1. Introduction

2. Safeguarding the conﬁdentiality of your personal information and protecting your

privacy

3. Personal information we collect

4. Processing of personal information and purposes

5. Disclosure of your personal information

6. Transfers outside Amega Group

7. Information collected from your use of our services

8. Cookies

9. How we obtain your consent

10. Storage of your personal information and retention period

11. Your rights regarding your personal information

12. Choice to opt-out collecting your personal information

13. Legal disclaimer

14. Changes in this privacy policy

15. Complaint and contact details

1. Introduction

1.1. AMEGA CAPITAL LTD. (referred to as the ‘Company’) provides you with

this ‘Privacy Policy’ (the Policy) to help you understand the risks that

might arise when trading Contracts for Difference (CFDs). However, you

need to bear in mind that the Policy does not contain all the risks and

aspects involved in trading CFDs. The Client should carefully read the

Policy in conjunction with the 'Client Agreement', the ‘Order Execution

Policy’ and the documentation/information available to you through our

Website.

1.2. This Policy outlines the Company’s responsibility to manage the

protection of privacy and the safekeeping of client’s personal and

ﬁnancial information. Your privacy is Company’s highest priority and

applies to all users of the Company’s website, whether you are former,

present or potential client of the Company.

1.3. The Company follows different principles in accordance with global

protection acts in order to achieve client privacy and data protection.

By subscribing to and/or using the Service, the Client expresses his

consent to the terms of this Policy. If the Client hereby gives its

consent to such collection, processing, storage and use of personal

information by the Company as explained below.

1.4. In addition, as a recipient of our Service, the Client commits to provide

appropriate notice of its privacy practices to, and obtain the necessary

permissions and consent from any User whose Personal Information is

collected, received, used and/or disclosed (collectively, “Process(ed)”)

by the Company.

2. Safeguarding the conﬁdentiality of your

personal information and protecting your

privacy

2.1. The Company respects the privacy of any users who access its

website(s), and it is therefore committed to taking all reasonable steps

to safeguard any existing or prospective clients, applicants and website

visitors.

2.2. The Company keeps any clients’/potential clients’ personal data in

accordance with the applicable data protection laws and regulations.

2.3. We have the necessary and appropriate technical and organisational

measures and procedures in place to ensure that your information

remains secured at all times. We regularly train and raise awareness to

all of our employees on the importance of maintaining, safeguarding

and respecting your personal information and privacy. We regard

breaches of individuals’ privacy very seriously and will impose

appropriate disciplinary measures, including dismissal where

necessary. The personal information you provide us with when

registering yourself as a user of the Company’s website(s) and/or of its

services, is classiﬁed as registered information, which is protected in

several different ways. You can access your registered information

after logging into the Client Area by entering a username and a

password that you select. It is your responsibility to make sure that

your password is only known to you and not disclosed to anyone else.

Registered information is securely stored in a safe location and only

authorized personnel have access to it via a username and password.

All personal information is transferred to the Company over a secure

SSL connection and thus all necessary measures are taken to prevent

unauthorized parties from viewing any such information. Personal

information provided to the Company that does not classify as

registered information is also kept in a safe place and accessible by

authorized personnel only via a username and a password.

2.4. Transmission of information via the internet is not always completely

secure, but the Company endeavors to protect your personal

information by taking serious precautions. Once we have received your

personal information, we will apply procedures and security features to

try to prevent unauthorized access.

3. Personal information we collect

3.1. In order to open an account with us, you must ﬁrst complete and

submit an application form to us by completing the required

information. By completing this form, you are requested to disclose

personal information in order to enable the Company to assess your

application and comply with the relevant rules and regulations. The

information you provide may also be used by the Company to inform

you regarding its services.

3.2. The information we may collect from you includes the following:

a. Full name, residential address and contact details (e.g. email

address, telephone number, fax etc)

b. Date of birth, place of birth, gender, citizenship

c. Information about your income and wealth, including details

about your source of funds, assets and liabilities, bank account

information, trading statements, FATCA and CRS information

and ﬁnancial statements

d. Trading account balances, trading activity, your inquiries and our

responses

e. Information on whether you hold a prominent public function

(PEPs)

f. Profession and employment status

g. Authentication data (e.g. signature)

h. Location data

i. Trading performance, knowledge and experience

j. Veriﬁcation information, which includes information necessary

to verify your identity such as passport or driving license

(examples also include background information we receive

about you from public records or from other entities not

aﬃliated with us); furthermore, we may collect other identiﬁable

information such as identiﬁcation numbers and/or passport/tax

registration numbers

k. Any other information customarily used to identify you and

about your trading experience which is relevant to us providing

our services to you.

3.3. We obtain this information in a number of ways through your use of our

services including through any of our websites, apps, account opening

applications, our demo sign up forms, webinar sign up forms,

subscribing to news updates and from information provided in the

course of ongoing customer service communications. We may also

collect this information about you from third parties such as through

publicly available sources. We also keep records of your trading

behavior, including records regarding the following:

a. Products you trade with us and their performance

b. Historical data about the trades and investments you have made

including the amount invested

c. Your preference for certain types of products and services

We may ask for other personal information voluntarily from time to time (for

example, through market research or surveys).

3.4. We may record any communications, electronic, by telephone, in

person or otherwise, that we have with you in relation to the services

we provide to you and our business relationship with you. These

recordings will be our sole property and will constitute evidence of the

communications between us. Such telephone conversations may be

recorded without the use of a warning tone or any other further notice.

Further, if you visit any of our oﬃces or premises, we may have CCTV

which will record your image.

3.5. Where we receive personal information about an individual which is

unsolicited by us and not required for the provision of our services, we

will securely destroy the information (provided it is lawful and

reasonable for us to do so).

4. Processing of personal information and

purposes

4.1. We may process your personal information on the following basis and

for the following purposes:

a. Performance of contractual obligations: we process personal

information in order to provide our services and products, as

well as information regarding our products and services based

on the contractual relationship with our clients (i.e. so as to

perform our contractual obligations). In addition, processing of

personal data takes place to be able to complete our client

on-boarding/acceptance procedures.: we process personal

information in order to provide our services and products, as

well as information regarding our products and services based

on the contractual relationship with our clients (i.e. so as to

perform our contractual obligations). In addition, processing of

personal data takes place to be able to complete our client

on-boarding/acceptance procedures.

In view of the above, we need to verify your identity in order to

accept you as our client and we will need to use those details in

order to effectively manage your trading account with us to

ensure that you are getting the best possible service from us.

This may include third parties carrying out credit or identity

checks on our behalf. The use of your personal information is

necessary for us to know who you are as we have a legal

obligation to comply with certain Know Your Customer and

Customer Due Diligence requirements.

b. Compliance with a legal obligation: there are a number of legal

obligations emanating from the relevant laws and supervisory

authorities to which we are subject as well as statutory

obligations (e.g. the Anti-Money Laundering Laws, Financial

Services Laws, Corporation Laws, Privacy Laws and Tax Laws).

Such obligations and requirements impose on us necessary

personal data processing activities for credit-checks, identity

veriﬁcation, compliance with court orders, tax law or other

reporting obligations and anti-money laundering controls.

These obligations apply at various times, including client

onboarding, payments and systemic checks for risk

management.

c. Safeguarding legitimate interests: we process personal data so

as to safeguard the legitimate interests pursued by us or by a

third party. A legitimate interest is when we have a business or

commercial reason to use your information. Despite that, it must

not unfairly go against what is right and best for you. Examples

of such processing activities include the following:

- Initiating legal claims and preparing our defense in

litigation procedures

- Means and processes we undertake to provide for the

Company’s IT and system security, preventing potential

crime, asset security, admittance controls and

anti-trespassing measures

- Setting up CCTV systems (e.g. at our premises for

security purposes)

- Measures to manage business and for further developing

products and services

- Sharing your personal information with third party service

providers for the purpose of updating/verifying your

personal data in accordance with the relevant anti-money

laundering compliance framework

- Risk management

d. You have provided your consent: our storage and use of

personal data is based on your consent (other than for the

reasons described or implied in this policy when your consent is

not required). You may revoke consent at any time; however, any

processing of personal data prior to the receipt of your

revocation will not be affected.

e. To assess the appropriateness of our services/products for the

Clients

f. To provide you with products and services, or information about

our products and services and to review your ongoing needs:

once you successfully open a trading account with us, or

subscribe to an update or webinar, we will need to use your

personal information to perform our services and comply with

our obligations to you. It is also in our legitimate interests to

ensure that we are providing the best products and services so

we may periodically review your needs to ensure that you are

getting the beneﬁt of the best possible products and services

from us.

g. To help us improve our products and services, including

customer services, and develop and market new products and

services: we may from time to time use personal information

provided to you through your use of the services and/or through

client surveys to help us improve our products and services. It is

in our legitimate interests to use your personal information in

this way to try to ensure the highest standards when providing

you with our products and services and to continue to be a

market leader in the ﬁnancial services industry.

h. To form a proﬁle about you: we may from time to time use

personal information provided to you through your use of the

services and/or through client surveys to help us improve our

products and services. It is in our legitimate interests to use

your personal information in this way to try to ensure the highest

standards when providing you with our products and services

and to continue to be a market leader in the ﬁnancial services

industry.

i. To investigate or settle enquiries or disputes: we may need to

use personal information collected from you to investigate

issues and/or settle disputes with you as it is in our legitimate

interests to ensure that issues and/or disputes get investigated

and resolved in a timely and eﬃcient manner.

j. To comply with applicable laws, court orders, other judicial

processes, or the requirements of any applicable regulatory

authorities: we may need to use your personal information to

comply with any applicable laws and regulations, court order or

other judicial process, or the requirements of any applicable

regulatory authority. We do this not only to comply with our legal

obligations but because it may also be in our legitimate interest

to do so.

k. To send you surveys: from time to time, we may send you

surveys as part of our customer feedback process. It is in our

legitimate interest to ask for such feedback to try to ensure that

we provide our services and products at the highest standards.

However, we may, from time to time, also ask you to participate

in other surveys and if you agree to participate in other surveys

we rely on your consent to use the personal information we

collect as part of such surveys. All responses to any survey we

send out whether for customer feedback or otherwise will be

aggregated and depersonalized before survey results are shared

with any third parties.

l. Data analysis: our website pages and emails may contain web

beacons or pixel tags or any other similar type of data analysis

tools that allow us to track receipt of correspondence and to

count the number of users that have visited our webpage or

opened our correspondence. We may aggregate your personal

information (such as trading history) with the personal

information of our other clients on an anonymous basis (that is,

with your personal identiﬁers removed) so that more rigorous

statistical analysis of general patterns may lead to us providing

better products and services.

If your personal information is completely anonymised, we do

not require a legal basis as the information will no longer

constitute personal information. If your personal information is

not in an anonymised form, it is in our legitimate interest to

continually evaluate that personal information to ensure that the

products and services we provide are relevant to the market.

m. Marketing purposes: we may process your personal information

to send you marketing communications by email or phone or

other agreed forms (including social media campaigns) to

ensure that you are always kept up to date with our latest

products and services. If we send you marketing

communications, we will either do so based on your consent or

if it is in our legitimate interest. We will not disclose your

information to any outside parties for the purpose of allowing

them to directly market to you.

n. Internal business purposes and record keeping: we may need to

process your personal information for internal business and

research purposes as well as for record keeping purposes. Such

processing is in our legitimate interests and is required in order

to comply with our legal obligations. This may include any

communications that we have with you in relation to the

services we provide to you and our relationship with you. We will

also keep records to ensure that you comply with your

contractual obligations pursuant to the agreement governing our

relationship with you.

o. Legal notiﬁcations: often the law requires us to advise you of

certain changes to products or services or laws. We may need to

inform you of changes to the terms or the features of our

products or services. We need to process your personal

information to send you these legal notiﬁcations. You will

continue to receive this information from us even if you choose

not to receive direct marketing information from us.

p. Corporate restructuring: if we undergo a corporate restructuring

or part, or if all of our business is acquired by a third party, we

may need to use your personal information in association with

that restructuring or acquisition. Such use may involve sharing

your information as part of a due diligence enquiries or

disclosures pursuant to legal agreements. It is our legitimate

interest to use your information in this way, provided we comply

with any legal/regulatory obligation we have towards you.

q. Physical security: if you enter any of our premises we may

record your image on our CCTV for security reasons. We may

also take your details to keep a record of who has entered our

premises on any given day. It is our legitimate interest to do this

to maintain a safe and secure working environment.

5. Disclosure of your personal information

5.1. The Company shall not disclose any of its clients’ conﬁdential

information to a third party, except:

a. To the extent that it is required to do so pursuant to any

applicable laws, rules and/or regulations

b. If there is a duty to the public to disclose

c. If our legitimate business interests require disclosure

d. At your request or with your consent or to persons described in

this Policy

5.2. The Company will endeavor to make such disclosures on a ‘need to

know’ basis, unless otherwise instructed by a regulatory authority.

Under such circumstances, the Company will notify the third party

regarding the conﬁdential nature of any such authority.

5.3. As part of using your personal data for the purposes set out above, the

Company may disclose your personal information to the following:

a. Our Associates, for business purposes, including certain third

parties such as service providers and specialist advisers who

have been contracted to provide us with administrative, ﬁnancial,

legal, insurance, research or other services

b. Business introducers with whom we have a mutual business

relationship

c. Business parties, credit providers, courts, tribunals and

regulatory authorities as agreed or authorized by Law

d. Payment service providers (PSPs) and/or banking institutions in

relation to issues raised regarding deposits/withdrawals to/from

trading account(s) held with the Company and/or for the

purpose of commencing an investigation regarding such

matters (e.g. third party deposits)

e. Anyone authorized by you

5.4. If the Company discloses your personal information to business

parties, such as card processing companies or banks, in order to

perform the services requested by clients, such third parties may store

your information in order to comply with their legal and other

obligations.

5.5. Generally, we require that organizations outside the Company who

handle or obtain personal information acknowledge the conﬁdentiality

of this information, undertake to respect any individual’s right to privacy

and comply with all relevant data protection laws and this Privacy

Policy. Third party service providers such as credit referencing

agencies (if and when applicable) may keep record of any searches

performed on our behalf and may use the search details to assist other

companies in performing their searches. Please note that the use of

your personal information by external third parties who act as data

controllers of your personal information is not covered by this Privacy

Policy and is not subject to our privacy standards and procedures.

5.6. Clients accept and consent that the Company may, from time to time,

analyze the data collected while visiting our website(s) or by other

means, such as questionnaires, for statistical purposes in order to

improve the Company’s business activities.

6. Transfers outside Amega Group

6.1. We may transfer your personal information outside the Amega Group

to service providers (i.e. processors) who are engaged on our behalf.

To the extent we transfer your information outside the Amega Group,

we will ensure that the transfer is lawful and that processors in third

countries are obligated to comply with the applicable data protection

laws and/or regulations or other countries’ laws which are comparable

and to provide appropriate safeguards in relation to the transfer of your

data.

6.2. In view of the above, your personal information may be processed by

the staff of our service providers operating outside AMEGA CAPITAL

LTD., who work for us. Such staff may be, among others, engaged in the

fulﬁllment of your requests, the processing of your payment details and

the provision of support services. By submitting your personal data,

you agree to this transfer, strong and processing. The Company will

take all steps reasonably necessary to ensure that your data is treated

securely and in accordance with this Privacy Policy.

7. Information collected from your use of our

services

7.1. Tracking systems used on the Company’s website(s) may collect your

personal data in order to optimize the services provided to

clients/potential clients. The website collects information in the

following ways:

a. Device information: by recognizing your device used to access

and sue the Company’s website(s), we can provide you with the

most appropriate version of our website(s)

b. Log information: logging certain behaviors on the side enables

the Company to track user action and therefore troubleshoot any

issues that may occur

c. Location information: using your IP address helps us localize

our website content, which we provide to you based on your

country, and improve your user experience on our site(s)

d. Cookies: cookies are text ﬁles with a small amount of data sent

from our website(s) to your browser and stored on your

computer’s hard drive. Cookies help us improve the performance

of our website(s) and our website visitors’ experience, track your

referrer (if any) and improve our future advertising campaigns

e. Local storage: you must submit veriﬁcation documents to us

through the Company’s Client Area in order to activate your

trading account. These documents are transmitted over a

secure SSL connection and stored in a safe location.

8. Cookies

8.1. Internet cookies are small pieces of data sent from our website(s) to

your browser and stored on your computer’s hard drive when using our

website(s), and they may include a unique identiﬁcation number. The

purpose of collecting this information is to provide you with a more

relevant and effective experience on our website(s), including the

presentation of our web pages according to your needs or preferences.

8.2. Cookies are frequently used on many websites on the internet and you

can choose if and how a cookie will be accepted by changing your

preferences and options in your browser. You may not be able to

access some parts of our website(s) if you choose to disable the

cookie acceptance in your browser, particularly in the Company’s Client

Area and other secure parts of our website(s). We therefore

recommend you to enable cookie acceptance in order to beneﬁt from

all our online services.

8.3. Furthermore, we use cookies for remarketing features in order to allow

us to reach out to users who have previously visited our website(s) and

have shown an interest in our products and services. periodically , we

may use third party vendors to display our ads over the internet to you,

based on your previous use of our website(s). You can opt out this

particular use of cookies at any time by emailing us at

support@amega.capital.

8.4. The Company uses session ID cookies and persistent cookies. A

session ID cookie expires after a set amount of time or when the

browser window is closed. A persistent cookie remains on your hard

drive for an extended period of time. You can remove persistent

cookies at any time by emailing us at support@amega.capital.

8.5. For further details about our Cookies Policy and how our cookies work,

read our Cookies Policy.

9. How we obtain your consent

9.1. Where our use of your personal information requires your consent,

such consent will be provided in accordance with the express written

terms which govern our business relationship (which are available on

our website(s) as amended from time to time), or any other contract we

may have entered into with you or as set out in communication with

you from time to time.

9.2. If we rely on your consent as our legal basis for holding and processing

your personal information, you have the right to withdraw that consent

at any time by contacting us using the contact details set out in this

10. Storage of your personal information and

retention period

10.1. Safeguarding the privacy of your personal information is of utmost

importance to us, whether you interact with us personally, by phone, by

email, over the internet or any other electronic medium. We will hold

personal information, for as long as we have a business relationship

with you, in a combination of secure computer storage facilities and

paper-based ﬁles, and other records and we take the necessary

measures to protect the personal information we hold from misuse,

loss, unauthorized access, modiﬁcation or disclosure.

10.2. When we consider that personal information is no longer necessary for

the purpose for which it was collected, we will remove any details that

will identify you or we will securely destroy the records. However, we

may need to maintain records for a signiﬁcant period of time. For

example, we are subject to certain anti-money laundering laws which

require us to retain the following, for a period of ﬁve (5) years after our

business relationship with you has ended:

a. A copy of the documents we used in order to comply with our

customer due diligence obligations

b. Supporting documentation and records of transactions with you

and your relationship with us

10.3. Also, the personal information we hold in the form of a recorded

communication, by telephone, electronically, in person or otherwise, will

be held in line with local regulatory requirements (e.g. 5 years after our

business relationship with you has ended). Where you have opted out

of receiving marketing communications we will hold your details on our

suppression list so that we know you do not want to receive these

communications.

10.4. We may keep your data for longer than ﬁve years if we cannot delete it

for legal, regulatory or technical reasons.

11. Your rights regarding your personal

information

11.1. Your rights that might be available to you in relation to the personal

information we hold about you are set below. You may exercise these

rights by sending us an email at dpo@amegafx.com.

11.2. Information and Access: if you ask us, we will conﬁrm whether we are

processing your personal information and, if so, what information we

process and if requested, provide you with a copy of that personal

information (along with certain other details) within thirty (30) days

from the date of your request. If you require additional copies, we may

need to charge a reasonable administration fee.

11.3. Rectiﬁcation: it is important to us that your personal information is up

to date. We will take all reasonable steps to make sure that your

personal information remains accurate, complete and up to date. If the

personal information we hold about you is inaccurate or

incomplete,you are entitled to have it rectiﬁed. If we have disclosed

your personal information to others, we will let them know about the

rectiﬁcation where possible. If you ask us, if possible and lawful to do

so, we will also inform you who we have shared your personal

information with so you can contact them directly. You may inform us

at any time that your personal details have changed by sending us an

email at support@amega.capital. The Company will change your

personal information in accordance with your instructions. To proceed

with such requests, in some cases we may need supporting

documents from you as proof, e.g. utility bills, that we are required to

keep for regulatory or legal purposes.

11.4. Erasure: you can ask us to delete or remove your personal information

in certain circumstances such as if we no longer need it or you

withdraw your consent (if applicable) provided that we have no legal

obligation to retain that data. Such requests will be subject to any

retention limits we are required to comply with in accordance with

applicable laws and regulations and subject to section ‘Storage of your

personal information and retention period’. If we have disclosed your

personal information to others, we will let them know about the erasure

where possible. If you ask us, where possible and lawful to do so, we

will also inform you who we have shared your personal information

with so that you can contact them directly.

11.5. Processing restrictions: you can ask us to ‘block’ or suppress the

processing of your personal data in certain circumstances such as if

you contest the accuracy of that personal information or object to us

processing it. It will not stop us from storing your personal information.

We will inform you before we decide not to agree with any requested

restriction. If we have disclosed your personal information to others,

we will let them know about the erasure where possible. If you ask us,

where possible and lawful to do so, we will also inform you who we

have shared your personal information with so that you can contact

them directly.

11.6. Data portability: under the General Data Protection Regulation

(679/2016), you have the right, in certain circumstances, to obtain

personal information you have provided us with (in a structured,

commonly used and machine readable format) and to re-use it

elsewhere or ask us to transfer this to a third party of your choice.

11.7. Objection: you can ask us to stop processing your personal

information, and we will do so, if we are:

a. Relying on our own or someone else’s legitimate interests to

process your personal information except if we can demonstrate

compelling legal grounds for the processing;

b. Processing your personal information for direct marketing;

c. Processing your personal information for research unless we

reasonably believe such processing is necessary or prudent for

the performance of a task carried out in the public interest (such

as by a regulatory or enforcement agency).

11.8. Automated decision-making and proﬁling: if we have made a decision

about you based solely on an automated process (e.g. through

automatic proﬁling) that affects your ability to use the services or has

another signiﬁcant effect on you, you can request not be subject to

such a decision unless we can demonstrate to you that such decision

is necessary for entering into, or the performance of, a contract

between you and us. Even where a decision is necessary for entering

into or performing a contract, you may contest the decision and require

human intervention. We may not be able to offer our services or

products with you, if we agree to such a request (e.g. end our

relationship with you).

12. Choice to opt-out collecting your personal

information

12.1. Should you not want us to use your personal information, you must

inform the Company by sending an email to dpo@amegafx.com. If you

decide to do so, we may not be able to continue to provide information,

services and/or products requested by you and we will have no liability

to you in this respect.

13. Legal disclaimer

13.1. The Company may disclose your personally identiﬁable information as

required by rules and regulations and when the Company believes that

disclosure is necessary to protect our rights and/or to comply with any

proceedings, court order, legal process served or pursuant to

governmental, intergovernmental or other regulatory bodies. The

Company shall not be liable for misuse or loss of personal information

or otherwise on the Company’s website(s) that the Company does not

have access to or control over. The Company will not be liable for

unlawful or unauthorized use of your personal information due to

misuse or misplacement of your passwords, negligent or malicious

intervention and/or otherwise by you or due to your acts or omissions

or a person authorized by you (whether that authorisation is permitted

by the terms of our legal relationship with you or not).

14. Changes in this privacy policy

14.1. Our Privacy Policy is reviewed from time to time to take into account

new laws and technologies, changes to our operations and practices,

and to ensure that it remains appropriate to the changing environment.

14.2. If we decide to change our Privacy Policy, we will post those changes

to this Privacy Policy and other places we deem appropriate so that

you are aware of what information we collect, how we use it, and under

what circumstances, if any, we disclose it.

15. Complaint and contact details

15.1. If you have a concern about any aspect of our privacy practices, you

can submit a complaint via email at compliance@amega.capital.

15.2. If you have any enquiries regarding this Privacy Policy, please email us

at support@amega.capital or at dpo@amegafx.com