Privacy Policy EN

This Privacy Policy describes Dolphin Corp LLC policies and procedures on the collection, use, and disclosure of Your information (including personal data) when You use the Binomo Trading Platform through the website binomo.com (hereinafter the “Website”) and/or the Binomo Mobile Application and tells You about Your privacy rights and how the law protects You. All further references to the Website and the Binomo Mobile Application are equivalent.

This Privacy Policy is an integral part of the Binomo Client Agreement.

The information You provide is jointly collected and processed by Dolphin Corp LLC, a company registered in accordance with the laws of Saint Vincent and the Grenadines with registration number 915 LLC 2021, located at Euro House, Richmond Hill Road, Kingstown, St.Vincent and the Grenadines, and Pollack Trade LTD, a company registered in accordance with the legislation of the Republic of Bulgaria, whose office is located at 96 Georgi Sava Rakovski St., Sredets Region, Sofia Municipality, Sofia 1000, (hereinafter – the “Company,” “We,” “Us,” or “Our”), providing access to the Binomo Trading Platform.

We assure You that We take all measures necessary to ensure the confidentiality of the personal data that You provide to Us.

We encourage You to carefully read this Privacy Policy. By registering on the Website, You fully and unconditionally agree to its terms.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following definitions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

‘Cookies’ means small files that are placed on Your computer, mobile device, or any other device by a website, which contain the details of Your browsing history on that website.

‘You’ means the individual accessing or using the Trading Platform.

Any other terms are interpreted in accordance with the Binomo Client Agreement.

1. The information You provide to Us

1.1. Like most websites, We use Cookies.

Some Cookies are necessary for the normal operation of the Website and are used without obtaining Your additional permission. These files include the following:

a) Cookies needed to identify the source from which the transition was made to the Website;

b) Cookies containing Your session ID on the Website.

We also collect and process data about Your device, including the IP address (Internet Protocol address), browser type, browser version, browser configuration (hereinafter the “Usage Data”).

1.2. When registering on the Website, We ask You to provide Us your email address.

If You prefer to register on the Website using Your Google account, You provide Us with access to Your name, email address, language preference, and profile picture in Your Google account (“Google User Data”).

If You prefer to register on the Website using Your Facebook account, You provide Us with access to Your name, email address, and profile picture in Your Facebook account (“Facebook User Data”).

In the future, You have the option to enter Your first and last name, date of birth, gender, phone number, and country in Your Personal Account on the Website.

If You register and log in on the Website using Your Google or Facebook account, We also collect authorization data (technical data about Your registration, logging in and out of the Website through Your Google or Facebook account).

1.3. When crediting an Account on the Trading Platform, You provide Us information containing Your payment details, including the bank card number, its expiration and CVC/CVV code, information on the credit/financial institution and/or the issuer, and other data depending on the means of payment, as well as Your first and last name, passport/ID number, address, phone number, date of birth, and email address.

1.4. When crediting an Account on the Trading Platform, Our partners (financial institutions and Payment System Providers) receive and process information containing Your payment details, including the bank card number, its expiration and CVC/CVV code, information on the credit/financial institution and/or the issuer, and other data depending on the means of payment, as well as Your first and last name. Also, upon the request of the payment system or Payment System Provider, We may provide them with data from Your passport or other identity document, email address, and phone number (in the event this data is indicated in Your Personal Account).

Payment System Providers process such information during the period of Your use of the Company’s services and delete it upon achieving their processing goals, unless the law requires or allows for the establishing of a longer period for the storing of such personal data.

A prerequisite for Our cooperation with Payment System Providers is that they fulfill the requirements of personal data protection laws.

1.5. As part of verification, We request You to provide:

– a photograph of Your passport or ID-card;

– a photograph of Your bank card/screenshot of Your e-wallet;

– a photograph of You with the documents specified above in Your hand.

In order to comply with laws aimed at countering the legalization of illegally obtained funds, the Company may require You to submit additional documents, such as:

– a utility bill;

– a bank reference letter;

– a bank statement letter;

– documents confirming the source of Your wealth/funds (for example, salary agreement, sale of property, loan agreement, inheritance notice);

– a 2nd ID-document.

Verification procedures are described in more detail in the Binomo Client Agreement. 

1.6. We collect and store data on Your financial activity and other actions on the Trading Platform, as well as information contained in web server reports (including the interface language, browser type, and date and time of the last visit).

1.7. If You become a winner in Our promotions, We may ask You provide Us Your first and last name, address, and phone number, so We can send You a prize.

1.8. From time to time, We may ask You to fill out questionnaires in order to improve Our quality of service, for statistical purposes, or to comply with applicable laws.

Sometimes when filling out a form You will be asked to provide Your name and email address.

1.9. When contacting the Company’s Support Service, We ask You to include Your first and last name, and email address.

1.10. In order to comply with international legislation aimed at countering the laundering of proceeds from crime (Anti-Money Laundering laws), and adhering to the principle of KYC, We are entitled to ask You for other information and data, that which is established by relevant laws, including information about the sources of Your income.

We collect and process Your personal data only in the following situations:

i) it is necessary in order to conclude the agreement on the provision of services (Client Agreement) in accordance with Your request and its further execution; or

ii) You have given Us Your consent to the collection and processing of such data, including through the acceptance of the terms of the Client Agreement and the Privacy Policy when registering on the Website; or

iii) such collection and processing are necessary in order to comply with the requirements of applicable law; or

iv) such collection and processing are in Our legal interests, while We always strive to maintain a balance between Our legal interests and the confidentiality of Your personal data.

Kindly note that in most cases, if You do not provide the necessary information, We cannot provide You with the service You have requested.

2. How We use the information You provide

2.1. The information We receive about You allows Us to provide quality services, develop Our existing services, and create new ones.

2.2. Your data obtained using Сookies and similar tools ensures the functionality of the Website and improves the quality of the services provided.

2.3. The data collected when visiting the Website is necessary for the operation of the Trading Platform and its subsequent analysis, as well as to provide You with information in the most convenient way for You.

For example, such data makes it possible to determine the appropriate language of the Trading Platform user interface and Account currency.

2.4. The data provided during registration and verification (including last name, first name, middle name (if any), gender, date of birth, nationality, and email address, Google User Data (if any) or Facebook User Data (if any)) is used to contact You and to provide You with the most accurate and personalized information.

Moreover, the data obtained by Us during verification (including information from Your bank documents) is necessary to ensure the legality and security of the Company’s services.

2.5. For Your convenience, We retain information You provide Us when You credit an Account on the Trading Platform, and prepopulate it during Your subsequent deposits (except for Your bank card number, its expiration date and service code, and security-related information). Thus, You do not have to enter data once again. If this information changes We update it and delete old data.

2.6. Information about Your financial activity and other activity on the Trading Platform, as well as information from web server reports, is used to protect Your funds and block scammers from accessing Your Account.

2.7. We may use the information You provide, including Your name, email address, and phone number, in order to send You system notifications and advertising materials via phone calls, text messages, and other methods not prohibited by applicable law.

You have the right to unsubscribe from the Company’s mailing list at any time by clicking on the “Unsubscribe” link in an email from the Company, disabling the corresponding option in Your Personal Account on the Website, or contacting the Company’s Support Service. You have the right to unsubscribe from calls and text messages from the Company at any time by contacting the Company’s Support Service.

We are committed to promptly responding to a request from You to unsubscribe from all types of emails (except for transactional notifications) as well as to not receive calls and text messages.

2.8. From time to time, We may send You email notifications about changes in the operation of the Website or the terms of service provision.

2.9. Moreover, We need your data in order to personalize the content of the Website and show You relevant advertising.

2.10. The data You provide when contacting the Company is necessary in order to establish the circumstances of Your request and provide a complete answer in the shortest possible time.

In the event We need to use the information provided for other purposes, We always ask for Your consent.

In the event of automated processing of Your personal data, We ensure that such processing does not have any impact on You.

3. Retention of Your personal data

We will retain Your personal data (including Google User Data or Facebook User Data) only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your personal data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

Any personal data that We process for any purpose or purposes shall not be kept for longer than are necessary for that purpose or those purposes.

4. Your rights

4.1. Your principal rights regarding Your personal data are as follows:

(a) The right to access

This enables You to receive a copy of the personal data We hold about You;

(b) The right to rectification/correction

This enables You to have any incomplete or inaccurate data We hold about You corrected; however, We may need to verify the accuracy of the new data You provide to Us;

(c) The right to erasure

This enables You to ask Us to delete or remove Your personal data where there is no good reason for Us to continue processing it;

(d) The right to restrict or object to processing

This enables You to initiate the suspending of the processing of Your personal data;

(e) The right to withdraw consent

However, this will not affect the lawfulness of any processing carried out before You withdraw Your consent.

This list of rights is not complete and may include other rights established by applicable law.

Please note that Your right to demand that We suspend or terminate the processing of Your personal data and/or delete it is not absolute and may be limited by applicable law, including (but not limited to) the requirements of AML & KYC legislation.

In addition, exercising this right may serve in some cases as a basis for termination of service provision to You.

5. Transfer of Your personal data

5.1. Your information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction, where the data protection laws may differ from those of Your jurisdiction.

5.2. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

5.3. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your personal data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information.

6. Disclosure of Your personal data

6.1. Your personal data may be disclosed for the following purposes:

  • Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your personal data may be transferred. We will provide You with notice before Your personal data is transferred and becomes subject to a different privacy policy.

  • Law Enforcement

Under certain circumstances, the Company may be required to disclose Your personal data if required to do so by applicable law or in response to valid requests by public authorities (e.g., a court or a government agency).

  • Other Legal Requirements

The Company may disclose Your personal data in the good faith belief that such action is necessary to:

•  comply with a legal obligation; and/or

•  protect and defend the rights or property of the Company; and/or

•  prevent or investigate possible wrongdoing in connection with the using of the Trading Platform; and/or

•  protect the personal safety of Our clients; and/or

•  protect against legal liability.

7. The information We provide to third parties

7.1. We do not share Your personal data (including Google User Data or Facebook User Data) with third parties who are not affiliated with Your activity on the Website.

7.2. Third parties to whom We may transfer Your personal data process them on Our behalf and strictly in accordance with Our requirements, instructions, and this Privacy Policy.

Such third parties may include:

1) a limited number of Our employees and employees of Our affiliates;

2) professional auditors;

3) professional dispute resolution organizations;

4) payment systems;

5) Payment System Providers;

6) verification service providers;

7) service providers that significantly affect the performance and operation of the Trading Platform.

7.3. To verify You and Your payment details, We engage Sum and Substance Limited, a company incorporated and registered in England, with registration number 09688671, to which We transfer the personal data provided by You.

For more information on the handling of personal data by Sum and Substance Limited, please see their Privacy Policy: https://sumsub.com/privacy-notice/ 

7.4. For promotional purposes, as well as for statistics generation, We provide information that does not contain Your personal data to the following:

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data they collect to track and monitor the use of Our service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

7.5. CloudFlare

CloudFlare is a cloud service for transferring and storing information, including Your personal data. Moreover, that information is hosted on servers in the European Union and the United States of America.

For more information on the privacy practices of CloudFlare, please visit the CloudFlare Privacy web page: https://www.cloudflare.com/privacypolicy/ 

7.6. Zendesk

Zendesk is a service (system) that tracks, prioritizes, and executes tickets assigned to requests. Therefore, if You contact Our Support Service, the Zendesk service gets access to the personal data You provided upon request.

For more information on the privacy practices of Zendesk, please visit the Zendesk Privacy web page: https://www.zendesk.com/company/agreements-and-terms/privacy-policy/ 

7.7. Microsoft Clarity

Microsoft Clarity is a behavior analytics tool which helps Us to capture how You use and interact with Our Website through behavioral metrics, heatmaps and session replay to improve and market Our services. Website Usage Data is captured using Cookies and other tracking technologies to determine the popularity of Our services and online activity. Additionally, this information is used for Website optimization, fraud/security purposes, and advertising.

For more information on the privacy practices of Microsoft, please visit the Microsoft Privacy Statement web page: https://privacy.microsoft.com/en-us/privacystatement 

7.8. For Your convenience, We use services of the PGW Services kft, a company incorporated and registered in Hungary, with registration number Cg. 01-09-377183, to which We transfer Your cardholder data (Primary Account Number, cardholder name, expiration date and/or service code, and security-related information), that provides an opportunity to save those data when depositing Your Account. Thus, You do not have to enter Your cardholder data during subsequent deposits.

We ensure that PGW Services kft stores, processes and transmits Your personal data in strict compliance with requirements specified by law, including personal data protection laws and Payment Card Industry Data Security Standard (PCI DSS).

7.9. If You become a winner in Our promotions, We may provide Your first and last name, address, and phone number, to a postal or courier service to send You a prize.

7.10. We may also transfer information to countries outside the European Economic Area. The level of protection of personal data in those countries may vary.

However, Our partners in such jurisdictions are always bound by contractual obligations to maintain an adequate level of protection of any transmitted data, and We take all possible measures to ensure the confidentiality of the information You provide.

In the event the Company participates in mergers or acquisitions, it may be necessary to transfer Your personal data to Our future partners, and We guarantee the confidentiality of that data.

7.11. With Your prior consent, We may provide information about You to companies, organizations, or individuals not listed in this Privacy Policy.

8. Protecting technical information

8.1. To ensure the security of the information You provide, We have implemented special rules and technical measures to protect that information.

8.2. We use a Secure Sockets Layer (SSL) encryption system for transmitted data. Accordingly, all operations carried out on the Website are well protected.

9. Passwords

9.1. When registering on the Website, You specify Your email address and set Your own password for Your Account.

9.2. We do not have the right to make changes to such data and cannot be held responsible for how You ensure its confidentiality.

9.3. We ask You to immediately report any unauthorized or other suspicious activities related to the use of Your Account.

10. The use of Our services by minors

10.1. The Website is an open resource, but is not intended for use by persons under the legal age in accordance with applicable law.

10.2. In the event that We become aware that a minor has provided or attempted to provide their personal information to register on the Website, We delete such information from the Company’s servers.

11. Changes

11.1. From time to time, We may make changes to this Privacy Policy, but the content of such changes will never limit Your rights with respect to Your personal data to a greater extent than is established by applicable law.

11.2. In the event of changes, they enter into force from the moment of posting the amended text of the Privacy Policy on the Website, unless a different deadline is specified for the changes to enter into force. We inform You of such changes via email.

11.3. If You do not agree to the amended edition of the Privacy Policy, We ask You to stop using the Website and block Your Account via the interface in Your Account or by contacting Our Support Service using the contacts listed in the Binomo Client Agreement, having previously withdrawn the funds from Your Account on the Trading Platform.

11.4. In the case of a discrepancy between the text of this Privacy Policy in English and the text in other languages, the version of the Privacy Policy in English shall prevail.

12. Contacts

If You have any questions or would like to receive additional information regarding the processing of Your personal data, to check what is being processed, or to withdraw Your consent to such processing, You may contact us at dataprotection@binomo.com.

Effective July 10, 2023