Privacy and Policy

Administration of Personal Data

Tradefd is committed to ensuring the privacy of non-public information and personal data provided by all clients of the company as well as all visitors to and users of the website www.tradefd.com (the website).

Please read the following Privacy and Personal Data Protection Policy (the Policy) to understand how Tradefd collects, uses, discloses, and protects the non-public information and personal data provided by you.

Tradefd will only use the non-public information and personal data it gathers in accordance with this Policy and the relevant regulation.

Data Protection Officer contact details:

You can contact our Data Protection Officer directly here:

Email: [email protected]

Collection of Information

If a prospective client decides to open an account with Tradefd, there is certain information that will be required from them. This information includes, but is not limited to, personal data such as name, address, date and place of birth, phone number and other contact details, passport details, citizenship and tax status information, employment details, as well as other necessary financial information. The purpose for the collection of this information is to identify the prospective client and to assess whether the service requested by them is appropriate, before entering into an agreement.

Occasionally, Tradefd may request further information which will, on one hand, help improve the services it provides, and, on the other, is necessary in order to fulfill the regulatory duty to maintain the data through which it individualises a website user as its client in current form and volume.

Tradefd collects information from the following direct sources:

online application form for opening an account for trading in financial instruments;
documents necessary for opening an account for trading in financial instruments;
transactions made online related to the services offered by Tradefd;
Declaration for the purposes of the automatic exchange of financial information pursuant to Art. 142t, para. 1 of the Bulgarian Tax and Social Security Procedure Code (TSSPC);
Declaration of the origin of client funds under Art. 66, para. 2 of the Measures against Money Laundering Act (MAMLA);
email and chat correspondence as well as telephone communication to and from Tradefd;
visits to Tradefd website;
Internet Protocol (IP) address;
browser type;
operating system;
Internet Service Provider (ISP);
banner ads viewed, etc.

Tradefd collects information indirectly through the use of cookies, which are addressed below in this Policy.

To ensure the security of information transfer, Tradefd uses an SSL certificate to encrypt information transmitted by or to the visitor through the website.

Special categories of data we process

In order to fulfill its obligations under MAMLA, Tradefd collects and processes information that may be considered to some extent as information about your political views (representing a special category of personal data under Regulation 2016/679). This personal data is collected on the basis of a legal obligation and therefore its processing by Tradefd is lawful.

Use of Information and Purposes of Processing Personal Data

Tradefd uses the non-public personal information containing personal data collected from clients in order to establish and service clients’ accounts for trading in financial instruments.

Tradefd will use the data collected from the client to establish their identity in accordance with the applicable law, as well as to enter into an agreement with the client for providing the services offered by the company. The data gathered will also be used to classify the client as professional or retail client – and with regard to this, to provide them with the legally established set of documents and other information, as well as to determine the client’s tax status for the purposes of the automatic exchange of financial information in the field of taxation.

Unless the client is informed otherwise, the non-public information and personal data that Tradefd holds and processes is also used for:

reviewing the client’s ongoing needs;
AML (anti-money laundering) and fraud prevention;
enhancing customer service and products;
providing ongoing information or opportunities that Tradefd believes may be of interest to the client.

The grounds that entitle us to process client data are:

Processing is necessary in order to comply with our legal obligation arising from the following legal acts:

Measures against Money Laundering Act (MAMLA); Rules for Implementing of MAMLA (RIMAMLA); Measures against the Financing of Terrorism Act (MAFTA); Public Offering of Securities Act (POSA); Markets in Financial Instruments Act (MiFIA); Ordinance No. 38 of 25.07.2007 on the requirements to the activities of investment intermediaries (Ordinance № 38); and other.

Disclosure of Information

Tradefd does not disclose clients’ non-public information and personal data to any non-affiliated third parties or to affiliated entities, except as permitted by applicable law.

Depending on the product or service concerned and particular restrictions on confidential information, personal client data and information may be disclosed to:

service providers and specialist advisers who have been contracted to provide Tradefd with administrative, financial, legal, research, or other services;
courts and regulatory authorities, in accordance with or as prescribed by law;
anyone authorised by the client, as specified by that individual or the contract.

Access to Information

Any client, after submitting a written request, is entitled to access the personal data collected about them by Tradefd. In the cases where the right of access granted to an individual may also lead to disclosure of personal data of third parties, Tradefd is obligated to provide to the relevant client access only to the part of the data referring solely to them. When exercising their right of access, any client of Tradefd is entitled to request at any time:

a confirmation as to whether or not data relating to them is being processed, information as to the purposes of such processing, the categories of data concerned, and the recipients or categories of recipients to whom the data is disclosed;
a notification to the client, in an intelligible form, containing their personal data which is being processed, as well as any available information about their source;
information concerning the logic involved in any automated processing of personal data.

Any client is entitled to require, at any time, from Tradefd to:

erase, rectify or block their personal data whose processing does not comply with the legal requirements;
notify any third parties to whom their personal data has been disclosed of any erasure, rectification, or blocking carried out in compliance with the previous item, unless this is impossible or involves a disproportionate effort.

At any time while Tradefd stores or processes their personal data, the client is entitled to:

request a copy of their personal data from Tradefd, as well as a right to access their personal data at any time;
request from Tradefd their personal data in a form convenient for transfer to another administrator of personal data or request that Tradefd does so without being impeded;
request from Tradefd to correct, without unnecessary delay, inaccurate personal data as well as data that is no longer up to date;

The client has the right to request that Tradefd delete the personal data without undue delay in the presence of any of the following circumstances:

the personal data is no longer needed for the purposes it was collected for;
when they have withdrawn their consent and the processing of data is based solely on this;
when they have objected to the processing and Tradefd has no legal basis for continuing to process and / or store the data;
when the processing is unlawful;
when the personal data must be deleted in order to comply with a legal obligation under EU law or the law of the Member State which that applies to Tradefd as an administrator of personal data;
when the personal data has been gathered in connection with the provision of services to the information society.

Tradefd may refuse to delete a client’s personal data due any of the following reasons:

when exercising the right to freedom of expression and the right to information;
to comply with a legal obligation on behalf of Tradefd or to carry out a task of public interest;
due to public interest reasons in the field of public health;
for the purposes of archiving in the public interest, for scientific or historical research or for statistical purposes,as far as erasure is likely to make it impossible or seriously hinder the achievement of the purposes of such processing; or for the establishment, exercise or protection of legal claims.

The client may request that Tradefd restricts the processing of personal data, in which case the data will only be stored but not processed. The denial of restriction will explicitly be only in writing, and Tradefd is obliged to motivate the refusal with a legitimate reason;

the client has the right to withdraw their consent for processing of the personal data at any time, by submitting a separate request to the administrator;
the client may object to certain types of processing, such as direct marketing (unsolicited advertising messages);
the client has the right to object to the automated processing, including profiling;
the right not to be the subject of a decision based solely on automated processing involving profiling;

In the event that Tradefd needs to use the personal data for a new purpose, Tradefd will provide a new data protection notice and when and where necessary, it will require a prior consent for the new processing.

If the client wishes to exercise any of the rights listed above, they should inform the company in writing. In that case, Tradefd may not be able to provide them with information about services and/or products requested by them, and also the products and services themselves; and with regard to this, Tradefd will have no liability to the client in respect of the same.

Updating or Deleting Client Data

The client should inform Tradefd in a timely manner that their personal data has changed by providing their up-to-date data through the MyAccount section on Tradefd website.

The client should inform Tradefd if they wish their personal data to be deleted by sending an email to [email protected].

Tradefd will change or delete a client’s personal data in accordance with their instructions, except to the extent, terms and manner that Tradefd is required to hold clients’ personal data for regulatory or legal purposes, in order to provide the client with the services they have requested, or due to the fact that it has provided the services during a past period, and must now maintain certain information until a certain regulatory deadline.

Protection of Information

Clients’ non-public information and personal data are kept in a secure and strictly confidential manner; thay are accessed and used only by employees who service the client’s account, as well as by employees who exercise controlling functions.

Tradefd uses advanced security software and technology to ensure a safe and secure trading environment and to protect clients’ non-public personal, financial and trading information.

Tradefd encrypts all client personal data in order to be able to protect this data to the fullest extent possible.

Opt-out Procedure

It is Tradefd policy not to disclose non-public client information to third parties, except in legally defined cases.

The client has no obligation to provide any part of their non-public information or personal data that may be requested by Tradefd

The client’s refusal to provide the information or personal data requested by Tradefd may result in Tradefd inability to open or maintain the client’s account for trading in financial instruments, or to provide financial services to them.

Amendments to the Privacy and Data Protection Policy

Any changes to this Policy will be published promptly on Tradefd website and will serve as notification to clients.

Consent

By agreeing to accept this Privacy Policy, the clients’ grants permission to Tradefd to process their personal data only for the stated purposes.

The consent is necessary for Tradefd in order to process both types of personal data (ordinary and special), but it needs to be explicit.

In the cases where Tradefd requests a consent for special (sensitive) personal data, it will always be reasoned why and how this information will be used.

The client may withdraw its consent by a written request to Tradefd at any time.

Law and Jurisdiction

This Policy shall be governed by and construed in accordance with the laws of the Republic of Bulgaria, and any disputes relating to this Policy shall be resolved between the parties themselves, and in case of failure to do so, they shall be subject to the jurisdiction of the courts of the Republic of Bulgaria.