XBO shall take measurable steps to protect the confidentiality, security, and integrity of client information.
“AML”means anti-money laundering.
“Personal Data” includes but is not limited to personal details such as date of birth, address, name, contact details, payment details, including bank account details, debit card, credit card and any other necessary financial information.
“XBO”, “We”, “Us”, “Our”, refers collectively to XBO and its subsidiaries.
Collection of Information
When opening an account with XBO, We shall collect information directly from the client or from other persons including, for example, banks, other financial institutions, credit reference agencies, fraud prevention agencies, third authentication service providers and the providers of public registers. This information includes but is not limited to Personal Data.
XBO might also be collecting information regarding the use of the website(s), such as frequency and duration of visit.
From time-to-time We may also request further information to help improve service or comply with the applicable laws and regulations.
If the client is a natural person and/or corporate, XBO is the personal data controller of the client’s Personal data in relation to the processing activities which the client’s Personal Data undergoes.
The first type of information is unidentified and nonidentifiable information pertaining to a client(s) (“Non-personal Information”), which may be made available or gathered via your use of the Site, even if you do not participate or register to Our Site. We are not aware of the identity of a client from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of the Our website. We may also collect information on your activity on the Website (e.g. pages viewed, online browsing, clicks, actions, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information includes:
- Device Information: We may also collect Personal Data from you. Such data includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
- Payment Information: To execute withdrawals and for AML purposes, you may be required to share personal information within the site or with Our trusted payment processors. Such personal information may include your name, billing address, identity number, financial information (e.g. your credit card number, bank account, etc.) and any other information that is required in order to perform transactions.
Based on the aforementioned, We collect information which is required to communicate with and identify Our clients. In addition, certain demographic information, including, birth date, education, occupation, etc. maybe also collected from Our clients along with information related to trading so that We will be in a position to assess trading related details which are deemed to be necessary. Examples include:
- Application information that includes personal information provided by the client in the application. The client’s name, address, date of birth, email address, income and income source are asked. This information is also used by the Us in order to communicate with the Client.
- Transaction information that includes information about the anticipated volume and value of the Client’s transaction with Us. The client’s economic profile is also construed based on this.
- Verification information that includes the client’s identity card, passport, or driver’s license.
Use of Information
We shall process, store and handle personal information of corporate clients. The information which we hold, which are not already in the public domain or have already been processed by XBO without duty of confidentiality, shall be treated by Us as confidential and will not be used for any other purpose other than in connection with the provision, administration and improvement of its services, establishing and managing the account, enhancing products and customer service, reviewing clients’ ongoing needs, providing clients with information or opportunities that XBO believes may be relevant to them, AML and due diligence checks, for research and marketing purposes as applicable.
XBO collects and uses information only for the purposes and the provision of its services and in order to fulfill its compliance and other obligations as per the relevant Laws and Regulations.
In this respect the clients hereby consent to the usage of this data for the above mentioned purposes.
In case where the clients do not wish to receive information for any reason, they can contact Us at [email protected].
How to exercise your rights
You can submit an official GDPR related request/ complaint to [email protected] providing the following information:
- Personal Details:
- Name and surname;
- Trading account;
- Email address;
- Specific details of the request
Only complete if you wish to be represented by a third party. Please note that you will be required to provide the Power of Attorney authorising the relevant third party to act on your behalf.
- Name of the representative
- Your relationship with the representative
- Email address
- Contact number
- Postal address
Disclosure of Information
XBO has the right to disclose client information (including recordings, card details and documents of a confidential nature) in certain circumstances. The information may be disclosed:
- Where required by law or a court order by a competent Court.
- The relevant authorities to investigate or prevent fraud, money laundering or other illegal activity.
- To fraud prevention agencies, third authentication service providers, banks and other financial institutions for credit checking, AML, identification or due diligence checks of clients. To do so We may check the details client supplied against any particulars on any database (public or otherwise) to which We have access. We may also use client details in the future to assist other companies for verification purposes.
- To the 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.
- 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 to collect, storage, process and use information or get in touch with clients or improve the provision of the Our services or activities.
- To data reporting service providers.
- To other service providers for statistical purposes in order to improve Our marketing;
- To market research call centers that provide telephone or email surveys with the purpose to improve Our Services or activities, but only contact details. For the avoidance of doubt no payment details such as but not limited to credit card, debit card and bank details will be transmitted.
- 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.
- At the request of the client or with clients’ consent.
- To affiliates or any other company in Our group excluding payment details such as but not limited to credit card, debit card, and bank account details.
- To employees so as to exercise their duties to further the agreement with the client, or to assure the efficient functioning of the platform.
We forbid users under the age of 18 to register or trade using our services. If we become aware that a user is under the age of 18 and has shared any information, we will discard such information.
Client information is stored on secure servers. XBO takes reasonable, technical, and organizational measures to prevent the loss, misuse or alteration of its clients’ personal information. XBO stores all the personal information which is provided by the clients on its secure (password and firewall protected) servers.
We shall limit access to the information only to those partners or employees that need to know the information in order to enable the carrying out of the agreement.
There shall be procedures in place regarding how to safeguard and use information, for example by requesting our affiliates and employees to maintain the confidentiality of client information.
We shall not keep information for any longer than required. In many cases, information must be kept for considerable periods of time. Retention periods will be determined by taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. In any event, We will keep information for the duration of applicable Laws and Regulations as a minimum.
The clients are responsible for keeping the password they use for accessing our website confidential; XBO will not ask the clients for their passwords (expect when they login to the website).
While We shall use all reasonable efforts to safeguard client information, 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 clients, or to clients via the internet.
Transfer of Data outside the EEA
Please note that where and if applicable, some date recipients may be located outside the EEA. In such cases We will transfer your data only to such countries as approved by the European commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
Non-affiliated third parties
XBO may engage third parties to help carry out certain internal functions such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to its business. Use of the shared information is strictly limited to the performance of the above and is not permitted for any other purpose. All third parties with which XBO shares personal information are required to protect such personal information in accordance with all relevant legislation and in a manner similar to the way XBO protects the same. XBO will not share personal information with third parties which it considers will not provide its clients the required level of protection.
Restriction of responsibility
Use of ‘Cookies’
A cookie is a file containing an identifier that is sent by a web server browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either ‘persistent’ cookies or ‘session’ cookies. A persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website. We use both session and persistent cookies on our website.
For the purpose of administering the terms of its agreement with the clients, We may, from time to time, make direct contact with clients by email, telephone, post or fax.
XBO or any of its affiliates or group company, may make contact with the clients with the abovementioned means for marketing purposes, to bring to their attention products or services that may be of interest to them or to conduct market research. Any person wishing to opt out of further contact with Us at any time whatsoever is entitled to do so, simply by contacting Us whether by phone or email and requesting that no further contact be made.
Full Details of Data Controllers
You are in contact with one of XBOs’ companies which are as follows:
- PROCRYPTIC SP. Z O.O., a company incorporated under the laws of Poland, with a registered address at Mennica Legacy Tower, Prosta 20, 00-850 Warsaw, Poland.
- CLICKJOINT B.V., a company incorporates under the laws of Curacao with registered address at Zuikertuintjeweg Z/N (Zulkertuin Tower) Curacao.
Digital assets are complex instruments and involve high risk. Please ensure that you fully understand the risks involved before entering into any transactions.
Contact us: [email protected]
Procryptic Sp. Z O.O. Registered Address: Mennica Legacy Tower, Prosta 20, 00-850 Warsaw, Poland.