Who we are?
Goldcopytrade LTD ("us", "our" or "we") collects, uses and is responsible for certain personal information
about you. When we do so we are regulated under the General Data Protection Regulation which applies
across the European Union and we are responsible as "controller" of that personal information for the
purposes of those laws.
Data Controllers and Contracting Parties
Regardless of whether you reside inside or outside the "Designated Countries", Goldcopytrade will be
the controller of your personal data provided to, or collected by or for, or processed in connection with
our services and regulated activities.
Whether information has to be provided by you, and if so why
The provision of "Your Data" is required from you to enable us to provide our services. We will inform you
at the point of collecting information from you, whether you are required to provide the information to
Information collected by us
In the course of your registration as a client, signing up for a demo or a live account with Goldcopytade
or filling in any form on our Website, subscribing to our services, news or offers, marketing
communications or posting material, the following information about you ("Your Data") will be collected
and stored for administrative, service related and/or legal purposes
We will limit the collection of personal information to what is necessary to administer our business and
carry out our regulated activities in an effort to provide you with superior service,
Information that you provide to us directly:
• Personal information, such as names, addresses, personal registration number, national
identification number, passport number and email addresses etc ("Personal Information"), and
• Financial Information, trading experience and employment information for appropriateness
assessment will also be collected.
However, the meaning of data "provided to" Goldcopytrade is not limited to this. It is also personal
data resulting from observation of your activities (i.e where using a device or service).
This may include:
• History of website usage or search activities, details of your visits to our Website including,
• Traffic and location data;
• Website traffic pattern information, including IP address, operating system and browser type, for
system administration and to report aggregate information to our advertisers. This kind of
information is only used in masked or aggregated form, which means that the individual user will not
be recognisable. These data do not identify any individual.
• Communications between you and Goldcopytrade via Live Chat, email, or telephone call.
Your e-mail address may be used by Goldcopytrade LTD in relation to its products and services (including
any marketing campaigns related to these products or services). If you do not wish to receive such
marketing material and marketing communications, you can opt-out at any time by clicking on
"unsubscribe" or by sending an email stating so to email@example.com
The type of data collected and purpose of collection
The type of data we collect along with the purpose for collection is listed below:
Personal data type: Purpose:
Personal information such as gender,
name, date of birth and address
To meet our anti money laundering (AML) and other
regulatory AML) and other regulatory obligations in
relation to Know Your Client (KYC) and client due diligence.
To verify your identity using our verification processes.
Contact information (email address
and phone number)
In order to send you correspondence in relation to the
services provided and to fulfil our regulatory and
Employment information, financial
In order to comply with KYC obligations and in order to
meet our regulatory obligations relating to assessing the
appropriateness of our products and services.
Ethnicity, citizenship and social
security numbers or national identity
In order to comply with KYC and regulatory trade reporting
and other AML obligations.
Proof of photo ID, address verification In order to comply with KYC and regulatory trade reporting
and other AML obligations.
Unique device number (IP address) and
device information including version of
web browser you use
When you visit our website, navigate through the pages
or fill in any forms, we may collect your unique device
number or IP address in order to set up your profile.
Financial sanctions and credit header
In order to perform our electronic AML screening checks
and to comply with other fraud detection policies. This
may generate further information on your credit history,
criminal convictions or political interests leading to us
making decisions based on the results of these checks.
How we use your personal information
We use information held about you in the following ways:
- To ensure that the content in our website is presented to you in the most effective manner and to
improve the content of our website
- To communicate with you and contact you and to provide you with products and services that you
request from us or, where you have considered to be contacted, for products and services that we
feel may be of interest to you;
- Managing and administering the products and services provided to you;
- Keeping you updated as a Client in relation to changes to our services and relevant matters
- Provide, improve, test and monitor the effectiveness of our Services.
- Develop and test new products and features.
- Monitor metrics such as total number of visitors, traffic and demographic patterns.
- Diagnose or fix technology problems.
- To carry out our obligations arising from any contracts entered between you and us
We may also use your data, or permit selected third parties and our processors to use your data, to
provide you with information about goods and services which may be of interest to you and we or
they may contact you about these by email.
- To notify you about updates to the website.
- To send out newsletters or information about other opportunities that we believe will be of interest
to you. We will only send this to you if you have indicated that you wish to receive such information
and we will respect your wish not to do so if you communicate such wish to us. You can opt-out
receiving marketing communications at any time if you do not wish to receive such marketing
material by clicking on "unsubscribe" or by sending an email request to firstname.lastname@example.org.
- To promote safety and security. We use the information we have to help verify accounts and activity,
and to promote safety and security on our regulated services, such as by investigating suspicious
activity or violations of our terms or policies. We work hard to protect your account using teams of
IT specialists, automated systems, and advanced technology such as encryption.
Who we share your personal information with?
We will not rent or sell your information to third parties outside of Goldcopytrade LTD (or the group of
companies of which Goldcopytrade LTD is part of) without your consent. We also impose strict restrictions
on how our processors can use and disclose the data we provide. Here are the types of third parties we
share information with:
• Service providers and other partners: We transfer information to service providers (processors), and
other partners who globally support our business, such as providing technical infrastructure services,
trading platforms analysing how our Services are used such as measuring the effectiveness of ads
and services, providing client service and support, client on-boarding, client identify verification,
including PEPs and sanctions, conducting marketing communications and design, services related to
our website management, services related to software and business development services.
We need to transfer personal data to recipients outside the European Union; these activities can
include dealings with foreign public entities (only when necessary and under request), the
outsourcing of services to external providers located outside the EU and/or processing the data
outside the EU (i.e cloud computing, client identity verification and individuals from outside the EEA
accessing to our web-services).
• Measurement and Analytics Services: Partners who use our analytics services like Google Analytics
(Non-Personally Identifiable Information Only). We do not share information that personally
identifies you (personally identifiable information is information like name or email address that can
by itself be used to contact you or identifies who you are) with advertising, measurement or analytics
Goldcopytrade LTD does extensive due diligence before choosing processors assuring that they provide
sufficient safeguards, in particular in terms of expert knowledge, data governance, data security, cyber resilience, reliability and resources to implement technical and organisational measures in such a manner
that processing will meet the requirements of General Data Regulation and ensure the protection of the
rights of the data subject.
The adherence of the processor to an SLA Contract is used as an element to demonstrate compliance with
the obligations of the controller.
The carrying-out of processing by our processor it is governed by a contract other legal act under Union
or Member State law, binding the processor to the controller.
This data sharing with our processor enables us to proceed with our regulated activities and duties to KYC
in order to meet our regulatory obligations relating to assess the appropriateness of our products and
services, provide support to clients, etc. Some of those third party recipients (processors) may be based
outside the European Economic Area; if the third party recipient is located outside the EU/EEA in a country
not ensuring an adequate level of data protection, the transfer will only be completed if a written
agreement has been entered into between IC Markets Global and the third party. The written agreement
shall be based on the Standard Contractual Clauses approved by the European Commission (and any
updated versions). - for further information including on how we safeguard your personal data when
these cases occur, see paragraph ‘Transfer of your information out of the EEA
We will share personal information with law enforcement or other authorities if required by applicable law.
For more information about cookies and how we use them, please read our Cookies Policy.
How our global services operate
Transfer of your information out of the EEA
Information collected within the European Economic Area ("EEA") will be transferred to countries outside
of the EEA for the purposes described in this policy and relying on the lawful basis of contractual necessity
and compliance with our legal obligations.
We and our processors when data is transferred outside the EEA utilise standard contract clauses
approved by the European Commission and we adopt other means under European Union law and may
obtain your consent to legitimise data transfers from the EEA to and other countries.
How do we respond to legal requests or prevent harm?
We access, preserve and share your information with regulators, law enforcement or others by request:
- We can respond to legal requests when we have a good-faith belief that the response is required by
law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally
- When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorised
use of the services or products, violations of our terms or policies, or other harmful or illegal activity;
to protect ourselves (including our rights, property or Products), you or others, including as part of
investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if
relevant, we provide information to and receive information from third-parties about the reliability
of your account to prevent fraud, abuse and other harmful activity on and off our Products.
Information we receive about you (including financial transaction as data related to deposits and
withdrawals) can be accessed and preserved for an extended period when it is the subject of a legal
request or obligation, governmental investigation, or investigations of possible violations of our terms or
policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms
violations for at least a year to prevent repeat abuse or other term violations.
Under the General Data Protection Regulation you have a number of important rights if you are resident
within the European Union. In summary, those include rights to:
- Fair processing of information and transparency over how we use your use personal information,
- The right to access personal data: via a Subject Access Request. Your request should be made in
writing to email@example.com
- We may ask you for proof of identity before providing you with the data. There is usually no charge
for such requests, however in limited circumstances we may be able to charge an administrative fee
(and we will inform you in response to your request if that is the case).
- The right to request that your personal data is corrected if it is found to be inaccurate: require us to
correct any mistakes in your information which we hold.
- The right to request that your personal data is erased where it is no longer necessary. In some
circumstances this right may not apply e.g. if there is some other compelling reason for us to keep or
process your data (and we will inform you in response to your request if that is the case).
- Right to data portability: to receive the personal information concerning you which you have
provided to us, in a structured, commonly used and machine-readable format and have the right to
transmit those data to a third party (another controller) in certain situations.
- The right to withdraw consent to processing at any time, where relevant i.e. where we are relying on
your consent to process the data and not another legal reason for processing.
The right to object at any time to processing of personal information concerning you for direct
- The right not to be subject to a decision which is based solely on automated processing, including
profiling which produces legal effects concerning them or significantly affects them.
- The right to object in certain other situations to our continued processing of your personal
• Otherwise restrict our processing of your personal information in certain circumstances
If you would like to exercise any of those rights, please:
- email to us at firstname.lastname@example.org
- let us have enough information to identify you (eg account number, username, registration details),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent
utility or credit card bill), and
- let us know the information to which your request relates, including any account or reference
numbers, if you have them.
Legal basis for processing personal data
Reasons we can collect and use your personal information: Lawful basis for processing under EU data
protection law, there must be a lawful basis for all processing of personal data (unless an exemption or
derogation applies). We rely on:
- Contractual necessity Processing is necessary for the performance of a contract with the data subject
or to take steps to enter into a contract to conduct regulated activities, when processing is necessary
for the entry into, or performance of contract with the data subject or in order to take steps at this
or her request prior to the entry into a contract.
- Compliance with legal obligations Processing is necessary for compliance with our legal obligation.
Goldcopytrade has the necessity for compliance with a legal obligation.
- Legitimate interest Data will only be processed where it is necessary for the purposes of the
legitimate interests pursued by Goldcopytrade, and these interests or fundamental rights are not
overridden by the interests, rights and freedoms of the data subject and that the processing would
not cause unwarranted harm. For instance, it is a legitimate interest of Goldcopytrade to process
personal data on data subjects in order to expand the business, develop new business relations
prevention of fraud, maintaining the security of our systems if/when necessary, enhancing, modifying
or improving our services. The data subject must be given information on the specific legitimate interest if a processing is based on this provision.
Keeping your personal information secure
Your Data is stored and kept confidential according to the legislation on protection of personal data and
processing thereof applicable in the jurisdiction in which Goldcopytrade with which you have signed
up is located.
We have appropriate security measures in place to prevent personal information from being accidentally
lost, misused, modification, disclosure or accessed in an unauthorised way. We limit access to your
personal information to those who have a genuine business need to know it. Those processing your
information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and
any applicable regulator of a suspected data security breach where we are legally required to do so.
How long your personal information will be kept
You can close your account any time, but for audit trail purposes Goldcopytrade shall hold personal
data for a period of at least five years after closing the account in order for us to comply with our record
keeping obligations under the Money Laundering Regulations 2020.
At the end of that period, we will delete all personal data relating to you, unless a legal requirement
requires them to keep the data for a prolonged period of time, or Data Subject has expressly consented
to their data being held for an extended period of time.
What happens in the event of a change of control?
If we sell or otherwise transfer part or the whole of Goldcopytrade or our assets to another organization
(e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your
information such as name and email address and any other information collected through the Service may
be among the items sold or transferred. You will continue to own your User Content. The buyer or
How to complain?
We hope that our Data Protection Officer, client support or compliance team can resolve any query or
concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory
authority. In the Seychelles the Data Protection Act (the 'Act') was enacted in 2003 (Act No. 9 of 2003)
with the aim of protecting the fundamental privacy rights of individuals against the use of data concerning them without their informed consent. The Act will come into operation on such date as the Minister notifies in the official Gazette.
Goldcopytrade shall comply with both the GDPR and national data protection legislation.
If applicable national legislation requires a higher level of protection for personal data than such
policies/guidelines, such stricter requirements are to be complied with. If Goldcopytrade
policies/guidelines are stricter than the local legislation, our policies/guidelines must be complied with.
Changes to this privacy notice
This privacy notice was published in Jan 2023.
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Goldcopytrade - Fzco registered in Dubai, United Arab Emirates with registration number: DSO-FZCO-23470, is regulated by Dubai Silicon Oasis Trade License number: 25215. Business activities: Commercial broker/ Financing Broker.
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