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We reserve the right at our discretion to update this Policy to reflect our privacy practices. We encourage you to periodically review this page for the latest information on our privacy practices, and any use of our Website after any updates constitute your acknowledgement that you have read and consented to the updated Policy.
Collecting and Use of Personal Information
Enigma Securities may collect and use the Personal Information such as your name, address, email address, signature, and other information that you provide in connection with the following:
- The visiting of our Website;
- Your application to Onboard with us;
- Subscription to our research through our Website; and
- Contacting us with a comment, question, complaint or other query.
We also obtain data about you from other sources, including identity verification services, fraud prevention agencies, websites and other publicly accessible information about you. We may also receive data you submit to us through third-party website.
If you fail to provide personal information, where we nee to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with out Website or Services). In this case, we will not be able to provide our Website or Services to you.
Communications: You may request to receive communications about Enigma Securities and its products and services through our Website or by connecting with us, also through the use of a third-party Website (including through social media websites). If you subscribe through our Website or request to receive communications from us, we collect certain Personal Information (as described above) which we use to send you email and other communications to keep you informed about our research products, our events and to tell you about products and services that may be of interest to you. You can ask us to stop or start sending you such marketing messages at any time by writing, electronic messaging or calling us.
Contact Information: When you Contact Us with a comment, question, complaint or other query, you may be asked for Personal Information along with additional information we need to help us promptly answer your questions or respond to your comment, complaint or query. If you interact with us through social media or other channels, we may store details of these interactions.
Automatically Collected Information: In general, you can visit our Website without telling us who you are or submitting any Personal Information. However we collect the IP (Internet Protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system, average time spent on our Website and how you are using our Website. We use this information to help us understand activity on our Website and to monitor and improve our Website. We may also collect information from your digital devices so as to perform checks required to meet our regulatory obligations: for example, we may identify your IP address in order to ascertain and verify your residency status.
Change of purpose
We will only use your Personal Information for the purposed for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact Us at email@example.com.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Confidentiality and Security of Personal Information
Enigma Securities maintains commercially reasonable physical, electronic and procedural safeguards that comply with applicable laws and regulations to protect the confidentiality of your Personal Information. However, as no method of transmission over the Internet, nor method of electronic storage, is 100% secure, Enigma Securities cannot guarantee the absolute security of your Personal Information.
Disclosure and Transfer of Information
Service Providers: Your Personal Information may be disclosed, stored and/or transferred (or otherwise made available) to our affiliates, including Oscar Gruss & Sons Inc., Makor Securities London Ltd., Makor Capital Markets SA and Makor Capital Ltd., and other third parties who provide services such as identification and background checks, cloud-based information hosting and maintenance, website hosting, record keeping, and analytics, and to exchanges, trading platforms and financial institutions.
Legal and Compliance: We and our service providers may provide your Personal Information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purpose of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable law or legal process. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: Your Personal Information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Enigma Securities or as part of a corporate reorganization or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
Enigma Securities retains your Personal Information for as long as needed for our functions, activities or services, or to comply with our legal obligations (such as reporting to regulatory authorities) to resolve disputes and to enforce our rights. We also may retain your information to support our business operations and develop our Website or Services. The criteria used to determine our data retention periods include: (1) how long the Personal Information is needed to provide the services and operate the business; (2) the type of Personal Information collected; and (3) whether we are subject to a legal, contractual or similar obligation to retain the data (for example, mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes.)
When we no longer need to use your Personal Information, we will take steps to properly anonymize or destroy it. We may retain information that is not personally identifiable to an individual User, including without limitation anonymized data and aggregate information, at our discretion.
Third-Party Websites and Social Networking Platforms
We may further offer you the opportunity to engage with our content on or through third-party social networking platforms, plug-ins, applications and/or services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly. When you engage with our content on or through third-party social networking websites, plug-ins, services and/or applications, you should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social networking platform or otherwise online, may be viewed by other users. We are unable to control such uses of your Personal Information identified on these online platforms, and by using such third-party services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. You have the right to access (ask for a copy of your Personal Information), update, correct or delete your Personal Information in our custody and control, and restrict (stop any active) processing of your Processing Information, subject to certain exceptions prescribed by law.
You may request access, updating, deletions and corrections of inaccuracies in other Personal Information we have in our custody or control by emailing or writing to us at the contact information set out above. You may also obtain the Personal Information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller. We may request certain Personal Information for the purposes of verifying your identity when seeking access to Personal Information records.
In addition, you can object to the processing of your Personal Information in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal Personal Information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes such as those set out above.
You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may refuse to comply with your request if it is clearly unfounded, repetitive or excessive.
We may need to request specific Personal Information from you to help us verify your identity and ensure your right to access your Personal Information or to exercise any of your other rights. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
Use by Minors Prohibited
The Website is not designed or intended for use by children under the age of 18, and we do not knowingly collect information from children. If you are under the age of 18, do not use this Website.