FDC Trade Asia is committed to ensuring the privacy of non-public information and personal data provided by all clients of the company as well as all visitors to and users of the website www.tradefdc.com (the website).
Please read the following Privacy and Personal Data Protection Policy (the Policy) to understand how FDC Trade Asia collects, uses, discloses, and protects the non-public information and personal data provided by you.
FDC Trade Asia will only use the non-public information and personal data it gathers in accordance with this Policy and the relevant regulation.
Data Protection Officer contact details:
You can contact our Data Protection Officer directly here:
Email: data@tradefdc.com
If a prospective client decides to open an account with FDC Trade Asia, there is certain information that will be required from them. This information includes, but is not limited to, personal data such as name, address, date and place of birth, phone number and other contact details, passport details, citizenship and tax status information, employment details, as well as other necessary financial information. The purpose for the collection of this information is to identify the prospective client and to assess whether the service requested by them is appropriate, before entering into an agreement.
Occasionally, FDC Trade Asia may request further information which will, on one hand, help improve the services it provides, and, on the other, is necessary in order to fulfill the regulatory duty to maintain the data through which it individualises a website user as its client in current form and volume.
FDC Trade Asia collects information from the following direct sources:
Tradefdc collects information indirectly through the use of cookies, which are addressed below in this Policy.
To ensure the security of information transfer, FDC Trade Asia uses an SSL certificate to encrypt information transmitted by or to the visitor through the website.
Special categories of data we process
In order to fulfill its obligations under MAMLA, FDC Trade Asia collects and processes information that may be considered to some extent as information about your political views (representing a special category of personal data under Regulation 2016/679). This personal data is collected on the basis of a legal obligation and therefore its processing by FDC Trade Asia is lawful.
FDC Trade Asia uses the non-public personal information containing personal data collected from clients in order to establish and service clients’ accounts for trading in financial instruments.
FDC Trade Asia will use the data collected from the client to establish their identity in accordance with the applicable law, as well as to enter into an agreement with the client for providing the services offered by the company. The data gathered will also be used to classify the client as professional or retail client – and with regard to this, to provide them with the legally established set of documents and other information, as well as to determine the client’s tax status for the purposes of the automatic exchange of financial information in the field of taxation.
Unless the client is informed otherwise, the non-public information and personal data that FDC Trade Asia holds and processes is also used for:
The grounds that entitle us to process client data are:
Processing is necessary in order to comply with our legal obligation arising from the following legal acts:
Measures against Money Laundering Act (MAMLA); Rules for Implementing of MAMLA (RIMAMLA); Measures against the Financing of Terrorism Act (MAFTA); Public Offering of Securities Act (POSA); Markets in Financial Instruments Act (MiFIA); Ordinance No. 38 of 25.07.2007 on the requirements to the activities of investment intermediaries (Ordinance № 38); and other.
FDC Trade Asia does not disclose clients’ non-public information and personal data to any non-affiliated third parties or to affiliated entities, except as permitted by applicable law.
Depending on the product or service concerned and particular restrictions on confidential information, personal client data and information may be disclosed to:
Any client, after submitting a written request, is entitled to access the personal data collected about them by FDC Trade Asia In the cases where the right of access granted to an individual may also lead to disclosure of personal data of third parties, FDC Trade Asia is obligated to provide to the relevant client access only to the part of the data referring solely to them. When exercising their right of access, any client of FDC Trade Asia is entitled to request at any time:
Any client is entitled to require, at any time, from FDC Trade Asia to:
At any time while FDC Trade Asia stores or processes their personal data, the client is entitled to:
The client has the right to request that FDC Trade Asia delete the personal data without undue delay in the presence of any of the following circumstances:
FDC Trade Asia may refuse to delete a client’s personal data due any of the following reasons:
The client may request that FDC Trade Asia restricts the processing of personal data, in which case the data will only be stored but not processed. The denial of restriction will explicitly be only in writing, and FDC Trade Asia is obliged to motivate the refusal with a legitimate reason;
In the event that FDC Trade Asia needs to use the personal data for a new purpose, FDC Trade Asia will provide a new data protection notice and when and where necessary, it will require a prior consent for the new processing.
If the client wishes to exercise any of the rights listed above, they should inform the company in writing. In that case, FDC Trade Asia may not be able to provide them with information about services and/or products requested by them, and also the products and services themselves; and with regard to this, FDC Trade Asia will have no liability to the client in respect of the same.
The client should inform FDC Trade Asia in a timely manner that their personal data has changed by providing their up-to-date data through the MyAccount section on FDC Trade Asia website.
The client should inform FDC Trade Asia if they wish their personal data to be deleted by sending an email to data@tradefdc.com.
FDC Trade Asia will change or delete a client’s personal data in accordance with their instructions, except to the extent, terms and manner that FDC Trade Asia is required to hold clients’ personal data for regulatory or legal purposes, in order to provide the client with the services they have requested, or due to the fact that it has provided the services during a past period, and must now maintain certain information until a certain regulatory deadline.
Clients’ non-public information and personal data are kept in a secure and strictly confidential manner; thay are accessed and used only by employees who service the client’s account, as well as by employees who exercise controlling functions.
FDC Trade Asia uses advanced security software and technology to ensure a safe and secure trading environment and to protect clients’ non-public personal, financial and trading information.
FDC Trade Asia encrypts all client personal data in order to be able to protect this data to the fullest extent possible.
It is FDC Trade Asia policy not to disclose non-public client information to third parties, except in legally defined cases.
The client has no obligation to provide any part of their non-public information or personal data that may be requested by FDC Trade Asia
The client’s refusal to provide the information or personal data requested by FDC Trade Asia may result in FDC Trade Asia inability to open or maintain the client’s account for trading in financial instruments, or to provide financial services to them.
Any changes to this Policy will be published promptly on FDC Trade Asia website and will serve as notification to clients.
By agreeing to accept this Privacy Policy, the clients’ grants permission to FDC Trade Asia to process their personal data only for the stated purposes.
The consent is necessary for FDC Trade Asia in order to process both types of personal data (ordinary and special), but it needs to be explicit.
In the cases where FDC Trade Asia requests a consent for special (sensitive) personal data, it will always be reasoned why and how this information will be used.
The client may withdraw its consent by a written request to FDC Trade Asia at any time.
This Policy shall be governed by and construed in accordance with the laws of the Republic of Bulgaria, and any disputes relating to this Policy shall be resolved between the parties themselves, and in case of failure to do so, they shall be subject to the jurisdiction of the courts of the Republic of Bulgaria.
