1.0 Introduction

1.1 The company referred to as “ Renovox” or “the Company” collects, maintains, uses, and discloses personal information of clients, as outlined in this privacy statement.

1.2 This privacy statement applies to the website www.renovox.com and its related mobile applications operated by the Company.

1.3 The Company abides by the provisions of the law and explains in its Privacy Policy (referred to as the “Policy”) how it collects, handles, uses, and shares personal information of clients.

1.4 This Policy applies to existing clients, potential clients, former clients, and website visitors (collectively referred to as “Clients” or “you”) who access or use the Company’s website and mobile applications (referred to as “Platforms”).

1.5 The Company is dedicated to safeguarding the privacy of Clients’ personal data, which it processes in accordance with this Policy and the Company’s Client Agreement.

1.6 In this Policy, “Personal Data” refers to information that identifies or can identify Clients, such as their name, address, identification number, telephone number, and date of birth.

 

2.0 Collection of Personal Data

2.1 The Company collects various types of Personal Data from Clients who visit its Platforms or access, use, or request its products and services.

2.2 Providing certain Personal Data is necessary to establish a contractual relationship with the Company. Clients who choose not to provide such Personal Data will be unable to open an account or receive other products and/or services from the Company.

2.3 Clients are responsible for ensuring the accuracy and currency of the Personal Data they provide to the Company, which is recorded in their personal account (Client Area) throughout their contractual relationship.

 

2.4. Along with the information provided by clients, the company also lawfully acquires and processes personal data from publicly accessible sources, including but not limited to the press, social media, and the internet. This is done to fulfill regulatory obligations and verify the accuracy of the provided information using third-party risk management software solutions.

 

2.5. The personal data received from clients, collected, and processed by the company are necessary for identifying, verifying, and evaluating clients, as well as communicating with them. Additionally, this data is used to establish a business relationship, ensure contract fulfillment, and comply with legal requirements. The specific types of personal data collected from clients may vary depending on the product or service provided by the company. These include:

 

1. a) Contact details, such as the client’s name, email address, and phone number.
2. b) Identification details, such as the client’s ID or passport number.
3. c) Biographical and demographic information, such as gender, age, ethnicity, education, occupation, financial trading experience, and whether the client holds a prominent public function status (PEP).
4. d) Financial information, including income status, bank account number and details, tax information, and other relevant financial data.
5. e) Information pertinent to the services offered by the company, such as the client’s transactions and communication records.
6. f) Details of website visitors and clients, collected through cookies and tracking technologies, including IP address, domain name, browser version, operating system, and geolocation.
7. g) Information related to criminal convictions and offenses, as required and permitted by applicable law.
8. h) Marketing preferences specified by the client.

 

3.0 No Collection of Children’s Data

3.1. The company recognizes the importance of safeguarding children’s privacy. Its services are not intended for individuals under the age of eighteen (18), nor is the company’s website designed for use by children. Consequently, the company does not knowingly or intentionally collect personal data from children. In the event that such data is mistakenly or unintentionally collected, the company will promptly delete the information as soon as it becomes aware of it. If a client becomes aware of any such data collection, they should notify the company at [email protected].

 

4.0 Utilization of Personal Data

4.1 The Company gathers and processes Personal Data that are necessary for evaluating, establishing, and maintaining the contractual relationship between the Company and the Client, as well as for complying with the Policy and relevant laws and regulations governing the provision of financial services. In certain cases, the Company may also process the Client’s Personal Data to pursue its own legitimate interests or those of third parties, ensuring that the interests and fundamental rights of the Clients are not overridden.

4.2 Specifically, the Client’s Personal Data will typically be utilized in the following circumstances:

1. a) When the Company needs to fulfill the contract it has entered into with the Client or to take specific steps prior to entering into a contract with the Client. Processing is necessary for the Company to provide the Client with its products and services, including:

 

Verifying the Client’s identity and conducting any necessary credit checks.

Ensuring the Client meets the suitability requirements for using the Company’s products and services.

Managing the Client’s account with the Company.

Processing the Client’s transactions.

Sending the Client information about transactions or post-transaction services.

If the Client does not provide the requested Personal Data, the Company may be unable to offer its products and/or services to the Client.

1. b) When the Company needs to comply with a legal obligation.

As an investment firm, the Company must adhere to specific legal and regulatory obligations that may involve the processing of Personal Data. These obligations require the Company to carry out necessary data processing activities for identity verification, compliance with court orders, tax laws, reporting obligations, and anti-money laundering controls.

1. c) When the Company has legitimate interests in utilizing the Client’s Personal Data.

More specifically, the Company may process Personal Data for the following purposes:

Developing or enhancing its products and services.

Enhancing the security of the Company’s network and information systems.

Identifying, preventing, and investigating fraud, unlawful activities, unauthorized transactions, liabilities, and managing risk exposure.

Maintaining accounts and records.

Managing business operations and complying with internal policies and procedures.

Defending, investigating, or prosecuting legal claims.

Seeking professional advice (such as legal advice).

Analyzing statistical data to improve products and services for Clients in the future. It should be noted that the Company anonymizes and aggregates such data to prevent the direct or indirect revelation of Clients’ identities. The Company may provide this statistical data to third parties (as described in more detail in Section 6) solely for statistical purposes and to enhance the Company’s marketing campaign.

1. d) When the Client has given consent.

The Company will seek the Client’s consent when it intends to provide marketing information about its products or services that may be of interest to the Client.

The Client has the right to withdraw such consent at any time. This does not affect the legality of processing based on consent before its withdrawal.

 

5.0 Cookies

5.1 A cookie is a small text file that is stored on a user’s computer for the purpose of recording information.

The Company utilizes cookies on its website. However, the information stored in cookies is not linked to any Personal Data provided by the Client while accessing the Company’s website.

5.2 The Company employs both session ID cookies and persistent cookies. Session ID cookies do not expire when the Client closes their browser, but they can be removed by clearing the cache. Persistent cookies, on the other hand, remain on the Client’s hard drive for an extended period and can be deleted by following instructions in the Internet browser’s “help” file.

5.3 The Company sets persistent cookies for statistical purposes. These cookies also allow the Company to track and target the location and interests of its users, thereby enhancing the overall experience of its services on the Company’s website.

5.4 If the Client chooses to reject cookies, they can still use the Company’s website; however, they will not be able to utilize the Client Area or submit online application forms.

5.5 Some of the Company’s business partners also use cookies on the Company’s website. The Company has no access to or control over these cookies.

5.6 Analysis of Cookies

5.6.1 Third-Party Cookies

Third-party providers employ cookies on our website to facilitate tools and services for our visitors and clients, as well as to support our internal analytical and marketing activities. It should be noted that the Company is not liable for any misuse or loss of Personal Data resulting from cookies on the Company’s website that are not under its access or control.

5.7 The Client or visitor of the Company’s website acknowledges that they can manage and control the aforementioned cookies through the security and privacy settings of their web browser. For further information on cookies, as well as instructions on how to manage and delete them, please send an email to: [email protected].

 

6.0 Personal Data Sharing and Disclosure

6.1 During the fulfillment of the Company’s contractual and legal obligations, the Client’s Personal Data may be shared with third parties. These third parties typically enter into contractual agreements with the Company, ensuring compliance with data protection and confidentiality measures.

6.2 In the aforementioned circumstances, recipients of Personal Data may include:

1. a) Third-party payment service providers who assist the Company in offering secure deposit and withdrawal services to Clients.
2. b) Other service providers chosen by the Company to support the effective delivery of products and services, offering technological expertise, solutions, and support.
3. c) Governmental and regulatory bodies, including law enforcement authorities, in relation to inquiries, proceedings, or investigations, or to enable compliance with legal and regulatory requirements.
4. d) Credit reference and fraud prevention agencies, third-party authentication service providers, and financial institutions for purposes such as credit checks, fraud prevention, and anti-money laundering measures.
5. e) Third-party service providers facilitating customer support services through live chat and monitoring website visits and traffic through cookies.
6. f) External consultants, including legal and tax consultants.
7. g) Data reporting service providers.
8. h) Market research companies and call centers.
9. i) Partners of the Company.
10. j) Affiliates of the Company.

6.3 Customer card details are safeguarded using Transport Layer encryption (TLS 1.2) and application layer encryption with AES algorithm and a key length of 256 bits.

6.4 The Company does not collect, store, or process personal credit or debit card information. All payment transactions are processed through payment service providers.

 

7.0 Business Transfers and Legal Requirements

7.1 If the Company undergoes a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of services to another provider, the Client’s Personal Data and other information may be transferred to a successor or affiliate as part of that transaction, along with other assets.

8.0 Marketing Communications and Subscription Preferences

8.1 The Company may process Personal Data to inform Clients about products, services, and offers that may be of interest, but only with the explicit consent of the Client.

8.2 If the Client no longer wishes to receive promotional communications, they can opt-out by following the instructions provided in each communication or by updating their email subscription preferences within their Client account area.

 

9.0 Personal Data Rights

9.1 The rights pertaining to personal data for clients are as follows:

1. a) Right of access: Clients have the right to know whether the Company is processing their personal data and, if so, to receive a copy of that data.
2. b) Right to rectification: Clients have the right to request corrections or completion of their personal data if it is inaccurate or incomplete.
3. c) Right to erasure: Clients can ask the Company to erase or remove their personal data under certain circumstances, such as withdrawing consent.
4. d) Right to restrict processing: Clients can ask the Company to limit the processing of their personal data if it is inaccurate, unlawfully used but not to be deleted, no longer relevant but required for legal claims, or if they are awaiting confirmation of legitimate grounds for its use.
5. e) Right to data portability: Clients have the right to receive their personal data provided to the Company in a structured, commonly used, and machine-readable format.
6. f) Right to object: Clients can request the Company to stop processing their personal data if the Company cannot demonstrate compelling legitimate grounds for processing based on a legitimate interest, or if the data is being processed for direct marketing.
7. g) Rights in relation to automated decision-making and profiling: Clients have the right not to be subject to decisions based solely on automated processing of their personal data, including profiling, unless necessary for a contract or explicit consent is given.
8. h) Right to withdraw consent: Clients have the right to withdraw their consent for the processing of their personal data, without affecting the lawfulness of prior processing.
9. i) Right to lodge a complaint with the data protection authority: Clients can report concerns about the Company’s privacy practices and handling of their personal data to the relevant data protection authority.

 

To exercise any of the above rights, clients can contact the Company at [email protected].

 

10.0 Automated decision-making and profiling

10.1 When clients apply for account opening, the Company may use automated systems to assess their knowledge and experience through an appropriateness test. In such cases, clients have the right to request information about the processing of their personal data and challenge any automated decisions reached. The Company will reassess the application, taking into account both the reasons for the automated decision and the client’s perspective.

11.0 Confidentiality and Security of Personal Data

11.1 The Company treats personal data as confidential and will only use it for the purposes specified in this Policy.

11.2 Personal data provided by clients is confidential and shared only with the parties mentioned in Section 6 of this Policy.

11.3 Personal data will not be disclosed to any other third party unless required by regulatory or legal proceedings.

11.4 Registration Information, which includes personal data provided during website registration or for the Services, is highly protected by the Company. Clients can access their Registration Information through an encrypted password known only to them. The Company takes precautions to prevent unauthorized access to this information.

11.5 Personal data other than Registration Information is stored securely on servers accessible only to authorized personnel. Clients do not have access to this information, and no password is provided for viewing or modifying it.

 

12.0 Amendments to this Policy

12.1 The Company reserves the right to review and modify this Policy as needed, notifying clients of any changes by posting an updated version on the Company’s website or through direct communication.

12.2 Clients are responsible for regularly reviewing the Policy and any amendments.

 

13.0 Enquiries and Contact Details

13.1 For inquiries regarding personal data rights outlined in Section 9 of this Policy or questions about the Company’s processing of clients’ personal data, please contact [email protected].