- Introduction
By accessing or using VistaMX Markets Limited's (hereinafter also referred to as "we", "us" and "our" or the "Company") Services and/or Products, you agree to the policies and practices contained in this Privacy Policy (the "Privacy Policy") and represent and warrant that you have obtained valid consent and authorization from Relevant Persons (as defined below) to consent to and authorize us to collect, use, disclose and/or process your personal data in accordance with this Privacy Policy. This Privacy Policy explains how we collect, use and disclose your personal data when you access or use our Services/Products. You agree that the Company may update this Privacy Policy at any time by posting an amended version on our website and related application program interfaces or mobile applications or by sending you the latest version of the Privacy Policy by email. Your use or continued use of any of our Services/Products after the revision of this Privacy Policy shall be deemed as your acceptance of and agreement to such revision.
- What Personal Data We Collect
When you use our Services/Products or with your consent, we may from time to time collect, process and store certain personally identifiable information ("Personal Data") that can be used to contact or identify you and your beneficial owners, directors, officers, authorized signatories, employees, representatives, guarantors/security providers and other natural persons related to you. Such Personal Data may include contact information, information and data generated in the course of your normal interactions with us, information and data we collect when you or Relevant Persons participate in activities organized by us, and cookie information or information generated from the use of information technology applications. During the client onboarding process, the Personal Data you may provide to us may also include but is not limited to:
- Legal name
- Type of identification document (e.g., passport)
- Identification document number (e.g., passport number)
- Gender
- Date of birth
- Place of birth
- Nationality
- Residential address
- Country/region of residence
- Total net wealth
- Purpose of opening an account
- Initial and ongoing sources of wealth or income
- Nature and details of business/occupation/employment
- Expected level of activity
- Source of funds/digital assets used for trading
- Contact phone number
- Email address
- Bank account information
- Customer services data
- IP address
- Other personal data or documents for providing services for you
- How We Use Your Personal Data
We may use the Personal Data we collect for the following purposes:
- To contact you regarding your account, including marketing;
- To facilitate your use of the Services;
- To verify your identity in accordance with legal obligations;
- To facilitate payments to and from your account;
- To facilitate the relevant activity and associated rewards;
- To facilitate ad attribution as part of our marketing campaigns;
- To facilitate analytics and develop, monitor and improve our products and services;
- To determine your approximate location;
- To monitor the integrity of the Services to ensure the provision of the Services is secure and lawful;
- To ensure the integrity and consistent operation of the Services;
- To protect our Services against cyberattacks, criminal activity, identity theft, or investigation of suspicious activity;
- To comply with our legal obligations, including as part of conducting routine audits of our Services;
- To enforce our terms and policies;
- To protect our users and clients;
- To determine the effectiveness of features and campaigns;
- To facilitate your trades and provide you with a historical log of such actions;
- To respond to your support request;
- For security and verification purposes.
- Who We Share Your Personal Data With
We may disclose your Personal Data to the following persons:
- Our third-party service providers (including any "Know Your Customer" or other analytics service providers, and service providers providing website hosting, data analysis, information technology, mailing, communications, human resources, data processing, payment, credit reference or other services);
- Any individual or entity within the Company and its affiliates who owes a duty of confidentiality to the disclosing entity;
- Any person to whom we are obligated or otherwise required to disclose pursuant to legal process or pursuant to any domestic or foreign legal, tax and/or regulatory obligations or requirements;
- Any actual or proposed assignee or business transferee of the Company and/or its affiliates.
We may also disclose aggregated or anonymized Personal Data to the above persons to help them manage, operate, deliver and improve our Services/Products.
- How We Transfer Your Personal Data
Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Please note that we may transfer data, including Personal Data, to a location outside your jurisdiction for processing. Your consent to this Privacy Policy and submission of such information constitutes your consent to such transfer.
We will take reasonable steps to ensure that your Personal Data is treated securely in accordance with this Agreement and that your Personal Data will not be transferred to an organization or country that has not established adequate controls, including security measures for your Personal Data and other personal information.
- How We Store Your Personal Data
The Personal Data we collect from you may be transferred to and stored at a destination in Singapore or outside of your state, province, country or other jurisdiction. By submitting your Personal Data, you consent to such transfer, storage or processing. Information you provide to us may also be stored on our and/or third-party cloud servers.
- How Long Do We Retain Your Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies. By accessing/using our Services/Products, you consent to our retention of your Personal Data.
- Legal Basis for Processing Personal Data
If you are a resident of the European Economic Area ("EEA"), the legal basis for our collection and use of the Personal Data described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. We may process your Personal Data for the following reasons:
- We need to use your Personal Data to enter into a contract with you or to perform our obligations under a contract;
- You have consented to our processing of your Personal Data;
- Processing your Personal Data is in our legitimate interests or is necessary to perform our legal obligations;
- To comply with applicable laws and regulations;
- If you are an EEA resident, you have certain data protection rights. We strive to take reasonable steps to enable you to correct, amend or delete your Personal Data or restrict the use of your Personal Data. Please see Section 15 below (Contacting Us About Privacy Questions or Concerns).
In certain circumstances, you have the following data protection rights:
- You have the right to access, update or delete the information we hold about you.
- Right of rectification. You have the right to have your information rectified if it is inaccurate or incomplete.
- Right to object. You have the right to object to our processing of your Personal Data.
- Right of restriction. You have the right to request that we restrict the processing of your Personal Data.
- Right to data portability. You have the right to obtain a copy of the information we hold about you.
- Right to withdraw consent. Where we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time.
- Marketing Communications
We may send company news, promotional advertisements and information related to our products and services. We may also share your Personal Data with our affiliates so that they can send marketing communications. By using our Services/Products, you accept this Privacy Policy and agree to receive such marketing communications, unless you choose not to receive such marketing communications during the client onboarding process.
If you have previously chosen to receive such communications but have changed your mind and no longer wish to receive them, please email us to opt-out.
To ensure the quality of our Services/Products, you understand that you will not be able to opt out of receiving communications related to Services/Products, such as revisions to terms and conditions, updates and operational notices.
- Cookie Usage
When you visit our Site, we may, in accordance with industry practice, place a small amount of data in your browser (a "Cookie"). Such information may be placed on your computer or other device used to access our Site. Such information helps us identify your customer identity, collect information about your use of our Services/Products, better personalize our services and improve your experience. We may also use the information we collect to ensure compliance with our compliance program and to ensure that your account security is not compromised by detecting unusual or suspicious account activity.
Most browsers are set to automatically accept Cookies. When you complete a session, some Cookies expire, while others remain on your computer or other device until deleted or expired. You may choose to refuse our Cookies, but this may affect the functionality of our Services/Products or your user experience.
Some browsers have a do-not-track feature that allows you to tell websites that you do not want your online activities to be tracked. At the moment, we do not respond to browser do-not-track signals.
- Links to Other Sites
Our website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's website. We strongly recommend that you review the privacy policy of each website you visit. You understand that we have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.
- Minor Policy
We do not provide Services/Products to minors under the age of 18. We do not knowingly or intentionally collect personally identifiable information from minors under the age of 18. If you are a parent or guardian and you know that your child has provided us with Personal Data, please contact us and we will take appropriate action.
- Contac Us
If you have any questions about this Privacy Policy or the use of your Personal Data, please send an email to ops@vistamx.net
To respond to data access, modification, deletion or data portability requests, we will verify the identity of the requester to ensure that they are legally entitled to make such requests. While we respond to such requests free of charge, in some cases (especially when you make multiple requests or when the content of your request is onerous or complex), we reserve the right to charge you a reasonable fee.
- Language
Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.
