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 Data protection notice 
=======================

**Data Protection Policy relating to the processing of personal data in connection with the MyBestFX Platform 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 protection of your Personal Data is essential. We will process your Personal Data in accordance with the Federal Act on Data Protection of 25 September 2020 (hereinafter « **FADP** ») and its implementing regulations and ordinances.

The term « **Personal Data** » means all information relating to an identified or identifiable natural person. The term « **Processing** » means any operation relating to Personal Data, regardless of the means and procedures used, including the collection, recording, storage, use, modification, disclosure, 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 FADP, 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 Data Subjects. Legal entities, such as companies, are not considered Data Subjects; data relating to them, such as their company name, addresses or generic email addresses, does not constitute Personal Data and is not processed as such.

This Data Protection Policy (hereinafter « **Policy** ») explains in a simplified manner how your Personal Data will be processed when using the MyBestFX Platform (hereinafter « **Platform** »). Terms used in this Policy that are not defined below have the meaning assigned to them in the Platform Terms of Use.

Types of Personal Data collected and Processing principles
----------------------------------------------------------

The Personal Data that we collect and process for registration and for opening a User Account consists of surname, first name, email address and telephone number. This registration allows you to use the Online Exchange service as well as the Fix &amp; Collect service.

The collection and processing of your Personal Data when opening 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 the use of the Platform and the provision of the related services possible.

The Personal Data that we collect and process to complete the User profile after registration is as follows: date of birth, nationality, address, profession, estimate of annual income and of the amounts that will be exchanged through the Platform, purpose of the transactions and origin of funds, identity documents and other information necessary to ensure our compliance with anti-money laundering regulations. The completed profile allows you to use the Online Exchange service.

The collection and processing of your Personal Data to complete the User profile is based on our legal and regulatory obligations, in particular those relating to the fight against money laundering and terrorist financing (AML regulations). This data will be processed in order to allow the use of the Platform and the provision of the Online Exchange service.

We may communicate with you regarding the Platform and its services, including for marketing purposes and to conduct surveys. The purpose of our communications is to provide you with information about our services or about other services offered by our affiliated companies. Communications concerning other services, including for marketing and survey purposes, are based on our legitimate interest in conducting our business activities. Our legitimate interest also justifies the transfer of your Personal Data to our affiliated companies. This transfer is intended to process such data for the purpose of improving our services and also serves statistical, research and development purposes. It also contributes to the protection and defence of our rights, property and security, as well as those of our customers and other Users of the Platform.

The processing of your data to send you commercial information about the offers and products of our Partners 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, in order to record and respect your choice not to 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 unsubscribe from the Platform and until you object to receiving such messages. You will have the opportunity to object to this processing before unsubscribing.

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

In addition, we may process the collected Personal Data in order to ensure that our activities comply with the regulations in force in Switzerland, in particular laws and regulations relating to the fight against money laundering and terrorist financing (AML regulations).

You may provide Personal Data when using other services or when contacting us, for example through our newsletter. These databases are managed independently; therefore, unsubscribing from the Platform will not automatically apply to these other services. We kindly ask you to take the time to indicate your consent or objection to the processing of your data for each service.

The Platform is not intended for persons under the age of 16. If you are under 16 years old, you must obtain the permission of your parents or the holder of parental authority before providing us with your Personal Data and using the Platform.

Retention period
----------------

We will retain Personal Data only for as long as necessary in light of the purposes described in the section above « **Types of Personal Data collected and Processing principles** ». We may retain the collected Personal Data after you unsubscribe where you have given your consent or to the extent necessary to achieve a purpose compatible with the purposes mentioned above.

More specifically:

- The Personal Data collected in connection with the use of the Platform is used to manage our contractual relationship and to provide you with access to the Platform’s features and services. Your Personal Data will be deleted following your unsubscription, unless you authorise us to use it for marketing communications. In that case, we and our affiliated companies will continue to use this data to communicate with you, even after your unsubscription from the Platform. Personal Data will also be deleted if no transaction has been carried out on the Platform within six months following registration. After this period, access to the Platform services requires a new registration.
- The Personal Data processed for the purpose of sending you commercial communications regarding our Partners’ offers will be retained until you withdraw your consent. Certain data, such as your email address, may be stored in order to respect your choice not to receive such communications anymore.
- The Personal Data collected for the purpose of ensuring compliance of our activities with the regulations in force in Switzerland, in particular those relating to the fight against money laundering, will be retained for up to ten years after the end of the business relationship or after the completion of the transaction.
- The Personal Data that you transmit by email, through a contact form, or by post will be retained for the time necessary to respond to your requests, depending on their nature.

Third-party access to data
--------------------------

Third-party providers of IT services may access some of your Personal Data. These providers mainly assist us with the maintenance and support of our IT systems, database hosting or the distribution of marketing communications. These databases are backed up on servers located in Switzerland.

We may be required to disclose and/or transfer your Personal Data where required by applicable law, to comply with legal proceedings, a court decision, a legal obligation, or as part of an investigation conducted by a public or judicial authority, or to protect and defend our rights.

Transfer 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 regarding your Personal Data:

- **Right of access**: upon 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 to rectification/deletion**: upon request, we will rectify or delete 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**: upon request and subject to the 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 at any time to withdraw any consent given for the processing of your Personal Data. Processing carried out before your withdrawal remains lawful. We encourage you to contact us for any questions or requests relating to the rights mentioned above at: support@mybestfx.ch. We will contact you as soon as possible.

Changes
-------

We reserve the right to amend this Data Protection Policy at any time in order to adapt it to technical or legal developments or when introducing new features and services. The applicable Data Protection Policy is the one in force on the date the User connects to and uses the Platform.

 

 

 

 

 

 

 

 

              

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