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Privacy Policy for the Newsletter

Dear User,

When you use our services, we process the personal data of our customers (“you“, “your” or the “Client“). This Privacy Policy (the “Policy“) provides you with information on how your data is processed.

In this Privacy Policy, you will find information regarding the following:

1. Who is the controller of your personal data and whom to contact?
2. What information do we collect about you and how do we obtain it?
3. How do we use your personal data?
4. How do we store personal data and how is it protected?
5. To whom do we make your personal data available?
6. Do we transfer your data to third countries and international organizations?
7. What are your rights and how can you exercise them?

1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA AND WHOM CAN YOU CONTACT?

The controller of personal data is CES FINANCIAL SERVICES FZCO, License Number: 55492, Address: Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates P.O. Box: 111311 (hereinafter referred to as “we“, “us“, “our Company” or “Controller“).
You can contact info@caisyprop.com for any questions and for the exercise of rights related to the processing of your personal data.

2. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE OBTAIN IT?

In this section, you can read general information about what personal data we collect and how we collect it. Detailed information on the purposes for which we process personal data is provided in Section 3 of this Policy. All information on the basis of which we can directly or indirectly identify you or which is related to you is considered personal data.
We obtain most of the data we collect about you directly from you in connection with your use of our services. This includes, in particular:

1. Data you provide to us yourself, in particular when you register on the website, enter information into your user account, order services, participate in our events and projects, or when you communicate with us through customer support or social networks. This includes identification and contact data, in particular first name, last name, phone number, email address, postal address, date of birth, username, password, and company identification number or tax registration number, if you are an entrepreneur; payment data, such as bank account details; other data, such as records of communication between you and our company or details of any warranty claims.

2. Data we collect automatically when you use our services. This includes data about your device (such as IP address, device type, operating system, browser used, connection provider); website usage data (such as date, time, and duration of visit, country from which you visit the website, website Browse history) and service usage data (such as login and logout information, account settings, fictitious capital value, account currency, business strategy).

Some data about you is provided to us by third parties, such as trading platform providers you choose for using our services and social network operators if you decide to link your social network accounts to an account on the website. This includes:

3. Data on simulated transactions you have completed (such as financial instrument type, position opening and closing time, investment amount, profit and loss) and social network data (username, profile picture, email address associated with the social network account). For information on how your personal data is processed by trading platform providers and social network operators for their own purposes, please refer to the privacy policies of those parties.

3. HOW DO WE USE YOUR PERSONAL DATA?

We use personal data for the following purposes:

• Registration and User Account
  To use our services, you must register on the Website and create your account, and we process personal data for this purpose.
  Personal data: Identification and contact data; we may also process your data related to your user account settings.
  Legal basis for processing: The processing is necessary for the performance of the contract, and the provision of this personal data is mandatory, as we cannot register your user account without it.


• Provision of Services and Exercise of Rights and Obligations Arising from the Contract between us and the Client
  To be able to provide you with our services, namely to provide you with access, relevant tools and support, and to carry out operations, we need to process your personal data. For this purpose, the following applies:
  Personal data: Identification and contact data and, in the case of paid services, also payment data, data on service usage, data on simulated operations, and, if you decide to link your social network accounts with the account on the website, also data from social networks.
  Legal basis for processing: The processing is necessary for the performance of the contract on the basis of which we provide our services or on the basis of our legitimate interest. After we stop providing you with services, we process personal information for a limited period of time. This processing is necessary for the purposes of exercising and protecting our rights based on our legitimate interests.


• Marketing Communication about Our Services and Products or Events We Participate In
  If you are a current or past customer of ours, we may from time to time send you marketing communications relating to our services. We may also send you commercial communications to the extent you give us your consent. Each of the emails sent will be marked as business communication, and each of them will contain a link with the help of which you can easily unsubscribe from business communications. For this purpose, the following applies:
  Personal data: Identification and contact data.
  Legal basis for processing: If we have provided you with our services, we may from time to time send you marketing communications based on our legitimate interest, namely to keep in touch with our customers. If you give us your consent to the processing of your data for marketing purposes, we process your data on the basis of the same.


• Customer Support and Communication
  If you use our customer support services, we will process your personal data. For this purpose, the following applies:
  Personal data: Identification data, contact data, other data, and data from social networks, if you contact us through social networks.
  Legal basis for processing: The processing is based on our legitimate interest, namely maintaining customer satisfaction and supporting the use of our services.


• Improving Services
  If you use some of our services, we will process your personal data in order to develop, test, and improve the services and enhance their security. For this purpose, the following applies:
  Personal data: Identification and contact data, device data, website usage data, service usage data, and simulated operation data.
  Legal basis for processing: The processing is based on our legitimate interest, namely improving our services.


• Analytics
  To gain insights into how our website and services are used, we analyze customer behavior. For this purpose, the following applies:
  Personal data: Identification data, contact data, payment data, data about your device, website usage data, service usage data, and simulated operation data.
  Legal basis for processing: The processing is based on our legitimate interest, namely determining customer behavior and estimating customer preferences.

4. HOW DO WE STORE PERSONAL DATA AND HOW IS IT PROTECTED?

We process your personal data in an encrypted database on computers and other devices. To ensure protection against unauthorized access or unauthorized alteration, disclosure, or destruction of the data we collect and process, we have adopted organizational and technical measures to protect them, which we strictly adhere to.

5. HOW LONG DO WE PROCESS YOUR DATA?

Personal data is processed to the extent necessary to fulfill the purposes described above and for the time necessary to achieve these purposes or for a period directly provided for by law. Thereafter, personal data is deleted or anonymized. We process personal data for the following periods of time:

1. For the purpose of performing the contract and for exercising rights and obligations in connection with the contract, including any complaints, resolution of claims for damages or related disputes, personal data is processed for the necessary period of time, but no longer than 10 years from the termination of the last contract;

2. For the purpose of sending commercial communications without your consent, personal data is processed for a maximum of 5 years from the expiration of the last contract between us or until you raise an objection or unsubscribe from commercial communications;

3. For the purpose of improving our services, we usually process personal data for a maximum period of 6 months;

4. For the purpose of fulfilling our legal obligations, we process personal data for the period established by relevant legal regulations (e.g., in accordance with tax regulations for a period of 10 years from the issuance of relevant documents for your order);

5. If you have given your consent, for the period specified in the consent.

6. DATA SHARING AND TRANSFERS TO THIRD COUNTRIES

We make your data available or transfer it to persons who help us provide our services, in particular the following persons:

1. The trading platform provider, to enable you to execute simulated operations.

2. Other third parties who help us operate our website and provide our services (such as other companies in our group, hosting and cloud service providers, payment system operators and financial institutions, providers of customer support tools and services, IT companies and system administrators, marketing and communication agencies, consultants, and postal service providers);

In addition, we may transfer your data to persons for whom you give your consent, as well as in cases where it is our obligation under law or a court decision or any other legally binding decision. Each of these entities to whom personal data is transferred is contractually obliged to protect your personal data in accordance with legal provisions and to process the data solely according to our instructions.

Some third parties collect personal data for their own purposes as data controllers. In such cases, their own rules for processing personal data apply.

7. YOUR RIGHTS

You can exercise all your rights mentioned below, including your right to erasure of personal data and withdrawal of your consent, by sending us a request via email to info@caisyprop.com, alternatively you can use our contact details in Section 1 of this Privacy Policy. There are no specific words you must use in your request, but please be specific enough so we can assist you with your request (e.g., identify yourself, specify the right you wish to exercise, what action you wish us to take, details on what personal data you wish to delete, etc.)

In relation to the processing of personal data, you have the following rights:

• Right of Access to Personal Data
  You can ask us at any time to send you a confirmation of whether or not your personal data is being processed. If we process your data, we will provide you with further details on the processing. If you request it, we will also provide you with a copy of the processed personal data. Please note that the first copy is free, but subsequent copies will be provided with a small surcharge.


• Right to Rectification of Personal Data
  If we process your personal data inaccurately, you can inform us of this fact and we will correct the inaccurate personal data without undue delay. If you register on the website, you will be able to rectify and amend your personal data by editing your user account.


• Right to Erasure of Personal Data (“right to be forgotten”)
  You have the right to obtain from us the erasure of personal data concerning you without undue delay in the following cases:
  
  
  • If the data is no longer necessary in relation to the purposes for which we collected or otherwise processed it;
  • If you withdraw your consent to their processing and, at the same time, there is no other legal basis for their processing (this applies only in cases where we process personal data based on your consent);
  • If you object and there are no overriding legitimate grounds for the processing, or if you object to processing for direct marketing purposes;
  • If your personal data is processed unlawfully.

  We will not be able to act on the request for erasure of personal data if their processing is necessary for the exercise of the right to freedom of expression and information, for compliance with any of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise, or defense of our legal claims, or for other reasons provided by law.



• Right to Restriction of Processing

  In the cases indicated in Article 18 of the GDPR, you have the right to obtain from us the restriction of processing of your personal data for a certain period.



• Right to Data Portability and Provision of Data in a Machine-Readable Format

  In the case of automated processing based on your consent or the performance of the contract, you have the right to receive the data in a structured, commonly used, and machine-readable format and to have it transmitted by us to another personal data controller.



• Right to Object

  If we process personal data based on our legitimate interest, you have the right to object to such processing. If you submit such an objection, we will not be able to process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests or rights and freedoms, or for the establishment, exercise or defense of our legal claims.
  In the event that we process your personal data for marketing purposes regarding our products and services, we will stop processing without undue delay upon receipt of the objection. In such a case, we will no longer be able to send you offers of our products and services.



• Right to Withdraw Consent

  If the processing is based on your consent, you have the right to withdraw such consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent given before its withdrawal.



• Right Not to be Subject to Automated Decision-Making Processes

  Except in cases where processing is necessary for the conclusion or performance of a contract, where this is permitted by applicable law or based on your explicit consent, you have the right not to be subject to any decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.



• Right to Lodge a Complaint with the Supervisory Authority

  If you believe that we are processing your data in violation of relevant legal regulations, you can lodge a complaint with the competent supervisory authority. Based on our registered office, our competent supervisory authority is the Office for Personal Data Protection with address: Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates P.O. Box: 111311

8. FINAL PROVISIONS

We may amend this policy unilaterally, but we will only do so when necessary and will inform you of such amendment. You can find the latest version of this policy in your Client Area.