Privacy policy relating to the processing of personal data as part of the GMT service

The data controller is Union of Financial Corners (Switzerland) SA, located at Rue de Mont-Blanc 11, 1201 Geneva, Switzerland (hereinafter "UFC" or "we"). The confidentiality of your Personal Data is essential. We will process your Personal Data in accordance with the Federal Data Protection Act of 25 September 2020 (hereinafter "DPA") and its implementing regulations and ordinances.

The term "Personal Data" refers to all information concerning an identified or identifiable natural person. Processing" refers to any operation relating to Personal Data, whatever the means and procedures used, in particular the collection, recording, storage, use, modification, communication, archiving, deletion or destruction of data.

The term "User" or "you" refers to any person who creates a User Account and uses our Platform and its services. In accordance with the DPA, you are considered a "Data Subject" if you are an identifiable natural person, directly or indirectly, whose Personal Data is processed when using the Platform. All natural persons creating a User Account are automatically considered as Data Subjects. On the other hand, legal entities, such as companies, are not considered as Data Subjects, and their data is not processed as Personal Data.

This Privacy Policy (hereinafter referred to as the "Policy") explains in simplified terms how your personal data will be processed when using the GMTPlatform (hereinafter referred to as the "Platform").

Types of personal data collected and processing principles

The personal data that we collect and process to open a User Account are the surname, first name, postal address, e-mail address and telephone number.

The collection and processing of your Personal Data when you open a User Account is based on the performance of the contract between us under the Platform Terms of Use. This data will be processed in order to make it possible to use the Platform and provide the associated services.

We may communicate with you about the Platform and its services, including for marketing purposes and to conduct surveys. The purpose of our communications will be to provide you with information about our services or other services offered by our Affiliates. Communications about other services, including for marketing and survey purposes, are based on our legitimate interest in conducting our business. Our legitimate interest also justifies the transfer of your Personal Data to our Affiliates. This transfer aims to process this data in order to improve our services, and is also used for statistical, research and development purposes. It also contributes to the protection and defence of our rights, property and safety, as well as those of our customers and other Users of the Platform.

The processing of your data to send you commercial information about our Partners' offers and products is based on your consent, which you give by agreeing to open a User Account. You may withdraw this consent at any time. If you withdraw your consent, we may retain certain data (such as your email address) to record and respect your choice to no longer receive commercial communications about our Partners' services. We will not transfer your Personal Data to third parties or to our Partners without your explicit consent.

We may use your Personal Data to communicate with you after you have unsubscribed from the Platform and until such time as you object to the sending of such messages. You will have the opportunity to object to this processing before unsubscribing.

We may process the Personal Data collected for any other purpose compatible with the purposes set out above. For example, we may use Personal Data for archiving and statistical purposes relating mainly to the use of services.

In addition, we may process the Personal Data collected in order to ensure the compliance of our activities with the regulations in force in Switzerland, in particular the laws and regulations relating to the fight against money laundering.

You may provide personal data when using other services or when contacting us, for example our newsletter. These databases are managed independently, so unsubscribing from the Platform will not automatically apply to these other services. Please take the time to indicate your consent or opposition to the processing of your data for each service.

The Platform is not intended for use by persons under the age of 16. If you are under 16 years of age, you must obtain your parent's or legal guardian's permission before providing us with your Personal Information, accepting this Privacy Policy and using the Platform.

Retention period

We will only retain Personal Data for as long as is necessary for the purposes described in the section above "Types of Personal Data collected and Processing principles". We may retain Personal Data collected after you have unsubscribed where you have given your consent or to the extent necessary to achieve a purpose consistent with the above purposes. More specifically:

The Personal Data collected when using the Platform is used to manage our contractual relationship and to provide you with access to the Platform's features and services. This data includes your surname, first name, physical address, e-mail address and telephone number. Your Personal Data will be deleted once you unsubscribe, unless you give us permission to use it for marketing communications. In this case, we and our Affiliates will continue to use this data to communicate with you, even after you unsubscribe from the Platform.

Personal Data processed for the purpose of sending you commercial communications regarding offers from our Partners will be retained until you withdraw your consent. Certain data, such as your e-mail address, may be saved in order to respect your choice not to receive such communications.

Personal Data collected in order to ensure the compliance of our activities with the regulations in force in Switzerland, in particular those relating to the fight against money laundering, will be kept for up to ten years after the termination of the business relationship or after the conclusion of the transaction.

Personal Data that you transmit by e-mail, via a contact form or by post will be kept for the time necessary to respond to your requests, depending on the nature of the request.

Third-party access to data

Third-party providers of IT services may have access to some of your personal data. These service providers mainly assist us with the maintenance and support of our IT systems, the hosting of databases or the distribution of marketing communications. These databases are stored on servers located in Switzerland.

We may need to disclose and/or transfer your Personal Data if required to do so by applicable law, to comply with legal process, a court order, a legal obligation, or as part of an investigation by a public or judicial authority, or to protect and defend our rights.

Transmission outside Switzerland and the EEA

Personal Data is hosted on servers located in Switzerland. It will not be transferred outside Switzerland.

Your rights regarding your personal data

You have the following rights concerning your personal data:

Right of access: on request and subject to the conditions and limits determined by applicable law, we will provide you with a copy of the Personal Data we hold about you.

Right of rectification/deletion: upon request, we will rectify or delete any of your Personal Data that is inaccurate or incomplete. We recommend that you regularly update your Personal Data registered on the Platform.

Right to object to processing: on request and subject to conditions and limits determined by applicable law, we will restrict/limit the processing of your personal data or delete your data.

Right to withdraw consent: you have the right to withdraw any consent given for the processing of your Personal Data at any time. Processing carried out prior to your withdrawal remains lawful.
We encourage you to contact us with any questions or requests relating to the above rights at : support@mybestfx.ch. We will contact you as soon as possible.

Changes

We reserve the right to amend this Privacy Policy at any time in order to adapt it to technical or legal developments or when new features and services are introduced. The applicable Privacy Policy is the one in force at the date of connection to and use of the Platform by the User.