Privacy Policy

This policy describes how ACM INDEX handles the collection, storage, and protection of user information

Introduction

We are committed to protecting the privacy of your personal data. This policy explains how we collect and use the information that we collect about you when you use our services, and how we will protect it. It also provides you with the rights to access and modify your personal information.

We may change this policy from time to time. To ensure that we provide the best possible service to you, we will periodically update this Notice with new information.

If you are a customer or a potential customer, please note that this notice is for you. If you are an employee of ACM INDEX or a contractor to ACM INDEX, your personal information will be collected and used in connection with the contract or your contractual relationship.

This notice applies to ACMINDEX. The context of this notice applies to each of the group companies.

Similarly, any reference to ‘you’ or ‘yours' in this privacy notice refers to any of our customers or potential customers.

Before you become a client, you should understand that this notice applies to all information that you provide to us when you register with us. This notice also governs how we collect, use, and share your personal data.

Who are we?

This notice applies to the activities of the data controllers of the ACM INDEX group of companies. These companies are responsible for the collection, use, and sharing of personal information.

ACM INDEX Financial Services Limited is a SVG registered company that is responsible for the protection of your personal information.

ACM INDEX Financial Services Limited processes the personal data of its customers and non-European entities of the ACM INDEX in accordance with this notice.

What kind of personal information do we collect and store?

As part of our business we collect personal data from customers and potential customers that include the following:

Name, Surname and contact details

Date of birth and gender

The information that we collect about you includes your name, address, telephone number, email address, and financial and personal details such as your income and wealth.

Profession and employment details

Location data

Knowledge and experience in trading, risk tolerance and risk profile

IP address, device specifications and other information relating to your trading experience

Bank account, e-wallets and credit card details

We collect various types of information about you when you visit our website or our apps. This includes, but is not limited to, traffic data, weblogs, and other communication data.

We use cookies to store information about your use of our website. These small text files are used to collect and store information about your visit to our website. They can be used to improve the content of our website and provide other services. You can find more about our cookies policy at our website.

We also keep records of your trading behaviour, including a record of:

Information about the types of products and services that you have traded with us. This includes the amount of money that you have invested and the products and services that you have chosen.

You are required to provide us with certain details to identify you when opening a new account or transferring money to an existing account. This information is required to meet the standards set by anti-money laundering legislation. (a) Passport; (b) Driver’s licence; (c) National identity card (if applicable); (d) Utility bills; (e) Trust deed (if applicable); (f) A credit check on the individual; or (g) Other information we consider necessary to our functions and activities.

We also collect additional information when you are a corporate client. This includes information about the directors and officers of the company. We have the right to request this information if it is necessary to comply with our legal obligations.

We collect this information from various sources, such as your use of our websites and apps, registration forms, and other communication data. We use this information to improve our services and to provide you with more relevant and personalized content.

We also collect this information from third parties, such as marketing lists and social media platforms. These companies can use this information to contact you about their products and services.

We may also ask for other personal information from time to time. This may include information that is required to provide you with a specific product or service. If you do not provide this information, we may not be able to fulfill your request.

We may also record telephone conversations that we have with you in order to provide you with the best possible service. These recordings will be used to maintain and improve our relationship with you.

Further, if you visit any of our offices or premises, we may have CCTV which will record your image.

We also may record electronic communications, such as emails and telephone calls, in person or otherwise. These recordings will be used by us to maintain and improve our relationship with you.

Who may we disclose personal information to?

As part of our operations, we may disclose your personal information to other ACM INDEX group companies who provide related services and products.

These companies provide various services to us, such as administrative, technology, and analytics. They can also help us improve our operations and provide you with the best possible service.

They can also help us with various tasks and activities related to our business. Some of these include introducing you to other companies that we have a relationship with, processing your transactions, and providing advice.

Law enforcement agencies and government bodies that are required by law to carry out their duties can also help us with our operations.

If a third party is required to disclose your personal information in order to comply with our legal obligations, such as enforcing our terms and conditions of service, this party should inform you.

We only disclose the minimum amount of personal data that is required to provide our services to these parties. They are not permitted to use this information for any other purpose.

We may also collect information from third parties through our websites and apps. However, these sites are not subject to the same privacy standards and procedures as we.

When and how do we obtain your consent?

Depending on the purpose for which we are processing your data, we may choose to process it for one or more lawful bases.

The Lawful basis are the following:

To comply with our legal obligations and perform our legitimate interests, we will only process your personal information for the legitimate interests of the company.

If we do not require your consent to process your personal information, then you can freely give it to us and withdraw it at any time. This is done by contacting us using the details provided in this privacy notice.

We may collect and use personal information that you provide to us, such as your name, address, telephone number, and email address, for various purposes, such as marketing and promotional purposes. These include sending you marketing messages and providing analytical reports.

You have the right to opt out of receiving email communications from us by using the email address that you provided to us when registering to our online account.

Management of personal information.

We are committed to protecting the personal data that we collect and maintain. We will implement appropriate security measures to safeguard and prevent unauthorized access, destruction, and alteration of the data that we collect.

We have a Data Protection Officer who will oversee the management of the personal information that we collect and maintain.

We also require organizations that are not part of the ACM INDEX to comply with our privacy standards and procedures. They should also respect the rights of individuals to privacy

In brief, the data protection measures we have in place are the following:

We also train our employees to respect the privacy of our customers and the confidentiality of the personal information that they handle.

Our employees only have access to the information that they need to perform their duties and responsibilities.

We use encryption technologies to safeguard the data that we collect. These include the client access codes and internet transactions that are transmitted across our networks.

We also use various security measures to prevent unauthorized access to our systems. These include deploying security measures such as encryption and deploying intrusion detection systems.

We also use various security measures to safeguard the physical records that we keep in our facilities. These include employing security measures such as cameras and access cards.

How do we store personal information and for how long?

We store the personal information that we collect in various forms of secure storage. These include paper-based records and computer storage facilities.

We will only use the information that is needed to provide you with the services that you requested. If you no longer need the information, we will delete it.

We may sometimes need to maintain records for a long time. For instance, we are required to retain records related to our activities in order to comply with anti-money laundering laws and to maintain the integrity of our business relationship.

Records related to our business relationship with you must be maintained for a certain period of time after our relationship with you has ended.

If you provided us with personal information during the account opening process, this information will be maintained for a certain period of time.

In most cases, we will only use the information that we collect to send you marketing communications.

The personal information that we collect from you may be stored and processed outside the European Economic Area. This is done by staff members of our company who are located outside the EEA.

We may transfer the personal information that we collect to third parties outside the EEA depending on the contractual arrangements that are in place with those third parties.

If you would like a copy of such arrangements, please contact us using the contact details below

Your rights

Please note that these rights do not apply in all circumstances. You are entitled to:

(a) Request access to your personal data (commonly known as a “data subject access request;

(b) Request correction of the personal data that we hold about you;

(c) You have the right to request the removal of your personal data. However, we may not always be able to fulfill this request due to various legal reasons.

(d) In most cases, you can object to the processing of your personal data by us where it is necessary to provide a legitimate interest to us. This means that it impacts on your rights and freedoms.In some cases, we may be able to justify the processing of your personal data in order to provide a legitimate interest to you.

(e) In most cases, you can also request to suspend the processing of personal data that we collect. This allows you to request that we stop doing so.

If you want us to use the data in a way that is consistent with our obligations and legal obligations, you can also request that we erase it.

Even if you no longer need the data, we may still need it to provide you with the services that you have requested or defend legal claims that you have filed against us.

(f) To transfer your personal data, we will need to transfer it to a third party or to a structured format. This right only applies to the information that we use to perform a contract with you and to the extent that you previously provided us with consent.

(g) withdraw consent at any time where we are relying on consent to process your personal data.

To request the correction of your personal data, or to request the removal of your data, please send an email to [email protected].

Erasure requests can also be submitted through your online portal.

Generally, we try to respond to all your requests within 1 month. In some cases, it may take longer to receive your request due to the complexity of it.

We may charge a fee for certain requests, such as requests for more data, if the request is unreasonable or repetitive. In these cases, we will send you a fee request that will be required before we can fulfill your request.

What if you have a query or a complaint?

If you have a query or a complaint, you can contact us using the email address that you provided to us.

Occasionally, we may take longer to respond to some of your requests due to the complexity of them. In this case, we will send you an email within a month of receipt of your request.

If, after receiving a response to your query, you are not satisfied with the way we handled it, you have the right to file a complaint with the Data Protection Authorities of SVG Regulations.