This Policy applies to ZEYFEX LLC (referred to as ‘Zeyfex’, ‘we’, ‘our’, ‘us’) and extends to and covers all operations and functions of ZEYFEX ’.
This Policy outlines ZEYFEX’ obligations to manage and protect personal information. ZEYFEX is bound by the St. Vincent & the Grenadines Privacy Freedom of Information Act 2003 (‘Privacy Act’), and where applicable, the EU General Data Protection Regulation (GDPR). This Policy also outlines ZEYFEX practices, procedures and systems that ensure compliance with the Privacy Act, and where applicable, the GDPR.
Where the GDPR applies to your personal information, we will be the responsible controller for any personal information you provide to us in connection with your relationship with us.
We collect and hold the following kinds of personal information about individuals:
ZEYFEX will not collect sensitive information unless the individual has consented or an exemption under the Privacy Act applies. These exceptions include if the collection is required or authorised by law or is necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If the personal information we request is not provided by an individual, we may not be able to provide the individual with the benefit of our services, or meet their needs appropriately.
ZEYFEX does not give individuals the option of dealing with them anonymously, or under a pseudonym, as ZEYFEX is required to identify all trading clients under the St. Vincent & the Grenadines Anti-Money Laundering and Terrorist Financing Regulations 2014, as amended. In addition, it is impracticable for ZEYFEX to deal with individuals who have no identified themselves or us a pseudonym.
Where your personal information is being collected under the GDPR, ZEYFEX will also take reasonable steps to make you aware of:
ZEYFEX may receive unsolicited personal information about individuals. ZEYFEX’ employees are required to notify the Privacy Officer of all unsolicited personal information received by them. We destroy all unsolicited personal information, unless the personal information is relevant to ZEYFEX’ purposes for collecting personal information.
The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals:
If necessary, we will also collect information about individuals such as:
We may collect and hold the information about an individual for the following purposes:
ZEYFEX may use and disclose personal information for the primary purposes for which it is collected (set out in section 6 above), for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act.
ZEYFEX will use your personal information for any of the following purposes:
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or permitted by law.
We engage other people to perform services for us, which may involve that person handling personal information we hold. In these situations, we prohibit that person from using personal information about the individual except for the specific purpose for which we supply it. We prohibit that person from using the individual’s information for the purposes of direct marketing their products or services.
ZEYFEX will attempt to destroy or de-identify sensitive information wherever possible. We also undertake to take reasonable steps to destroy or de-identify all personal information about an individual when it is no longer needed.
We may disclose personal information to:
Where we are processing your personal information under the GDPR, we will process your personal information to the parties listed above, and the purposes for use listed above because:
The legal bases for processing of your personal information are set forth in Article 6 of the GDPR.
As a general principle, you will provide us with your personal data entirely voluntarily; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which ZEYFEX cannot take action without certain of your personal data, for example because this personal data is required to process your orders, provide you with access to a web offering or newsletter or to carry out a legally required compliance screening. In these cases, it will unfortunately not be possible for ZEYFEX to provide you with what you request without the relevant personal data.
We will not send personal information to recipients unless:
ZEYFEX recognises how important the security of personal information is to our clients. We will at all times seek to ensure that the personal information we collect and hold is protected from inference, misuse or loss, unauthorised access, modification or disclosure. ZEYFEX’ employees must respect the confidentiality of the personal information we collect. We hold all of your personal information in secure computer storage facilities and in paper-based files. In relation to our computer storage facilities, we apply the following guidelines:
We will hold your personal information as long as required to provide you with the products or services, products or information you have requested and to execute and administer your business relationship with us. We are also required to keep certain information (e.g. relating to business or tax relevant transactions) for certain retention periods under applicable law. Your personal information will be promptly deleted when it is no longer required for these purposes.
We may use third party service providers to assist us to promote our products and services to individuals. ZEYFEX does not use personal information for the purposes of direct marketing unless:
If the individual would not reasonably expect us to use or disclose the information for the purpose of direct marketing, we may only use or disclose that information for direct marketing if the individual has consented to the use or disclosure of the information for direct marketing or it is impracticable to obtain that consent.
In relation to sensitive information, ZEYFEX may only use or disclose sensitive information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose. Individuals have the right to request to opt out of direct marketing and we must give effect to the request within a reasonable period of time.
Individuals may also request that ZEYFEX provides them with the source of their information. If such a request is made, ZEYFEX must notify the individual of the source of the information free of charge within a reasonable period of time.
If your personal information is being processed under the GDPR, where your permission is required for any marketing-related communication, we will only provide you with such information if you have opted in. You may opt out at any time if you do not want to receive any further marketing-related types of communication from us.
We will not use identifiers assigned by the Saint Vincent & the Grenadines Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes, unless any exemption as per the Privacy Act applies. ZEYFEX endeavours to avoid data-matching.
ZEYFEX is committed to ensuring that the personal information it collects, holds, uses and discloses is relevant, accurate, complete and up-to-date. We encourage individuals to contact us to update any personal information we hold about them. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless the individual agrees otherwise. We do not charge individuals for correcting the information.
Subject to the exceptions set out in the Privacy Act, individuals may gain access to the personal information that we hold about them by contacting the ZEYFEX’ Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide the information, we will provide reasons for the refusal. An individual’s request for access to his or her personal information will be dealt with by allowing the individual to look at his or her personal information at the offices of ZEYFEX, or by providing copies of the information requested. We will require identity verification and specification of the information required. An administrative fee for search and photocopying costs may be charged for providing access.
Once a client visits our web site www.zeyfex.com/int/, campaign and advertising cookies will be placed in a client’s device so that we can track the client, measure advertising outcome along with recording client interest. Our marketing and advertising partners including Google, Marketo, Hotjar, Taboola and more enables us to record client interest on products, client tracking and conversions. Cookies used by us and our partners do not collect personal information such as name, email, address or phone number. Clients can disable cookies from their browser however we encourage them to keep cookies enabled for a better site experience and to receive targeted materials from us.
If you are located in the EU a resident of the European Union for the purpose of GDPR (General Data Protection Regulations, regulation 2016/679 of the European Parliament), then in addition to above the following will apply to you.
If your personal information is being processed under the GDPR, where your permission is required for any marketing-related communication, we will only provide you with such information if you have consented to us sending you such communications. You can unsubscribe from receiving these communications at any time.
In addition to your rights above you may:
You have the right to complain to the relevant supervisory authority in your country. For example, if you are in the UK, you may contact the Information Commissioner’s Office via their website (www.ico.gov.uk).
Our Representative for the purpose of GDPR is set out below:
To: Privacy Officer
This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.
ZEYFEX are required by the St. Vincent & the Grenadines Anti-Money Laundering and Terrorist Financing Regulations 2014, as amended to verify your identity before we can provide you with financial products and services. Electronic verification allows us to verify your identity by using electronic tools and external data sources.
In order to verify your identity electronically, we will ask you for your details (such as your name, address, date of birth) and details of your identification documents. This information will be passed on to external organisations in order to electronically match your information with information on their databases. These organisations will assess and advise us whether all or some of the information you provided matches their records.
The external data sources used to verify your identity include:
It is an offence under the St. Vincent & the Grenadines Anti-Money Laundering and Terrorist Financing Regulations 2014, as amended to provide false and misleading information about your identity.
By agreeing to our terms and conditions you affirm that:
Should you wish to make a complaint we ask that you follow the process outlined below, this will aid us in resolving your complaint in the most efficient manner possible in order to regain your confidence.
Firstly, gather all supporting documents that relate to your complaint, think about the questions you want answered and decide what you want us to do. Next, contact your account manager directly. Remember, if the problem is current a call at the earliest possible time will give us the opportunity to resolve your complaint immediately. If your account manager is unable to satisfactorily resolve your complaint, please ask them to refer the complaint to their manager. If your complaint is about your account manager, please ask to speak to our Compliance department.
If your complaint cannot be resolved then you may refer the matter to our Compliance department if we have not already done so. They will review your complaint and contact you directly.
You can also contact our Compliance team directly by sending an email to: [email protected]
We aim to resolve most matters within 21 days. However, some complaints are more complex and may take longer to resolve. If this is the case, we will keep you informed of our progress.
Subject to the St. Vincent & the Grenadines Privacy Freedom of Information Act 2003 (‘Privacy Act’), ZEYFEX is required to comply with the data breaches, and where the GDPR is applicable, the data breach notification provisions in the GDPR.
Should any staff member become aware of any possible data breach where confidential data may have been accessed without the known consent of ZEYFEX, then this must be immediately reported to the Compliance Manager.
The Compliance Manager, in conjunction with Senior Management, will investigate the matter and if necessary obtain legal advice. Should it be considered that serious harm could arise from the breach then appropriate will be made in accordance with the Act.