At MintBroker International (“MBI”), we take your privacy very seriously.

 

This policy has been updated to adhere to the new GDPR regulation that comes into action 25 May 2018. This new law is built around the principles of transparency and control, something SureTrader feels very strongly about. Your trust is important to us, so keeping your personal information safe and secure remains our top priority.

 

This website is provided by MBI. When visiting this website and in the course of providing services to you, MBI (“we”, “us” or “our”) may collect personal information about you (“personal data”) either (i) directly when you are asked to provide data (e.g., name, e-mail address and mailing address) or when you email, phone or otherwise contact us; or (ii) indirectly, e.g. via cookies and other technical means to monitor your use of the portal such as access logs, your internet protocol address or profiling to tailor the website to your preferences or to track your use of certain pages of the website, or from third parties who provide us with information about you.

“You” or “your”, in this privacy statement, means you as an individual, rather than any legal entity (such as your employer) which you may represent when you order a service from us via this website.

We ask that you read this Privacy Policy carefully as it contains important information about what to expect when MintBroker International collects personal information about you and how we use your personal data.

  • Information we collect about you
  • Why we collect your information
  • Who we share information with
  • Personal information storage and transfers
  • How long we retain your Personal Information
  • Personal Information covered by GDPR
  • Updates to our Privacy Policy

Information we collect:

MBI collects and processes Personal Information from you. This may include, among other things, information:

  • provided during the account opening process or during use of any of MBI website applications (for example, your name, email address, telephone number, birth date, investment objectives, trading summary to determine if you are a professional or retail client, documents such as your photo ID and your address information, which is your full residential address, including proof; a colour copy of a recent utility bill or bank statement.
  • acquired as a result of the transactions you conduct through MBI systems or in connection with services offered by MBI (for example, if you sign up for the SureTrader Prepaid Mastercard Card or if a deposit is made using a credit card, ask you to provide us with a copy of your credit card showing only the last 4 digits, full name on the card and expiration for verification of ownership of funds/card);
  • collected through Internet cookies (for further information on our use of cookies, please see our Cookie Policy).

 

Why we collect your information:

As a licensed and regulated firm, we are required by law to conduct due diligence and determine suitability by confirming your identity and your address before opening your account. Reasons we collect your information is as follows:

  • To provide you with brokerage and other services available on our platforms, and/or to handle any requests or inquiries you may have;
  • To pursue legitimate interests, including to carry out, monitor and analyze our business or operations;
  • To conduct monitoring by us or any other person on our behalf using various methods, including: (i) the use of automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (iv) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioural patterns, interactions or preferences for analysis (including predictive analysis); and/or (v) using other similar monitoring technology that may become available from time to time;
  • To comply with applicable laws or regulations in our jurisdiction;
  • For any other purpose for which your Personal Information was provided to us.
  • To personalize user profiles with MBI in order to foster better communication with our customers (for example through web analytics and newsletter tracking).

With regard to marketing-related communication, we will only provide you with such information after you have opted in and we will also provide you with the opportunity to opt out at any time if you do not wish to receive further marketing-related communication from us. If you decide to opt-out of marketing-related communications, we may not be able to provide certain features of our Services to you.

Depending on which of the following reasons above, we may process your Personal Information for the following legal reasons:

  • To comply with our legal obligations (for example, reporting to the regulator; Securities Commission of the Bahamas);
  • Because processing is necessary for the purposes of our legitimate interest or those of any third-party recipients that receive your Personal Information, provided that such interests are not taken over by your own interests or fundamental rights.

In addition, the processing may be based on your consent where you have expressly given that to us.

Who we share information with:

We may share your Personal Information in the following circumstances:

  • We share your Personal Information between the MBI subsidiaries and related-entities on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, banking, custody and other business purposes.
  • We may instruct service providers within or outside of MBI, domestically or abroad, to process Personal Information for approved purposes on our behalf and in accordance with our instructions. For example, you will be subscribed to use the trading platform technology and market data, which is provided by a third-party provider. We may disclose such information to the service provider as necessary for them to provide the services that you have requested. MBI requires these service providers to enter into confidentiality agreements with MBI that limit their use of the information that they receive. Such agreements prohibit the service provider from using MBI customer information that they receive other than to carry out the purposes for which the information was disclosed. MBI retains control over your Personal Information and uses appropriate safeguards to ensure the integrity and security of your Personal Information when engaging the service provider.
  • We may share your Personal Information with verified global databases and credit reference agencies so that we can perform identity, money laundering and fraud prevention checks, including financial institutions and regulatory bodies.
  • Consistent with applicable law, we may share your Personal Information with law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;

Otherwise, we will only disclose your Personal Information when you direct us or give us permission to do so when we are allowed or required by applicable law or regulations or any official or judicial request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

Personal information storage and transfers:

This data is stored securely in The Bahamas.

For Personal Information subject to the General Data Protection Regulation (EU) (“GDPR”) we may transfer your Personal Information outside The Bahamas as described above. This may include countries that do not provide the same level of protection as the laws of your home country (for example, the laws within the EEA or the United States). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards if required by the GDPR or other relevant laws. You may email us at [email protected] at any time if you would like further information on such safeguards.

How long we retain your Personal Information:

Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Under the Securities Commission of the Bahamas regulation, client information is required to remain on file for a minimum period of 5 years. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations and proceedings. Only after the minimum period is met, can personal information be deleted.

Personal information covered by GDPR:

With respect to EEA residents, you have a number of legal rights under GDPR in relation to the Personal Information that we hold about you. These rights include:

  • Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you.
  • Requesting that we update your personal information if it is inaccurate or incomplete;
  • Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it;
  • Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;
  • Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.

Customer information will be held by us in both paper form and on our secure IT systems and will be kept in line with our retention procedures. If you would like a copy of the information we hold about you, you can make a Data Subject Access Request under the Data Protection Act. Please email us [email protected].

If any of the Personal Information that you have provided to us changes, for example, if you change your email address or if you wish to cancel any request that you have made of us, please contact Customer Service through our website at http://livesupport.suretrader.com/en . We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

Updates to our Privacy Policy

This Privacy Policy was last updated on 23 May 2018. We reserve the right to update and change this Privacy Policy from time to time based on changes to legal requirements to reflect updates to our systems. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.

If you do not agree with this policy, do not interact with our websites or any other aspect of our business including using or accessing our Services.

 

 

 

Privacy Policy

At MintBroker International (“MBI”), we take your privacy very seriously.

 

This policy has been updated to adhere to the new GDPR regulation that comes into action 25 May 2018. This new law is built around the principles of transparency and control, something SureTrader feels very strongly about. Your trust is important to us, so keeping your personal information safe and secure remains our top priority.

 

This website is provided by MBI. When visiting this website and in the course of providing services to you, MBI (“we”, “us” or “our”) may collect personal information about you (“personal data”) either (i) directly when you are asked to provide data (e.g., name, e-mail address and mailing address) or when you email, phone or otherwise contact us; or (ii) indirectly, e.g. via cookies and other technical means to monitor your use of the portal such as access logs, your internet protocol address or profiling to tailor the website to your preferences or to track your use of certain pages of the website, or from third parties who provide us with information about you.

“You” or “your”, in this privacy statement, means you as an individual, rather than any legal entity (such as your employer) which you may represent when you order a service from us via this website.

We ask that you read this Privacy Policy carefully as it contains important information about what to expect when MintBroker International collects personal information about you and how we use your personal data.

  • Information we collect about you
  • Why we collect your information
  • Who we share information with
  • Personal information storage and transfers
  • How long we retain your Personal Information
  • Personal Information covered by GDPR
  • Updates to our Privacy Policy

Information we collect:

MBI collects and processes Personal Information from you. This may include, among other things, information:

  • provided during the account opening process or during use of any of MBI website applications (for example, your name, email address, telephone number, birth date, investment objectives, trading summary to determine if you are a professional or retail client, documents such as your photo ID and your address information, which is your full residential address, including proof; a colour copy of a recent utility bill or bank statement.
  • acquired as a result of the transactions you conduct through MBI systems or in connection with services offered by MBI (for example, if you sign up for the SureTrader Prepaid Mastercard Card or if a deposit is made using a credit card, ask you to provide us with a copy of your credit card showing only the last 4 digits, full name on the card and expiration for verification of ownership of funds/card);
  • collected through Internet cookies (for further information on our use of cookies, please see our Cookie Policy).

 

Why we collect your information:

As a licensed and regulated firm, we are required by law to conduct due diligence and determine suitability by confirming your identity and your address before opening your account. Reasons we collect your information is as follows:

  • To provide you with brokerage and other services available on our platforms, and/or to handle any requests or inquiries you may have;
  • To pursue legitimate interests, including to carry out, monitor and analyze our business or operations;
  • To conduct monitoring by us or any other person on our behalf using various methods, including: (i) the use of automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (iv) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioural patterns, interactions or preferences for analysis (including predictive analysis); and/or (v) using other similar monitoring technology that may become available from time to time;
  • To comply with applicable laws or regulations in our jurisdiction;
  • For any other purpose for which your Personal Information was provided to us.
  • To personalize user profiles with MBI in order to foster better communication with our customers (for example through web analytics and newsletter tracking).

With regard to marketing-related communication, we will only provide you with such information after you have opted in and we will also provide you with the opportunity to opt out at any time if you do not wish to receive further marketing-related communication from us. If you decide to opt-out of marketing-related communications, we may not be able to provide certain features of our Services to you.

Depending on which of the following reasons above, we may process your Personal Information for the following legal reasons:

  • To comply with our legal obligations (for example, reporting to the regulator; Securities Commission of the Bahamas);
  • Because processing is necessary for the purposes of our legitimate interest or those of any third-party recipients that receive your Personal Information, provided that such interests are not taken over by your own interests or fundamental rights.

In addition, the processing may be based on your consent where you have expressly given that to us.

Who we share information with:

We may share your Personal Information in the following circumstances:

  • We share your Personal Information between the MBI subsidiaries and related-entities on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, banking, custody and other business purposes.
  • We may instruct service providers within or outside of MBI, domestically or abroad, to process Personal Information for approved purposes on our behalf and in accordance with our instructions. For example, you will be subscribed to use the trading platform technology and market data, which is provided by a third-party provider. We may disclose such information to the service provider as necessary for them to provide the services that you have requested. MBI requires these service providers to enter into confidentiality agreements with MBI that limit their use of the information that they receive. Such agreements prohibit the service provider from using MBI customer information that they receive other than to carry out the purposes for which the information was disclosed. MBI retains control over your Personal Information and uses appropriate safeguards to ensure the integrity and security of your Personal Information when engaging the service provider.
  • We may share your Personal Information with verified global databases and credit reference agencies so that we can perform identity, money laundering and fraud prevention checks, including financial institutions and regulatory bodies.
  • Consistent with applicable law, we may share your Personal Information with law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;

Otherwise, we will only disclose your Personal Information when you direct us or give us permission to do so when we are allowed or required by applicable law or regulations or any official or judicial request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

Personal information storage and transfers:

This data is stored securely in The Bahamas.

For Personal Information subject to the General Data Protection Regulation (EU) (“GDPR”) we may transfer your Personal Information outside The Bahamas as described above. This may include countries that do not provide the same level of protection as the laws of your home country (for example, the laws within the EEA or the United States). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards if required by the GDPR or other relevant laws. You may email us at [email protected] at any time if you would like further information on such safeguards.

How long we retain your Personal Information:

Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Under the Securities Commission of the Bahamas regulation, client information is required to remain on file for a minimum period of 5 years. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations and proceedings. Only after the minimum period is met, can personal information be deleted.

Personal information covered by GDPR:

With respect to EEA residents, you have a number of legal rights under GDPR in relation to the Personal Information that we hold about you. These rights include:

  • Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you.
  • Requesting that we update your personal information if it is inaccurate or incomplete;
  • Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it;
  • Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;
  • Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.

Customer information will be held by us in both paper form and on our secure IT systems and will be kept in line with our retention procedures. If you would like a copy of the information we hold about you, you can make a Data Subject Access Request under the Data Protection Act. Please email us [email protected].

If any of the Personal Information that you have provided to us changes, for example, if you change your email address or if you wish to cancel any request that you have made of us, please contact Customer Service through our website at http://livesupport.suretrader.com/en . We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

Updates to our Privacy Policy

This Privacy Policy was last updated on 23 May 2018. We reserve the right to update and change this Privacy Policy from time to time based on changes to legal requirements to reflect updates to our systems. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.

If you do not agree with this policy, do not interact with our websites or any other aspect of our business including using or accessing our Services.

 

 

 

Information Collection and Use

SureTrader is the sole owner of the information collected on this site. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement. This Web site does not collect personally identifying information about you except when you specifically and knowingly provide it.

Cookies

A cookie is a piece of data stored on the user’s hard drive containing information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. Once the user closes their browser, the cookie simply terminates. Although SureTrader does not use cookies, some of our business partners use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies. Please click here to learn more about How to work with Cookies.

Log Files

We use IP addresses to analyze trends, administer the site, track user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Sharing

We will share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person. We partner with another party to provide specific services. When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.

Links

This web site contains links to other sites. Please be aware that SureTrader is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site.

Newsletter

If a user wishes to subscribe to our SureTrader newsletter, we ask for contact information such as name and email address. A user may unsubscribe from this list at any time by contacting us.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.

Tell-A-Friend

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. SureTrader will automatically send the friend a one-time email inviting them to visit the site, and will receive no further correspondence from us.

Security

This website takes every precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected both online and off-line. When our registration/order form asks users to enter sensitive information (such as credit card number and/or social security number), that information is encrypted and is protected with the best encryption software in the industry – SSL. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when you are just ‘surfing’. To learn more about SSL, follow these links: Internet Explorer SSL or Netscape Navigator SSL. While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information off-line. All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Our employees must use password-protected screen-savers when they leave their desk. When they return, they must re-enter their password to re-gain access to your information. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. Every quarter, as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our customers’ information is protected. Finally, the servers that we store personally identifiable information on are kept in a secure environment, behind a locked cage. If you have any questions about the security at our website, you can contact us.

Special Offers

We send all new members a welcoming email to verify password and username. Established members will occasionally receive information on products, services, special deals, and a newsletter. Out of respect for the privacy of our users we present the option to not receive these types of communications. Please see our choice and opt-out below.

Site and Service Updates

We also send the user site and service announcement updates. Members are not able to un-subscribe from service announcements, which contain important information about the service. We communicate with the user to provide requested services and in regards to issues relating to their account via email or phone.

Correction/Updating Personal Information

If a user’s personally identifiable information changes, or if a user no longer desires our service, we will endeavor to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the member information page or by emailing our Customer Support.

Choice/Opt-out

Our users are given the opportunity to ‘opt-out’ of having their information used for purposes not directly related to our site at the point where we ask for the information. For example, our order form has an ‘opt-out’ mechanism so users who buy a product from us, but don’t want any marketing material, can keep their email address off of our lists. Users who no longer wish to receive our newsletter or promotional materials from our partners may opt-out of receiving these communications by replying to unsubscribe in the subject line in the email or contacting us.

Notification of Changes

If we decide to change our privacy policy, we will post those changes on our Homepage so our users are always aware of what information we collect, how we use it, and under circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

If you feel that this site is not abiding by its posted privacy policy, please contact SureTrader’s Privacy Concerns department. We at SureTrader recognize the importance of protecting your privacy. There are also several additional steps you can take to maximize your online security.