fill in the mandatory fields, we will not be able to provide you with all our services.
Collection of Data
You will find below a list of all the data that we may collect and process about you, depending on your use of the Website and the authorisations you provide.
Information related to your identity and the creation of your account: full name, username, email address, phone number, password, date of birth or confirmation of majority, profile picture and other information that may be related to the creation of your account.
Information about your device, account and activity: IP address, session information, cookies and trackers, consent and refusal, date and time of consent, user profile, language, preferences, browser used by your device, content and URLs you connect to, date and time of your connections.
Information about your interactions with the Website and other users: name of the user you are communicating with, messages, date and time of messages, photos shared, other data indicated in messages, your comments and public messages on the Website.
Information relating to the management of the messages you write to us, the management of disputes and inappropriate behaviour: messages (requests, complaints) sent to customer service.
Sensitive data: We do not collect sensitive data. Any sensitive personal data collected and/or processed by us will be done so only with your explicit consent and never without your knowledge. In any case, we invite you to communicate only strictly necessary information.
Processing that we carry out to execute pre-contractual measures, and our EULA Terms and Conditions
We process your personal data in order to:
Processing that we carry out on the basis of our legitimate interests
This category of processing is based on our legitimate interests. In order to legally base a processing operation on legitimate interest, three cumulative conditions must be met: (i) the interest pursued must be legitimate (i.e. lawful, clearly and precisely determined, real and present); (ii) the processing carried out must be necessary and; (iii) the processing must not adversely affect the rights and interests of data subjects.
For your complete information, we detail below the processing operations and the corresponding legitimate interests. We have ensured that these processing operations do not infringe your fundamental rights and freedoms.
We process your personal data in order to:
Processing we carry out only with your consent
We process your personal data in order to:
Length of time personal data are kept
We retain your personal data for the strict period of time necessary to fulfil the purpose of the processing concerned. Thus:
Recipients to whom your data are transmitted
Spotware is committed to implementing and maintaining appropriate technical and organisational measures for the processing and security of personal data in accordance with Articles 32 to 34 of the GDPR in order to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. We pass on these obligations to our service providers and subcontractors.
Cookies
Spotware uses internet cookies to facilitate navigation throughout the Website and to enhance the visitor's experience. Your internet browser is likely to accept these cookies by default. However, you can refer to your browser’s help guide if you would like to reject or delete them from your system.
We may use both "analytic" cookies and "social" cookies on the Website.
Cookies used by Spotware do not retrieve any personal information or any information from the visitor’s computer.
Contact
If you have any further questions about how Spotware collects and processes your personal data, please contact us via our Data Protection Officer at dpo@spotware.com.