Privacy Policy
TABLE OF CONTENT
Last
Revised: February 2023
1.
INTRODUCTION
FBS Markets Inc. (hereinafter the “Company”,
“we”, “our”, or “us”) is
incorporated in Belize with Certificate of Incorporation No. 000001317.
The Company’s Business office is at 2118, Guava Street, Belize Belama Phase 1, Belize.
The protection of the security and privacy of your Personal Data is
important to us and to the way we conduct our business in compliance with the
laws on privacy, data protection, and data security.
This Privacy Policy, together with our Terms and Conditions applicable
to you and any additional provisions that may be incorporated by reference into
the terms apply to your use of our services, our site accessible from https://fbs.com (“Website”), and any of the services accessible through the Website and
our products (collectively referred to as “Service”).
The purpose of this Privacy Policy is to outline what information the Company
may collect, how it uses and safeguards that information, and with whom we may
share it.
2.
WHO WE ARE
FBS Markets Inc. is the data controller and is
responsible for your Personal Data.
Our full details are as follows:
·
Postal
address: 2118, Guava Street, Belize Belama Phase 1,
Belize
·
Email
address: support@fbs.com
3.
PERSONAL DATA
3.1.
Information We Collect
1.
We
will collect the following personally identifiable information (“Personal Data” ):
·
full
name (patronymic name if applicable)
·
password
·
phone
number
·
country
of residence
·
email
·
tax
identification numbers
·
financial
information
·
IP
address, geolocation
·
browser
type/version
·
operating
system
2.
Account/Personal
Area passwords are stored in the system and are not public information for
employees of the Company who do not need it for the purpose of providing
services to the Client.
3.
Through
its Website (s), the Company will not collect any Personal Data unless you
voluntarily choose to provide it (e.g., by registration, email inquiry, survey,
etc.). If you do not want your Personal Data to be collected, please do not
submit it.
4.
We
will process your Personal Data legally and fairly and will not use it outside
the purposes of which we have informed you, including selling it individually
or in the aggregate for commercial use.
5.
We
retain Personal Data in an identifiable format for the least amount of time
necessary to fulfill our legal or regulatory obligations and for our business
purposes. We may retain Personal Data for longer periods than required by law
if it is in our legitimate business interests and is not directly prohibited by
the applicable law. If your account is deleted, we may take steps to mask
Personal Data and other Data, but we reserve our right to retain and access the
data for as long as required to comply with applicable laws. We will continue
to use and disclose such Personal Data in accordance with this Policy.
6.
We
also collect, use, and share aggregated data, such as statistical or
demographic data, for any purpose (“Aggregated
Data”). Aggregated Data could be derived from your Personal Data but is not
considered Personal Data by the law as this data will not directly or
indirectly reveal your identity. For example, we may aggregate your usage data
to calculate the percentage of users accessing a specific software feature.
However, if we combine or connect Aggregated Data with your Personal Data so
that it can directly or indirectly identify you, we treat the combined data as
Personal Data which will be used in accordance with this Privacy Policy.
7.
We
do not collect any special categories of Personal Data about you. This includes
details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership, or data
about your health.
3.2.
KYC
During the Know Your Client (KYC) process, we are also
required by law to collect certain documentation in order to verify your true
identity, which may include, but is not limited to, proof of identity in the
form of Identity documents,
proof of your permanent residential address in the form of a utility bill, as
well as your credit card details (we request both sides of the bank card. The
front side must contain the first 6 digits and the last 4 digits of the card
number, the cardholder’s name, expiry date, and signature. For security purposes, we request clients cover the
CVC/CVV codes on the back side). User’s card data is not stored in our systems
since we do not have a PCI DSS certificate. For all that information, we rely
on our Payment Providers, who are duly certified.
3.3.
How We Acquire Your Data
1.
Information
may come from the following sources:
·
directly
from you (from our communication and/or forms that you filled in)
·
cookies
stored in your browser by our Website
·
IP-address
·
other
sources, including third parties and publicly available sources
2.
We
may combine that with information we collect via our services.
3.4.
Purposes
We collect Personal Data for the
following purposes:
1.
to
authenticate your access to an account;
2.
to
manage your account and keep you updated on all matters that concern your
account;
3.
to
provide the services that you have requested, including processing
transactions;
4.
to
respond to your requests, for example, to contact you about a question you
submitted to our customer service team;
5.
to
provide the functionality of our products;
6.
to
inform you about changes in our services, our service offering, and other
important service-related notices;
7.
to
protect our rights and interests, as well as the rights and interests of our
users and any other person;
8.
to
carry out any actions for which we have received your consent;
9.
to
perform research and analysis about your use of, or interest in, our products,
services, or content, or products, services, or content offered by others;
10.
to
comply with applicable legal or regulatory obligations, including complying
with requests from law enforcement or other governmental authorities or in
legal proceedings;
11.
to
fulfill our contractual obligations;
12.
to
communicate with you, either directly or through one of our partners, including
for customer service, to provide you with updates and other information
relating to the Website, and for marketing and promotional purposes;
13.
to
tailor the Website or other service we provide to you relating to your needs
and interests;
14.
to
create anonymous statistical data;
15.
to
prevent and investigate fraudulent or other criminal activity.
4.
DISCLOSURE OF INFORMATION
4.1. To Whom We Disclose Information
1.
Your
Personal Data may be disclosed to different recipients. The list below provides
some of the types of recipients and reasons for sharing your Personal Data.
|
Category of recipient |
Examples or explanation |
Share purpose |
|
Our affiliates |
Any legal
entity affiliated with the Company |
·
Providing
the basic services under the Terms and Conditions; ·
Organizing
the work of customer support service; ·
Any
other purpose deemed necessary by the Company. |
|
Financial
institutions and other similar organizations |
Any such
organizations that the Company deals with in the course of
its business |
·
Providing
the basic services under the Terms and Conditions; ·
Complying
with our legal obligations imposed by applicable laws (in certain cases
provided by law). |
|
Partner (Introducing
Broker Program participant) |
Those who had
been contracted to provide us with administrative, financial, insurance,
research, and/or other services. |
·
Providing
the basic services under the Company’s legal agreements; ·
Notifying
the Partner that someone has registered using their Partner IDs or other
identification tools or has unsubscribed from the Partner. In this case, we
can give your name and contact information to the Partner; ·
Communicating with you through one of our Partners, including
for customer service, to provide you with updates and other information
relating to the Website and for marketing and promotional purposes. |
|
Auditors,
lawyers, and other examination organizations |
Any entity
conducting an audit or other legal/financial check |
Complying with our legal obligations imposed by applicable laws (in
certain cases provided by law). |
|
Third-party
service providers whose activities are required to perform the service |
Web hosting,
information technology providers |
Providing the basic services under the Terms and Conditions. |
|
Payment
partners |
|
Enabling purchase opportunities within our services. These payment
processors are responsible for the processing of your Personal Data and may
use your Personal Data for their own purposes in accordance with their
Privacy Policies. |
|
Data
aggregation, analytics, and market research services |
Google
Analytics, Google Ads |
·
Creating
and utilizing analytics on our services and audience; ·
Conducting
advertising and marketing activity; ·
Conducting
surveys and research; ·
Personalizing
our services for you. |
|
Advertising
partners |
Any partners |
·
Conducting
advertising and marketing activity; ·
Personalizing
our services for you. |
|
Relevant
parties in the event of a change in control, merger, or acquisition |
|
As our business develops, we may sell or buy businesses or assets. In
the event of a corporate sale, merger, reorganization, dissolution, or
similar event, Personal Data may be part of the transferred assets. |
|
Authorities and
parties where relevant for compliance with various laws |
Any authority |
Compliance with our legal obligations imposed by applicable laws. |
2.
Please
note that we will never sell the Client’s Personal Data.
3.
In
general, we require that any third-party service provider that we share any Personal
Data with undertakes to respect any individual’s right to privacy and comply
with the Data Protection Principles. These third-party service providers may
keep a record of any searches they performed on our behalf, and they may use
the search details to assist other companies in performing their searches. This
Privacy Policy does not cover the practices of third parties.
4.
In
cases where the Client is
attached to a Partner, such Partner may have access to the Client’s information. Hence, the
Client hereby consents to share information with such
Partner. We provide Partners only the
minimum necessary data required for the purpose of the Partner Agreement.
4.2. Third-Party Sites
Please be notified that FBS Markets Inc. cannot
be held responsible for the privacy practices of other websites. We advise all
visitors to be aware and read the privacy statements of every Website that
collects personal identity information.
4.3. Payment Providers
In accordance with the recommendations of the
Payment Card Industry Security Standards Council, customer card details are
protected using Transport Layer encryption – TLS 1.2 and application layer with
algorithm AES and key length 256 bit.
4.4. International Transfers
1.
We
operate all over the world, and therefore we may transfer your data to our
counterparties (partners, affiliates, etc.) in different countries, including
those which are located outside the country in
which you are based. We take all necessary steps, including those imposed on us
by applicable law, to ensure an adequate level of Personal Data protection in
each case. However, we would like you to consider that the countries to
which we transfer your data may not have the same data protection laws as your jurisdiction.
2.
To
facilitate our global operations, the Company may transfer, store, and process
your operations with our partners and service providers based outside of the
country in which you are based. Laws in those countries may differ from the
laws applicable to your country of residence. Where we transfer, store, and
process your Personal Data outside of the country where you are based, we will ensure that the appropriate
safeguards are in place to ensure an adequate level of protection. Further
details regarding the relevant safeguards can be obtained from us upon request.
5.
CONSENT
1.
BY
SUBMITTING INFORMATION, INCLUDING PERSONAL DATA, YOU ARE EXPRESSLY AND
VOLUNTARILY ACCEPTING THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. YOU HAVE
THE RIGHT TO WITHDRAW YOUR CONSENT AND USE OF YOUR INFORMATION BY CHANGING YOUR
ACCOUNT SETTINGS OR CLOSING YOUR ACCOUNT, BUT YOUR WITHDRAWAL OF CONSENT WILL
NOT BE RETROACTIVE.
2.
You
should also be aware that we do not sell, rent, or disclose your Personal Data in
exchange for money or other valuable consideration to any third parties, and we
shall not incorporate such practice in our business unless providing you with a
clear and explicit way to exercise your opt-out right
and before introducing appropriate changes to this Policy.
3.
You
consent to transfer your Personal Data to third parties as described in Section
4.1. of this Privacy Policy, and as
described in this Privacy Policy, including to carry out your instructions or
to provide our services, for the purpose of notifying a Partner of a client’s
detachment unless otherwise compelled by law or as necessary to enforce our Terms
and Conditions or to protect the rights or property of the Company or its users
or the public. We may provide Aggregated Data about the usage of our Services
to third parties for purposes that we deem, in our sole discretion, to be
appropriate.
4.
We
will display the Personal Data you select on your profile page and elsewhere
according to the preferences you select in your account settings. This Personal
Data may be made available for public viewing to other Clients.
Marketing
mailings
1.
If
you provide us with your email address and agree to this Privacy Policy, our
partners and we may send you emails regarding the products we offer. You can
choose to opt out of receiving emails from us at any time. If you wish to opt
out with respect to more than one email address, you must provide a separate
request for each email address. Every email sent from us will include
appropriate unsubscribe instructions. To opt out of all email marketing
messages from us, you should follow the instructions provided with each email.
2.
If
you provide us with your telephone number and agree to this Privacy Policy, our
partners and we may send you texts or call you regarding the products we offer.
You can choose to opt out of receiving texts or calls from us at any time by
emailing us.
6.
YOUR LEGAL RIGHTS
In accordance with applicable law,
you may have the right to:
1.
access Personal Data about you;
2.
request correction of your Personal Data
where it is inaccurate, incomplete, or outdated;
3.
request deletion, anonymization, or
blocking of your Personal Data;
4.
request restriction of or object
to our processing of your Personal Data;
5.
withdraw your consent to our processing of your Personal Data;
6.
request data portability and receive an electronic copy of the Personal Data that you have provided to us;
7.
be informed about third parties with which your Personal Data has been shared;
8.
request the review of
decisions taken exclusively based on automated
processing if that could affect data subject rights.
7.
SECURITY
7.1.
Retention of Records
1.
We
may be requested to retain and use your Personal Data to meet our legal
obligations for data security purposes and as we believe to be fit and
necessary or appropriate for purposes that include, but are not limited to,
a.
compliance
with our requirements under applicable laws and regulations;
b.
responding
to requests from courts and/or other public and governmental authorities;
c.
monitoring
through compliance and anti-money laundering processes.
2.
We
will not keep your information for any longer than the time required. In many
cases, information must be kept for considerable periods of time. Retention
periods will be decided, considering the type of information that is collected
and the purpose for which it is collected, bearing in mind the requirements
applicable to the situation and the need to destroy outdated, unused
information at the earliest reasonable time. Under applicable regulations, we
will keep records containing Personal Data, trading information, account
opening and verification documents, communication, and anything else that is
relative to the Client for a maximum of seven (7) years after the termination
of the Agreement between you and our Company. In any event, we will keep your
information for a minimum duration as provided in the applicable Limitation of
Actions Law.
7.2.
Security Measures
1.
The
Company takes precautions to ensure the security of your Personal Data and
strives to keep it accurate.
2.
We
act with care to protect the Client’s Personal Data from loss, destruction,
falsification, manipulation, and unauthorized access or unauthorized disclosure.
To do so, we have developed and will maintain security procedures to safeguard Personal
Data against loss, theft, copying, and unauthorized disclosure, use, and/or
modification.
3.
Access
to Personal Data is limited to the company employees and authorized service
providers who require to receive it in
order to perform their work.
4.
While
we will use all reasonable efforts to safeguard the Client’s information, the Client
acknowledges that the use of the Internet is not entirely secure, and
therefore, we cannot provide any guarantee concerning the security or integrity
of any Personal Data transferred from or to the Client with the use of the Internet.
8. GENERAL
8.1.
Changes to the Privacy Policy
This Privacy Policy may be modified from time to time, thus,
check back often. To help you be aware if changes have been made, we will
adjust the “Last Revised” date or “Date of publication” at the beginning of
this document. The new Policy may be displayed on-screen, and you may be
required to read it to continue using the Service, Product, or Website.
Continued use of our products and services by you will constitute your
acceptance of any changes or revisions to this Policy.
8.2.
Compliance with Applicable Legislation
We are committed to complying with applicable privacy and
data protection laws and regulations designed to protect your Personal Data,
including the Data Protection Bill, 2021, and other applicable current or future
regional and state privacy and data protection laws and regulations worldwide
as they become effective.
8.3.
Prevailing Language
This document, as well as the Company’s
other legally-binding documents, is drawn up in
English. Any other version is provided as a translation. In the event
of a conflict between the translation and English versions, the English version
will prevail. To get acquainted with the English version of the document, go to
https://cdn.fbs.com/docs/privacy_policy_en.pdf.
8.4.
Questions, Problems, or Complaints
1.
You
can contact us at support@fbs.com if you have any questions, problems, or complaints
regarding this Privacy Policy.
2.
Contact
Details of DPO:
·
Email
address: dpo@fbs.com
·
Postal
address: 2118, Guava Street, Belize Belama Phase 1,
Belize City, Belize
