Company") collects, uses arid manages the personal information received from its visitors,
active ahd/or potential clients who have terminated their business relationship with the
Company who are accessing or using the Company’s website(s) and mobile applications.
The Company is committed to safeguard the conﬁdentiality of your personal information or
data it collects, uses ahd/or holds in accordance with the applicable data protection laws and
regulations and particularly, the provisions of the Cayman Islands Data Protection Laws and
other applicable International Data Protection Regulations like the General Data Protection
regulation of 2016/679 (CDPR) (hereinafter ‘Data Protection Laws’).
Pursuant to the Data Protection Laws, the respective Company with whom you have
registered an account or have a business relationship with is the “Controller” of personal data
collected through https://universalfx.de, mobile applications and other platforms and is the
Company you should contact if you have questions about the use of your Personal Data; The
Company may transfer your personal data to the members ofthe UniversalFx Group of companies
under the Data Protection Laws and is always taking steps to ensure that the processing of
your Personal Data enjoys the same or at least an adequate level of protection.
The Company has established technical and other organisational measures and procedures as
appropriate in order to safeguard and protect your information and privacy as well as to ensure
that the Company manages or processes all personal information in compliance with the
1. Collection of Personal Data
During the account opening process for a demo or a trading account, you are requested to
complete and submit an application form by providing your personal information. The
provision of the information submitted by you will enable us to evaluate the application and
your eligibility to our services pursuant to the applicable laws and regulations governing the
provision of our services. The same information will be used by the Company to contact you
regarding the offered services.
The Personal Data collected by the Company might include (list not exhaustive):
Other than the information collected directly by you, the Company may also process
information about your transactions with the Company like the products you trade with the
Company and historical data ofyour transactions including, trading history or investments.
The Company is obligated by the regulations to keep your Personal Data on record for a period
of ﬁve years which is calculated after the execution of the transactions or the termination of
the business relationship.
2. Lawful basis for the use of Personal Data
The Company collects and process Personal Data which are required for the evaluation,
establishment and maintenance of the contractual relationship between the Company and
the Client and in order to comply with the applicable aforementioned data protection
legislation and regulations governing the provision of investment services, In some cases, the
Company may also process the Client’s Personal Data to pursue its legitimate interests or
those of third parties, provided that the Clients’ interests and fundamental rights are not
overridden by those of the Company or the third party.
In view of the above, the Company may use your personal information for one or more of
the following purposes:
The Company needs to comply with the Anti—Money Laundering regulations, therefore hard
copies and/or in electronic format copies shall be retained as evidence. Also the measures that
are taken by the Company in regards to your identity verification, source of income and wealth,
monitoring of your transactions, telephone/teXt/e—mail communication, and transaction
history must be kept to be able for the Company to demonstrate to the regulator that has
acted in accordance with the legislation.
Ifthere is no lawful basis, for the usage ofyour personal data as indicated above, your consent
will be required. The Companywill askforyour consent in regards to the provision of marketing
information in relation to the products and services offered in accordance with the Client
agreement between the contractual parties and/or any other mean of communication the
Company may use from time to time. Note that you may withdraw such consent at any given
time by sending an email to compliance©everfxglobalcom.
3. Disclosure of Personal Data
The Compa ny shall not disclose to a third party, any of your conﬁdential information unless it
is required to do so by a regulatory authority of a competent jurisdiction, the provisions of
applicable laws and regulations, there is a legitimate interest for such disclosure or duty to do
so or you have requested from us to proceed with a disclosure and/or you have consented to;
such disclosure shall occur on a ‘need—to know' basis, unless otherwise instructed by a
regulatory authority. Provided that such disclosure takes place, the Company shall expressly
inform the third party regarding the confidential nature ofthe information.
Any personal information is treated as confidential and may be shared within the Company
and its partners to meet its contractual and legal obligations. Contractual relationships exist
with the Company’s partners aiming to safeguard the Client’s personal data in accordance
with the Data Protection Laws. Our company partners maintain the privacy of your
information to the same extent the Company does in accordance with the policy. Non—
afﬁliated companies that assist the Company in providing services to you are required to
maintain the conﬁdentiality of such information and to use your personal information only in
the course of providing such services for the purposes that the Company dictates and within
the ambit ofthe applicable law. It is noted, however, that the use ofyour Personal Data by third
own privacy requirements and procedures.
4. Recipients of Personal Data may be:
5. Transfer Personal Data outside the Cayman Islands
The Company’s aim is to safeguard Personal Data when these are to be transferred outside the
Cayman IslandsAccording to Data Protection Laws, Personal Data can be transferred outside
the Cayman Islands if adequate protective measures are established, appropriate to the
safeguards dictated by Data Protection Laws.
The Company takes appropriate protective measures when Personal Data are disclosed to a
third party. The third parties that the Company may transmit Personal Data shall comply with
the Data Protection Laws or the legislation of their jurisdiction which has equivalent
In particular, you agree to the transfer and/or processing of your Personal Data outside the
Cayman Islands, as described in this section, by providing us with your Personal Data during
the account opening process and the submission of the information required to open and
maintain an account with the Company.
Cookies are small text ﬁles, given ID tags that are stored on your computer’s browser directory
or program data subfolders. Cookies are created when you use your browser to visit a website
left off, remember your registered login, theme selection, preferences, and other
customization functions. The website stores a corresponding ﬁle (with same ID tag) to the one
they set in your browser and in this ﬁle they can track and keep information on your
movements within the site and any information you may have voluntarily given while visiting
the website, such as email address.
Cookies are often indispensable for websites that have huge databases, need logins, have
customizable themes, other advanced features.
Cookies usually don’t contain much information except for the URL ofthe website that created
the cookie, the duration of the cookie’s abilities and effects, and a random number. Due to the
little amount of information a cookie contains, it usually cannot be used to reveal your identity
or personally identifying information.
There are two types of cookies: session cookies and persistent cookies. Session cookies are
created temporarily in your browser’s subfolder while you are visiting a website. Once you leave
the site, the session cookie is deleted. On the other hand, persistent cookie ﬁles remain in your
browser’s subfolder and are activated again once you visit the website that created that
particular cookie. A persistent cookie remains in the browser’s subfolder for the duration
period set within the cookie’s ﬁle.
browse our site correctly. The https://universalfx.de website issues cookies upon landing on
our website, unless the user has changed their cookie settings in their browser to refuse
cookies. Please note that with cookies switched off, some areas of our website and services
might not be made available to you.
that we use only collect anonymous information to optimize our services and do not collect
may refer to the Company's Cookies policy uploaded on the Company's website here.
The privacy and confidentiality of your personal information is of fundamental importance to
us. We take all appropriate security measures to protect against unauthorized access to or
unauthorized alteration, disclosure or destruction of data and personal information.
We restrict access to personal information to employees who need to know the specific
information in order to operate, develop or improve our services. These individuals are bound
by conﬁdentiality and will be subject to penalties If they fail to meet these obligations.
Also the Personal Data can be shared only with the parties set out in the aforementioned
section for Disclosure of Personal Data.
The Personal Data that you provide in connection with opening an account (appropriateness
/suitability test) with the Company are highly protected. This information can be accessed only
byyou using your own selected password and logins.The Company strongly recommends that
your password is carefully kept and not to be shared with any third party. In addition, this
information is safely stored in the Company’s servers that only authorized personnel have
access to it through access rights. The Company encrypts all this information to prevent
unauthorized parties from viewing or access such information.
8. Personal Data Rights
You have the following rights in respect of your Personal Data in accordance with the Data
9. Communication with the Company
You may exercise any of the above rights by contacting the Company as follows:
to you, provided that the Changes do not signiﬁcantly reduce your rights under this Policy. If
we make material changes to this policy, we will notify you by email or by means of a notice
on our home page or by Changing the version of the document including the date of the
update which will be visible to the first page ofthis document. The latest and prevailing version
of this Policy will at all times be available at https://www.even°xglobal.com. Any revised Policy
will be effective immediately upon posting on our Web Site.
11. Legal Disclaimer
The Company reserves the right to disclose your personally identifiable information as required
by rules and regulations and when the Company believes that disclosure is necessary to
protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal
process served. The Company will not be liable for misuse or loss of personal information
resulting from cookies on the Company’s siteIs) that the Company does not have access to or
control over. The Company will not be liable for unlawful or unauthorized use of your personal
information due to misuse or misplacement of your passwords, negligent or malicious.
Company’s contact details are:
Tel.: + 0013457695571 or 00380893240717
Address: Artemis House, Fort Street, KYI—III, Grand Cayman, Cayman Islands