PRIVACY POLICY
v. 1.0.
Last Revised: September 2024
Privacy Policy 2
TABLE OF CONTENT
1. INTRODUCTION 3
2. WHO WE ARE 3
3. PERSONAL DATA 3
3.1. Information We Collect 3
3.2. KYC 5
3.3. How We Acquire Your Data 5
3.4. Purposes 6
4. DISCLOSURE OF INFORMATION 7
4.1. To Whom We Disclose Information 7
4.2. Third-Party Sites 8
4.3. Payment Providers 9
4.4. International Transfers 9
5. CONSENT 9
6. YOUR LEGAL RIGHTS 10
7. SECURITY 11
1.1. Retention of Records 11
1.2. Security Measures 12
8. GENERAL 12
8.1. Changes to the Privacy Policy 12
8.2. Compliance with Applicable Legislation 13
8.3. Prevailing Language 13
8.4. Questions, Problems, or Complaints 13
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1. INTRODUCTION
The protection of the security and privacy of your Personal Data is important to us and to the way we
conduct our business in compliance with the laws on privacy, data protection, and data security.
This Privacy Policy, together with our Terms and Conditions applicable to you and any additional
provisions that may be incorporated by reference into the terms apply to your use of our services, our
site accessible from Website, and any of the services accessible through the Website and our products
(collectively referred to as “Service”).
The purpose of this Privacy Policy is to outline what information the Company may collect, how it uses
and safeguards that information, and with whom we may share it.
2. WHO WE ARE
FBS is the data controller and is responsible for your Personal Data.
Email address: yasirchakraborty@gmail.com
3. PERSONAL DATA
3.1. Information We Collect
(1) We will collect the following personally identifiable information (“Personal Data”):
Personal details Full name, e-mail address, gender, home address, phone address,
phone number, date of birth, nationality, signature, utility bills,
photographs, and a video recording of the Client
Contact Information E-mail address, country, region
Sensitive and
Biometric Personal
Data
Sensitive personal data, when permitted by local law or with Client
consent, such as biometric information, for example, to verify the
Client’s identity by comparing the facial scan data extracted from the
Client’s selfie or video with the photo in Client’s government issued
identity document.
Government
Identifiers
Government issued identity documents such as passport, national
identification number, national identity card details, driver’s license
numbers.
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(2) Account/Personal Area passwords are stored in the system and are not public information for
employees of the Company who do not need it for the purpose of providing services to the Client.
(3) Through its Website (s), the Company will not collect any Personal Data unless you voluntarily
choose to provide it (e.g., by registration, email inquiry, survey, etc.). If you do not want your
Personal Data to be collected, please do not submit it.
(4) We will process your Personal Data legally and fairly and will not use it outside the purposes of
which we have informed you, including selling it individually or in the aggregate for commercial
use.
(5) We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill
our legal or regulatory obligations and for our business purposes. We may retain Personal Data for
longer periods than required by law if it is in our legitimate business interests and is not directly
prohibited by the applicable law. If your account is deleted, we may take steps to mask Personal
Data and other Data, but we reserve our right to retain and access the data for as long as required
Financial details Assets, liabilities, income, expenses, bank account information,
payment card information, source of funding, source of wealth, job
title, salary wage rate
Taxation information tax file number
Broad location data country location
Browsing Information IP address, geolocation, browser type/version, and operating system
Data about device manufacturer, operating system, CPU, RAM, browser type and
language, current time
Usage data data we collect with cookies and similar technologies
Marketing and
Research Information
Data for advertising and analytics purposes so we can provide the
Client with better service (e.g. browser/web history data and
preferences expressed through selection/viewing/purchase of goods,
services and content, information about Client’s mobile device
including (where available) type of device, device identification
number, mobile operating system.)
Trading experience Information relating to the previous trading experience, personal
goals, and objectives
for the processing of your chooses to give the Company.
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to comply with applicable laws. We will continue to use and disclose such Personal Data in
accordance with this Policy.
(6) We also collect, use, and share aggregated data, such as statistical or demographic data, for
any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but
is not considered Personal Data by the law as this data will not directly or indirectly reveal your
identity. For example, we may aggregate your usage data to calculate the percentage of users
accessing a specific software feature. However, if we combine or connect Aggregated Data with
your Personal Data so that it can directly or indirectly identify you, we treat the combined data as
Personal Data which will be used in accordance with this Privacy Policy.
3.2. KYC
During the Know Your Client (KYC) process, we are also required by law to collect certain
documentation in order to verify your true identity, which may include, but is not limited to, proof of
identity in the form of Identity documents, proof of your permanent residential address in the form of a
utility bill, as well as your credit card details (we request both sides of the bank card. The front side
must contain the first 6 digits and the last 4 digits of the card number, the cardholder’s name, expiry
date, and signature. For security purposes, we request clients cover the CVC/CVV codes on the back
side). User’s card data is not stored in our systems since we do not have a PCI DSS certificate. For all
that information, we rely on our Payment Providers, who are duly certified.
3.3. How We Acquire Your Data
(1) Information may come from the following sources:
directly from you (from our communication and/or forms that you filled in)
cookies stored in your browser by our Website
IP-address
other sources, including third parties and publicly available sources
(2) We may combine that with information we collect via our services.
3.4. Purposes
We collect Personal Data for the following purposes:
(1) to authenticate your access to an account;
(2) to manage your account and keep you updated on all matters that concern your account;
(3) to provide the services that you have requested, including processing transactions;
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(4) to respond to your requests, for example, to contact you about a question you submitted to
our customer service team;
(5) to provide the functionality of our products;
(6) to inform you about changes in our services, our service offering, and other important
service-related notices;
(7) to protect our rights and interests, as well as the rights and interests of our users and any
other person;
(8) to carry out any actions for which we have received your consent;
(9) to perform research and analysis about your use of, or interest in, our products, services,
or content, or products, services, or content offered by others;
(10) to comply with applicable legal or regulatory obligations, including complying with
requests from law enforcement or other governmental authorities or in legal proceedings;
(11) to fulfill our contractual obligations;
(12) to communicate with you, either directly or through one of our partners, including for
customer service, to provide you with updates and other information relating to the
Website, and for marketing and promotional purposes;
(13) to tailor the Website or other service we provide to you relating to your needs and
interests;
(14) to create anonymous statistical data;
(15) to prevent and investigate fraudulent or other criminal activity.
(16) to congratulate you;
(17) to offer you personalized and/or unique offers, services, products.
4. DISCLOSURE OF INFORMATION
4.1. To Whom We Disclose Information
(1) Your Personal Data may be disclosed to different recipients. The list below provides some of
the types of recipients and reasons for sharing your Personal Data.
Category of recipient Examples or
explanation
Share purpose
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Our affiliates Any legal entity
affiliated with the
Company
Providing the basic services under
the Terms and Conditions;
Organizing the work of customer
support service;
Any other purpose deemed
necessary by the Company.
Financial institutions and
other similar organizations
Any such
organizations that
the Company deals
with in the course
of its business
Providing the basic services under
the Terms and Conditions;
Complying with our legal obligations
imposed by applicable laws (in
certain cases provided by law).
Partner (Introducing Broker
Program participant)
Those who had
been contracted to
provide us with
administrative,
financial,
insurance,
research, and/or
other services.
Providing the basic services under
the Company’s legal agreements;
Notifying the Partner that someone
has registered using their Partner
IDs or other identification tools or
has unsubscribed from the Partner.
In this case, we can give your name
and contact information to the
Partner;
Communicating with you through
one of our Partners, including for
customer service, to provide you
with updates and other information
relating to the Website and for
marketing and promotional
purposes.
Auditors, lawyers, and
other examination
organizations
Any entity
conducting an audit
or other
legal/financial
check
Complying with our legal obligations
imposed by applicable laws (in certain cases
provided by law).
Third-party service
providers whose activities
are required to perform the
service
Web hosting,
information
technology
providers
Providing the basic services under the
Terms and Conditions.
Payment partners Enabling purchase opportunities within our
services. These payment processors are
responsible for processing your Personal
Data and may use your Personal Data for
their own purposes in accordance with their
Privacy Policies.
Data aggregation,
analytics, and market
research services
Google Analytics,
Google Ads
Creating and utilizing analytics on
our services and audience;
Conducting advertising and
marketing activity;
Conducting surveys and research;
Personalizing our services for you.
Advertising partners Any partners Conducting advertising and
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marketing activity;
Personalizing our services for you.
Relevant parties in the
event of a change in
control, merger, or
acquisition
As our business develops, we may sell or
buy businesses or assets. In the event of a
corporate sale, merger, reorganization,
dissolution, or similar event, Personal Data
may be part of the transferred assets.
Authorities and parties
where relevant for
compliance with various
laws
Any authority Compliance with our legal obligations
imposed by applicable laws.
(2) Please note that we will never sell the Client’s Personal Data.
(3) In general, we require that any third-party service provider that we share any Personal Data
with undertakes to respect any individual’s right to privacy and comply with the Data
Protection Principles. These third-party service providers may keep a record of any
searches they performed on our behalf, and they may use the search details to assist other
companies in performing their searches. This Privacy Policy does not cover the practices of
third parties.
(4) In cases where the Client is attached to a Partner, such Partner may have access to the
Client’s information. Hence, the Client hereby consents to share information with such
Partner. We provide Partners only the minimum necessary data required for the purpose of
the Partner Agreement.
4.2.Third-Party Sites
Please be notified that FBS cannot be held responsible for the privacy practices of other
websites. We advise all visitors to be aware and read the privacy statements of every
Website that collects personal identity information.
4.3.Payment Providers
In accordance with the recommendations of the Payment Card Industry Security Standards
Council, customer card details are protected using Transport Layer encryption – TLS 1.2
and application layer with algorithm AES and key length 256 bit.
4.4.International Transfers
(1) We operate all over the world, and therefore we may transfer your data to our
counterparties (partners, affiliates, etc.) in different countries, including those which are
located outside the country in which you are based. We take all necessary steps, including
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those imposed on us by applicable law, to ensure an adequate level of Personal Data
protection in each case. However, we would like you to consider that the countries to
which we transfer your data may not have the same data protection laws as your
jurisdiction.
(2) To facilitate our global operations, the Company may transfer, store, and process your
operations with our partners and service providers based outside of the country in which
you are based. Laws in those countries may differ from the laws applicable to your country
of residence. Where we transfer, store, and process your Personal Data outside of the
country where you are based, we will ensure that the appropriate safeguards are in place
to ensure an adequate level of protection. Further details regarding the relevant
safeguards can be obtained from us upon request.
5. CONSENT
(1) BY SUBMITTING INFORMATION, INCLUDING PERSONAL DATA, YOU ARE EXPRESSLY AND
VOLUNTARILY ACCEPTING THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. YOU
HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AND USE YOUR INFORMATION BY
CHANGING YOUR ACCOUNT SETTINGS OR CLOSING YOUR ACCOUNT, BUT YOUR
WITHDRAWAL OF CONSENT WILL NOT BE RETROACTIVE.
(2) You should also be aware that we do not sell, rent, or disclose your Personal Data in
exchange for money or other valuable consideration to any third parties, and we shall not
incorporate such practice in our business unless providing you with a clear and explicit
way to exercise your opt-out right and before introducing appropriate changes to this
Policy.
(3) You consent to transfer your Personal Data to third parties as described in Section 4.1. of
this Privacy Policy, and as described in this Privacy Policy, including to carry out your
instructions or to provide our services, for the purpose of notifying a Partner of a client’s
detachment unless otherwise compelled by law or as necessary to enforce our Terms and
Conditions or to protect the rights or property of the Company or its users or the public. We
may provide Aggregated Data about the usage of our Services to third parties for purposes
that we deem, in our sole discretion, to be appropriate.
(4) We will display the Personal Data you select on your profile page and elsewhere according
to the preferences you select in your account settings. This Personal Data may be made
available for public viewing to other Clients.
Marketing mailings
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(1) If you provide us with your email address and agree to this Privacy Policy, our partners and
we may send you emails regarding the products we offer. You can choose to opt out of
receiving emails from us at any time. If you wish to opt out with respect to more than one
email address, you must provide a separate request for each email address. Every email
sent from us will include appropriate unsubscribe instructions. To opt out of all email
marketing messages from us, you should follow the instructions provided with each email.
(2) If you provide us with your telephone number and agree to this Privacy Policy, our partners
and we may send you texts or call you regarding the products we offer. You can choose to
opt out of receiving texts or calls from us at any time by emailing us.
6. YOUR LEGAL RIGHTS
In accordance with applicable law, the Client may have the right to:
(1) Access Personal Data about the Client.
The Client may, at any time, request access to the Client’s Personal Data, and the Company
will provide the Client with access to that information either by providing copies of the
information requested, allowing the Client to inspect the information requested, or providing
the Client with an accurate summary of the information held. The Company may, prior to
providing access in accordance with this Privacy Policy, require the Client to provide evidence
of the Client’s identity. In the event the Company refuses access to the Client’s Personal Data;
the Company will provide an explanation for that refusal. The Company will endeavor to
respond to any request for access within 14 days depending on the complexity of the
information and/or the request and may charge fees for the request of a significant amount of
information to be copied or accessed.
(2) Request correction of Client’s Personal Data where it is inaccurate, incomplete, or
outdated.
To assist the Company with this, please contact the Company if any details the Client has
provided change. Furthermore, if the Client believes that the information the Company has
about the Client is not accurate, complete, or up to date, please contact us, and we will take all
reasonable steps to correct the information.
(3) Request deletion, anonymization, or blocking of Client’s Personal Data.
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The Client may, at any time, request the deletion of Client’s Personal Data. We undertake to
perform the deletion within one month (30 calendar days). Please note that, under certain
circumstances, the Company may continue to process Personal Data if required to do so by
applicable law.
(4) Request restriction of or object to our processing of Client’s Personal Data.
(5) Withdraw the Client’s consent to our processing of the Client’s Personal Data.
(6) Request data portability and receive an electronic copy of the Personal Data that the
Client has provided to the Company.
(7) Be informed about third parties with which Client’s Personal Data has been shared.
(8) Request the review of decisions taken exclusively based on automated processing if
that could affect data subject rights.
7. SECURITY
7.1. Retention of Records
(1) We may be requested to retain and use your Personal Data to meet our legal obligations
for data security purposes and as we believe to be fit and necessary or appropriate for
purposes that include, but are not limited to,
a. compliance with our requirements under applicable laws and regulations;
b. responding to requests from courts and/or other public and governmental
authorities;
c. monitoring through compliance and anti-money laundering processes.
(2) We will not keep your information for any longer than the time required. In many cases,
information must be kept for considerable periods of time. Retention periods will be
decided, considering 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. Under applicable
regulations, we will keep records containing Personal Data, trading information, account
opening and verification documents, communication, and anything else that is relative to
the Client for a maximum of seven (7) years after the termination of the Agreement
between you and our Company. In any event, we will keep your information for a minimum
duration as provided in the applicable Limitation of Actions Law.
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7.2. Security Measures
(1) The Company takes precautions to ensure the security of your Personal Data and strives
to keep it accurate.
(2) We act with care to protect the Client’s Personal Data from loss, destruction, falsification,
manipulation, and unauthorized access or unauthorized disclosure. To do so, we have
developed and will maintain security procedures to safeguard Personal Data against loss,
theft, copying, and unauthorized disclosure, use, and/or modification.
(3) Access to Personal Data is limited to the company employees and authorized service
providers who require to receive it in order to perform their work.
(4) While we will use all reasonable efforts to safeguard the Client’s information, the Client
acknowledges that the use of the Internet is not entirely secure, and therefore, we cannot
provide any guarantee concerning the security or integrity of any Personal Data
transferred from or to the Client with the use of the Internet.
8. GENERAL
8.1. Changes to the Privacy Policy
This Privacy Policy may be modified from time to time, thus, check back often. To help you
be aware if changes have been made, we will adjust the “Last Revised” date or “Date of
publication” at the beginning of this document. The new Policy may be displayed on-screen,
and you may be required to read it to continue using the Service, Product, or Website.
Continued use of our products and services by you will constitute your acceptance of any
changes or revisions to this Policy.
8.2. Compliance with Applicable Legislation
We are committed to complying with applicable privacy and data protection laws and
regulations designed to protect your Personal Data, including the Data Protection Bill, 2021,
and other applicable current or future regional and state privacy and data protection laws
and regulations worldwide as they become effective.
8.3. Prevailing Language
This document, as well as the Company’s other legally-binding documents, is drawn up in
English. Any other version is provided as a translation. In the event of a conflict between the
