Privacy Policy: APRIL 2020

PRIVACY POLICY
APRIL 2020
V.4
SQUAREDFINANCIAL (CY) LTD
205, ARCH. MAKARIOS AVENUE

VICTORY HOUSE, 5TH FLOOR
3030, LIMASSOL
Table of Contents
General Information ....................................................................................................................... 2
a) Introduction ................................................................................................................................ 2
b) Purpose ....................................................................................................................................... 2
c) Controller .................................................................................................................................... 2
d) Data Protection Officer / Person responsible for the protection of data ................................... 3
Processing of Personal Data during Your Use of Our Website ....................................................... 3
a) Marketing, Newsletter and Daily Expert Analysis Service .......................................................... 8
b) Data Recipients ........................................................................................................................... 9
c) Retention Period ....................................................................................................................... 10
d) Personal Data Safeguard Measures .......................................................................................... 11
Your Rights .................................................................................................................................... 11
Changes to this privacy policy ....................................................................................................... 12
205, Arch. Makarios Avenue, Victory House, 5th Floor, 3030, Limassol, Cyprus
Email: [email protected] | Web: www.squaredfinancial.com Page | 1
Privacy Policy
Our Privacy Policy below describes in detail how SquaredFinancial handles the collection,
management and protection of all confidential user information.
General Information
a) Introduction
Thank you for your interest in our website and our online services. We understand the importance of
maintaining the confidentiality and privacy of Your Personal Data. By entrusting us with your
information, we would like to assure you of our commitment to keep such information private. We
have taken measurable steps to protect the confidentiality, security and integrity of Your Personal
Data.
Please note that this Policy is addressed to website and/or apps visitors, clients and potential client. If
you are a SquaredFinancial employee, a contractor to SquaredFinancial or a third-party service
provider, your personal information will be used in connection with your employment contract, your
contractual relationship or in accordance with our separate policies which are available by contacting
us.
Any reference to ‘us’, ‘our’, ‘we’ or ‘SquaredFinancial’ in this Policy is a reference to each group
company within the SquaredFinancial Group as the context requires unless otherwise stated.
Similarly, any reference to ‘you’, ‘your’, ‘yours’ or ‘yourself’ in this Policy is a reference to any of our
website and/or our applications clients and potential clients as the context requires unless otherwise
stated.
b) Purpose
The following policy is designed to inform you about the processing of your personal data and your
rights regarding this processing according to the General Data Protection Regulation (“GDPR”) and
other data protection laws. By using or navigating our Website or apps or any other product or service
(including the daily technical analysis and email newsletter) or in the case you choose to use our
services you acknowledge that you have read, understand and agree to be bound by this Privacy
Policy.
c) Controller
This privacy notice applies to the processing activities of the following data controller entities within
the SquaredFinancial group of companies, which are:
• Squared Financial (CY) Limited – www.squaredfinancial.com

A company authorized and regulated by the Cyprus Securities and Exchange Commission
(“CySEC”) as a Cyprus Investment Firm (CIF) to offer certain Investment and Ancillary Services
and Activities under the Provision of Investment Services, the Exercise of Investment
Activities, the Operation of Regulated Markets and Other Related Matters Law of 2017, Law
87(I)/2017, as subsequently amended or replaced from time to time (the “Law”), with CIF
license number 329/17. The company is registered in Cyprus under the Companies Law, with
registration number HE 355968. Its registered office is at Kedrou 9, Mesa Geitonia, 4004,
Limassol, Cyprus. For more information you can visit our Regulation section on our website.
We collect, use and are 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 (including in the United Kingdom) and we are responsible as ‘controller’ of
that personal information for the purposes of those laws.
• Squared Financial (Seychelles) Ltd – sc.squaredfinancial.com

A company authorized and regulated by the Financial Services Authority (“FSA”) Seychelles as
a Securities Dealer to offer certain Investment Services and Activities under Section 41 (1) of
the Securities Act 2007, as subsequently amended or replaced from time to time (the “Law”),
with license number SD024. The company is registered in Seychelles under the Companies
Act, with registration number 8423788-1. Its registered office is at Commercial House 1, Office
no 4, Eden Island, Victoria, Mahe, Seychelles. For more information you can visit our
Regulation section on our website. We collect, use and are responsible for certain personal
information about you. When we do so, we are regulated under the Data Protection Act (Act
No. 9 of 2003) which applies in Seychelles and we are responsible as ‘controller’ of that
personal information for the purposes of those laws.
Squared Financial (CY) Limited performs significant processing on behalf of the other entities of the
Squared Financial group. Therefore, if you are a client of the non- European entities of the group, we
process your personal data in accordance with this Privacy Policy and you are entitled to the same
protection and rights mentioned in this notice.
d) Data Protection Officer / Person responsible for the protection of

data
If you have any questions or queries regarding this policy, wish to access or change your information
or would like to raise a complaint, or if you have any questions about security on our Website, please
contact us using the following:
• Squared Financial (CY) Limited - You can contact our Data Protection Officer (the “DPO”) at
any time by using the following contact details: Kedrou 9, Mesa Geitonia, 4004, Limassol
Cyprus, Phone: +357 25260333 or in writing at [email protected].
• Squared Financial (Seychelles) Ltd - You can contact us at any time in writing at compliance-
[email protected].
Processing of Personal Data during Your Use of Our

Website
We collect personal information about you when you access our Website or your SCC mobile app,
register a live or demo account with us, contact us, send us feedback, login to your personal account
to purchase products or services via our website, register to be included in our newsletter and
compete customer surveys or participate in competitions via our website. The personal information
we collect about you depends on the particular activities carried out through our website. We have
taken appropriate measures to ensure that the data provided to us is adequately protected. These
measures include, but are not limited to, encryption, access control, segregation of duties, internal
audit etc. For further details on when we collect personal information, what we collect as well as how
we use it, please read the following sections:
How and why we use your

When Information is What information we ask for information
collected
We ask for this:

— to create and manage your account
with us
— to communicate with you about your
Individual Client account
When you register a live account Contact information including your
with us name and surname, email and We rely on consent as the lawful basis
telephone number; for collecting and using your personal
information (art. 6(1)(a)).
Personal information, including your
country of residence; Our legitimate interests are:
— Compliance with our legal
Personal identification documents, obligations (art. 6(1)(c));
including Passport, Utility Bill and other — Facilitating the use of services
information we consider necessary to provided electronically and
our functions and activities. improving the functionality of
these services (art. 6(1)(f));
Corporate Client — Determining, investigating and
Contact information including your enforcing claims and defending
company’s name, email and telephone against claims in proceedings
number; before courts and other state
authorities (art. 6(1)(f));
Corporate information and such as — For improving the functionality of
corporate documents of address, services provided electronically
shareholders, directors, officers and building positive relationships
including additional personal with Users and Users not logged in,
information on the Shareholders and based on reliability and loyalty (art.
Directors. 6(1)(f)).
We will keep this information until:

— you close your account with us;
— we close your account;
We ask for this:

— to create and manage your account
with us;
— to communicate with you about your
account and other products and services
When you register a demo account that we offer;
with us
Contact information including your We rely on consent as the lawful basis
name and surname, email and for collecting and using your personal
telephone number; information (art. 6(1)(a)).
Personal information, including your Our legitimate interests are:

country of residence; — Compliance with our legal
obligations (art. 6(1)(c))
— Marketing of products and services
(art. 6(1)(f));
— Facilitating the use of services
provided electronically and
improving the functionality of
— For improving the functionality of
services provided electronically
and building positive relationships
with Users and Users not logged in,
based on reliability and loyalty (art.
6(1)(f)).

— you close your account with us
— we close your account
We ask for this:

- In order to log-in use our products and
services, including creating a new
account, managing existing trading
When you log-in to access your -Login details including your email and accounts, make payments and place
personal SquaredPortal password deposits, request withdrawals or
access information relevant to you.
- To eliminate un-authorized access to
your account;
- Product and product user security
We rely on performance of a contract

(Art. 6(1)(b)) as the lawful basis for
collecting and using your personal
information. If processing involves
processing of special categories of
personal data, we rely on consent (Art.
9(2)(a))
-Your personal data will be stored as

long as necessary for us to fulfill our
obligations towards you within the
context of provision of our services,
except where we are legally obliged to
further store your information for the
purpose of submitting it to public
authorities, such as tax authorities.
We ask for this:
-To respond to your request
-To improve our services, product
development and enhancement
Personalized service and
communications.
When using the Contact Us form in -Your contact details (including your
our website title, name and surname, and your We rely on consent as the lawful basis
a) https://www.squaredfina email) for collecting and using your personal
ncial.com/support/contac information (art. 6(1)(c)).
t-us
b) https://sc.squaredfinancia Our legitimate interests are:
l.com/support/contact-us — Facilitating the use of services
these services (art. 6(1)(f)).
Third parties may have access to this

information in the case this is necessary
for enabling the carrying out of an
agreement between us.

— you close your account with us
(Client);
— we close your account (Client);
— You withdraw your consent (non-
Client).
We ask for this:

- to send our newsletter and keep you
updated on interesting topics from the
SquaredFinancial world.
When you subscribe to our - Your contact details (including your - to send the daily expert analysis to
newsletter and to our Daily Expert name and surname, email and clients and potential clients
Analysis service telephone number - for our legitimate interests or those of
- Personal data (including your country a third party, ie to promote our business
of residence) to existing and former customers


You withdraw your consent or
unsubscribe from our services;
For more information, please see

“Marketing, Newsletter and Daily Expert
Analysis Service” below
When signing up for webinars - Your contact details (including your We ask for this:
name and surname, email and - to create the subscription to the
telephone number webinar and send all relevant details in
Personal data (including your country relation to it.
of residence)
For our legitimate interests or those of a
third party, ie to promote our business
to existing and former customers.

When having a Telephone - Your personal details (including your We ask for this:
Conversation with any of our name and surname) - To identify the person on the other
representatives / employees - Your trading account details, such as line and address his requests
number accordingly;
- Telephone communication - For regulatory purposes;
- For improving our services.
Our legitimate interests are:

- Facilitating the use of services
provided over the phone;
- Compliance with our legal

— you close your account with us;
— we close your account;
Payment method information when - Your payment method information, We ask for this:
performing a transaction with us including bank statements, credit - To identify the account holder of
card copies, with the name and the payment account used for
account details visisble transaction for AML purposes;
- To prevent third-party
transactions.

- Compliance with our legal
Your payment method details will

remain stored until you decide to
remove or change them and at all times
subject to our Privacy Policy
requirements (section 2(c)).
Trading Activity Trading activity information such as, We ask for this:
trading history, number of trades, - For ensuring the proper
monetary activity and device performance of our services to
information logged in. clients for best execution practices
but also for meeting regulatory
requirements.

— Compliance with our legal
— Facilitating the use of services
— Determining, investigating and
enforcing claims and defending
against claims in proceedings
before courts and other state
authorities (art. 6(1)(f));
We ask for this:

- To optimize and improve our website
as well as our online services;
Your visit to the website, and/or use of - Our legitimate interests are protecting
our online services will be logged. The IP our website and to improve the quality
address currently used by your device, of our services;
Cookies date and time, the browser type and
operating system of your device, the Your personal data is only stored if you
pages accessed may be recorded. provide it to us on your own accord e.g.
as part of a registration, a survey, an
For more information please visit our online application or an online payment
Cookie Policy CY or (Performance of a contact).
Cookie Policy SC, respectively.
For more information please visit our
Cookie Policy CY or
Cookie Policy SC, respectively.
This website is not intended for use by children under the age of 18 and we do not knowingly collect
or use personal information relating to children.
a) Marketing, Newsletter and Daily Expert Analysis Service

We, or any of our Affiliates, would like to send you information about products and services and
market analysis, which may be of interest to you. Where we have your consent or it is in our legitimate
interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.
We will only ask whether you would like us to send you marketing messages when you tick the relevant
boxes when you complete our online registration form for the first time, or when you subscribe to our
newsletter.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:
— contacting us by completing the ‘Contact Us’ form;
— using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts;
— updating your marketing preferences on our SquaredFinancial Portal,
It may take up to 2 business days for this to take place.
For more information on your rights in relation to marketing, see 'Your rights’ below.
b) Data Recipients
We may use third party service providers to process your personal data. These service providers may
be located in countries within and outside the European Union (EU) and the European Economic Area
(EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our
suppliers or Affiliate companies We ensure that these service providers process personal data in
accordance with European data protection legislation to guarantee an adequate data protection level,
even if personal data are transferred into a country outside the EEA for which no adequacy decision
of the EU Commission exists. Transfers of personal data to other recipients is not performed, except
where we are obliged to do so by law. For more information about appropriate safeguards for the
international data transfer, please contact us.
For our clients, and under the terms of our Client Agreement, we have the right to retain and
disclose your Personal Data (including recordings and documents of a confidential nature) in certain
circumstances and as we believe to be necessary or appropriate. According to the Client Agreement
between us, your Personal Data may be retained and disclosed n the following circumstances:
(a) In order to comply with our obligations deriving from the applicable law and regulations,
which may include laws and regulations outside your country of residence;
(b) where required by law or a court order by a competent Court;
(c) where requested by our Supervisor (the Cyprus Securities and Exchange Commission) or any
other regulatory, public and government authority having control or jurisdiction over us or
you or our associates or in whose territory we have Clients or Providers, as applicable
(d) to relevant authorities to investigate or prevent fraud, money laundering or other illegal
activity;
(e) a Broker so as to execute your Instructions or Orders and for purposes ancillary to the
provision of our Services to you as our Client;
(f) to carry out anti-money laundering, sanctions or Know Your Customer checks as required by
applicable laws and regulations;
(g) to credit reference and fraud prevention agencies, third authentication service providers,
banks and other financial institutions for credit checking, fraud prevention, anti-money
laundering purposes, identification or due diligence checks of you. To do so they may check
the details you supplied against any particulars on any database (public or otherwise) to
which they have access. They may also use your details in the future to assist other companies
for verification purposes. A record of the search will be retained by us;
(h) to our professional advisors provided that in each case the relevant professional shall be
informed about the confidential nature of such information and commit to the confidentiality
herein obligations as well;
(i) to other service providers who create, maintain or process databases (whether electronic or
not), offer record keeping services, email transmission services, messaging services or similar
services which aim to assist us collect, storage, process and use Your Information or get in
touch with you or improve the provision of our Services or activities under the Agreement
between us;
(j) to data reporting service providers;
(k) to other service providers for statistical purposes in order to improve our marketing, in such
a case, the data will be provided in an aggregate form;
(l) to market research call centres that provide telephone or email surveys with the purpose to
improve our Services or activities, but only contact details;
(m) where necessary in order for us to defend or exercise our legal rights to any court or tribunal
or arbitrator or Ombudsman or governmental authority, as the case may be;
(n) at your request or with your consent;
(o) to our Affiliates;
(p) to our employees so as to exercise their duties to further the Agreement between us, or to
assure the efficient functioning of our Platform, the Automatic Orders and the Trading Data
functions.
We endeavour to disclose to these third parties only the minimum personal data that is required to
perform their contractual obligations to us. Our third-party service providers are not permitted to
share or use personal data we make available to them for any other purpose than to provide services
to us.
Our websites or our apps may have links to external third-party websites. Please note, however, that
third party websites are not covered by this Privacy Policy and those sites are not subject to our privacy
standards and procedures. Please check with each third party as to their privacy practices and
procedures.
c) Retention Period
Personal data provided to us via our website will only be stored until the purpose for which they were
processed has been fulfilled. Insofar as retention periods under regulatory, commercial and tax law
must be observed, the storage period for certain data can be up to 7 years. However, storage periods
may also be amended due to our legitimate interest (e.g. to guarantee data security, to prevent misuse
or to prosecute criminal offenders). We will keep your personal information while you have an account
with us, or we are providing products and services to you. Thereafter, we will keep your personal
information for as long as is necessary:
1. to respond to any questions, complaints or claims made by you or on your behalf;

2. to show that we treated you fairly;
3. to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in
this policy. Different retention periods apply for different types of personal information. For further
details on this please contact our person responsible for the protection of data of us as mentioned
above.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
d) Personal Data Safeguard Measures
We hold personal data in a combination of secure computer storage facilities and paper-based files
and other records and take steps to protect the personal information we hold from misuse, loss,
unauthorised access, modification or disclosure.
Access to your Information is limited only to those employees or partners that need to know the
information in order to enable the carrying out of the Agreement between us.
While we will use all reasonable efforts to safeguard Your Information, you acknowledge that the use
of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity
of any personal data transferred from you, or to you via the internet.
Your Rights
As a data subject, you can contact our person responsible for the protection of data of us as mentioned
above at any time with a notification under the contact information mentioned above under Section
1 to make use of your rights. These rights are the following:
• The right to receive information about the data processing and a copy of the processed data;
• The right to demand the rectification of inaccurate data or the completion of incomplete
data;
• The right to demand the erasure of personal data;
• The right to demand the restriction of the data processing;
• The right to receive the personal data concerning the data subject in a structured, commonly
used and machine-readable format and to request the transmittance of these data to
another controller;
• The right to object to the data processing;
• The right to withdraw a given consent at any time to stop a data processing that is based on
your consent;
We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or
excessive requests concerning your access to your personal data, and for any additional copies of the
personal data you request from us.
In the event that you wish to complain about how we have handled your personal data, you may
contact us at the above email address (section 1(d)). We will then look into your complaint and work
with you to resolve the matter.
We try to respond to all requests within 1 (one) month. Occasionally, it may take us longer than 1
(one) month if your request is particularly complex or you have made a number of requests. In this
case, we will notify you within 1 (one) month of the receipt of your request and keep you updated.
If you are not satisfied with our response to your complaint, you have the right to lodge a complaint
with our supervisory authorities, the Cyprus Data Protection Commissioner if you are a client of
Squared Financial (CY). Information on how to do this can be found on the following website:
http://www.dataprotection.gov.cy
Alternatively, you also have the right to lodge a complaint with the data protection authority of your
country of residence.
Changes to this privacy policy

This privacy notice was published and last updated on 7th April 202. We may change this privacy notice
from time to time and when we do, we will inform you via our website or other means of contact. Any
personal information we hold will be governed by the current Privacy Policy at the given time. If we
make changes we consider to be important, we will communicate them to you.

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PRIVACY POLICY

SQUAREDFINANCIAL (CY) LTD

205, ARCH. MAKARIOS AVENUE

• Squared Financial (CY) Limited – www.squaredfinancial.com

• Squared Financial (Seychelles) Ltd – sc.squaredfinancial.com

d) Data Protection Officer / Person responsible for the protection of

Processing of Personal Data during Your Use of Our

How and why we use your

We ask for this:

We will keep this information until:

We ask for this:

Personal information, including your Our legitimate interests are:

We will keep this information until:

We ask for this:

We rely on performance of a contract

-Your personal data will be stored as

Third parties may have access to this

We will keep this information until:

We ask for this:

Third parties may have access to this

We will keep this information until:

For more information, please see

Third parties may have access to this

Our legitimate interests are:

We will keep this information until:

Our legitimate interests are:

Your payment method details will

Our legitimate interests are:

We ask for this:

a) Marketing, Newsletter and Daily Expert Analysis Service

It may take up to 2 business days for this to take place.

(b) where required by law or a court order by a competent Court;

(j) to data reporting service providers;

(n) at your request or with your consent;

(o) to our Affiliates;

1. to respond to any questions, complaints or claims made by you or on your behalf;

d) Personal Data Safeguard Measures

Changes to this privacy policy

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