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Swiftic Mobile App – End User Privacy Policy

CONDUIT LTD., AND/OR ITS SUBSIDIARIES (DOING BUSINESS UNDER THE BRAND NAME: “SWIFTIC”) (“SWIFTIC”, “WE”, “US”, “OUR”), RESPECTS YOUR PRIVACY.

This privacy policy (the “Policy”) explains our privacy practices for Swiftic services, including each of the mobile applications powered by us, that you downloaded and their related services (“Swiftic Solution” and the “App”), that the respective business, vendor, or organization, whose App you have downloaded, use or have been registered to (“Brand Owner”) has created, customized and/or branded.

Swiftic and the Brand Owner are each distinct data controllers, as described below in this Policy.

This Policy describes the ways your personal information and data is collected, used and shared and the rights and options available to you with respect to your information.

You hereby agree to the use of: (a) electronic means to consent to and complete This Policy and to provide you with any notices given pursuant to this Policy; and (b) electronic records to store information related to this Policy and your use of the App.

  1. Privacy Policy Summary
Section Summary – for the full text please review the respective Section of this Policy
2 Personal information that you voluntarily provide. Swiftic collects and shares with the Brand Owner personal information you voluntarily provide, mainly through a Registration Form customized by the Brand Owner, which you fill in and submit while you register yourself to Swiftic Solution licensed to the Brand Owner.

If you choose not to provide information determined by the Brand Owner as mandatory, you will not become a Registered Member, and only Basic Functionalities, as determined by the Brand Owner, will be available to you.
3 Information collected by Swiftic from all End Users. Swiftic collects and shares with the Brand Owner information in regard of (a) your mobile device identifier and/or account identifier (Android UDID, iOS UUID; Advertising ID: IDFA for iOS devices and AAID for Android devices, or their equivalent), the Internet protocol (IP) address of the device used to access the Internet, geo-location (if enabled), device type and its operating system version; and (b) your usage of the App, including: interactions you make with the App’s features and functionalities, websites and content you have accessed, clicked or interacted with through the App.
4 Other Information collected by Swiftic from Registered Members. Swiftic collects and shares with the Brand Owner information regarding messages you receive through the App and/or Swiftic Solution, your participation in or use of certain features available to Registered Members only and purchases you make through the App.
5 Collection of your location. Swiftic collects and shares with the Brand Owner your geolocation (if made available to Swiftic by you).
6 Information shared with Swiftic. The Brand Owner may share with us information it has collected or processed about you prior to joining Swiftic Solution or from other sources. Third parties which provide other services or solutions to the Brand Owner, which are embedded in or integrated with SwifticSolution, will share with us information regarding your interactions with their systems.
7 Process of Sensitive Information. Swiftic does not require you to provide sensitive information and does not intentionally collect or process otherwise sensitive information.
8 Children’s Privacy. if you are under age of 13 years, or other minimum age which applies in your country (16 in most EU countries) you are not permitted to register to any Members Features, or use any aspect of Swiftic Solution, including the App.
9 Brand Owner’s Operating Partner. The Brand Owner may use the services of an operating partner which will operate Swiftic Solution licensed to the Brand Owner for or on behalf of the Brand Owner.
10, 11 Use of information. The information collected will be used for several purposes, such as: (a) providing you with Swiftic Solution’s (including the App) functionality, features and services; (b) providing you with the specific and/or personalized activities, promotions, advertisements, features and/or services (including location based services) via the App; (c) sharing it with the Brand Owner and third parties which provide you with services through Swiftic Solution (such as online ordering and ecommerce services) and for that purpose; (d) developing new services and improving the App; and (e) enforcing this Policy.
12 Information collected from Registered Member of several Brand Owners. If you are a Registered Member of more than one Brand Owner, we will unite your information which you provide, is collected by or shared with us in the scope of Swiftic Solution licensed to these Brand Owners.
13 Anonymized or aggregated information may be used by us in any way.
14 You hereby agree to the use of automated decision-making.
15 Third Parties Services. You may provide information through certain areas, features, frames or sections of the App, that are operated by or for third parties, which are responsible for their own data collection practices.
16 You hereby provide a consent to transfer of your personal information to another jurisdiction.
17 Legal basis for processing of data. Legal basis for processing your data is your consent to this Policy, if granted through submission of the registration form or otherwise. If such consent is not granted, the legal basis for processing your data is to provide you with the services of Swiftic Solution licensed to the Brand Owner or our legitimate interests.
18 Brand Owner Unique Terms. The Brand Owner may choose to make available additional terms for its engagement with you.
19 Your rights with the data. You are entitled to exercise any of the following rights: withdraw your consent, object processing of data, erasure or rectify of data, access your data or data portability.
20 Data retention. If we process your personal data, we will anonymize it if you ask to be erased or upon the lapse of eighteen (18) months as of termination of the Brand Owner engagement with us.
21 Information security. Security measures are implemented to reduce the risks of damage, loss of information and unauthorized access or use of information.
22 Changes to this policy. We may change this Policy from time to time. Updated version is available at:http://app4mobilebiz.wpengine.com/swiftic-mobile-app-end-user-privacy-policy.html.
  1. Personal information that you voluntarily provide

2.1.     You are requested to submit a registration form (or otherwise provide personal information about you in an equivalent form or manner) in order to become a registered (or logged in) member of the Brand Owner’s customer membership/community/“followers” club/association (or their equivalent) (“Brand Owner’s Program”) or other service of Swiftic Solution licensed to the Brand Owner (“Registered Member” and the “Registration Form” respectively). The Registration Form includes personal details such as: name, phone number, email and home address, it is customized by the Brand Owner and may include fields which are explicitly indicated as mandatory (i.e.: fields determined by the Brand Owner, which must be completed in order to submit the registration from and to join the Brand Owner’s Program thereof; “Mandatory Fields”).

2.2.     You may choose not to share your personal information with us. There are many activities, functionalities, features or services of the App (as will be determined by the Brand Owner), which will be available to you if you choose not to fill in all Mandatory Fields and not become a Registered Member of the Brand Owner’s Program thereof (“Basic Functionalities”).

2.3.     If you specifically opt-in to permit access and collection of information from your social network account(s), then your basic personal information in your social network account will be collected (such as your name, photo and email address) as well as your social network user ID (but not your password). Please refer to the social network’s privacy policy for more details on how you can set the privacy preferences of your account to control the information that may be accessed and retrieved. We collect this information for the purpose of enabling your registration to Swiftic Solution licensed to the Brand Owner (such as the loyalty program or the App).

2.4.     By customizing the Registration Form, the Brand Owner may ask you to provide information in addition to the above. Such information will be processed by us for the Brand Owner and under the Brand Owner responsibility.

2.5.     Your information may be provided in several occasions or phases and/or in separate submissions. Please note that refusal or avoidance to provide any additional information or to accept further terms or offers shall not derogate from our right to store former information provided or submitted to Swiftic Solution or to the Brand Owner.

  1. Information collected by Us from all End Users

The following section will apply to our data collection practices which apply to all End Users, including End Users which do not voluntarily share their personal information with us, or not asked to share their personal information.

3.1.     We collect from all App End Users information about the mobile device, such as mobile device identifier and/or account identifier (Android UDID, iOS UUID; Advertising ID: IDFA for iOS devices and AAID for Android devices, or their equivalent), the Internet protocol (IP) address of the device used to access the Internet, geo-location (if enabled), device type and its operating system version. We also collect information regarding the features, content, services or websites accessed, clicked or interacted with through the App as well as information regarding the interactions made with the App’s interface and features such as logging info, the App’s tabs, banners, or pages that are clicked on or accessed, ads and/or promotions viewed through the App and receipt of notifications sent through the App and/or Swiftic Solution.

3.2.     Some of the App features are chosen and/or customized by the Brand Owner. Process of such data depends therefore on the Brand Owner’ decision which features and/or functionalities will be included in the Swiftic Solution licensed to it.

  1. Other Information collected by us from Registered Members

4.1.     In addition to the above, if you are a Registered member, we collect information regarding (i) receipt of SMS text messages or emails sent to you through the App and/or Swiftic Solution; and (ii) your participation in or use of Swiftic Solution features available to Registered Members only (such as: scratch card, point accumulation plans, punch card, coupons, gift card, cash back or their equivalent; collectively: “Members Features”).

4.2.     Some Members Features and/or other functionalities of Swiftic Solution are selected and/or customized by the Brand Owner. Process of such data depends therefore on the Brand Owner’ decision which features and/or functionalities will be included Swiftic Solution (including in the App).

  1. Collection of your location

5.1.     We process your geolocation information in order to provide you with offers and/or promotions which are based on your location (“Location Based Services”). These Location Based Services apply whenever your location is made available to us.

5.2.     Your location will be available to us (i) via your mobile phone, if you provide permission to share it with us; and/or (ii) if you check in with Facebook or another equivalent source.

5.3.     By disabling your geo-location (through the mobile device operating system), certain features which require your geo-location information may not function or may be interrupted. Please note that by such disabling, your location may still be assumed and/or collected by us from other available sources as described above.

  1. Information Shared with Us

6.1.     The Brand Owner may, upon its discretion, share with us information it has collected or processed about you prior to joining Swiftic Solution or from other sources (“Shared Information”). We are not responsible for the Shared Information, nor for its collection, process or sharing practices or authorizations. You hereby agree that the Shared Information shall be used in accordance with and subject to the terms of this Policy, and it will be added to or combined with other information processed (including: collected, used or shared) under this Policy.

6.2.     Third parties which provide other services or solutions to the Brand Owner, which are embedded in or integrated with Swiftic Solution, such as ordering, payment, e-commerce or scheduling services or solutions (“Third Parties Services”), will share with us information regarding your interactions with their systems such as: (i) your name, email address and/or phone number (if provided by you); and (ii) purchase details (time and date of the purchase, place where purchase was made, the amount paid and information about the items purchased). Please note that we are not responsible for the data collection and process practices of Third Parties Services, which you are encouraged to review before interacting with these Third Parties Services.

  1. Process of Sensitive Information

7.1.     Swiftic does not require its End Users to provide sensitive information and does not intentionally collect or process otherwise sensitive information.

7.2.     If by using Swiftic Solution (including any third-party services integrated to or embedded in Swiftic Solution) you are asked to provide sensitive information, or you have a reason to suspect that sensitive information is collected, you are requested to immediately report to Swiftic at support@swiftic.com. Please note that the definition of “sensitive information” may not have the same meaning in different jurisdictions.

  1. Children’s Privacy

Personal information about children who are under 13 years, or other minimum age which applies in your country (16 in most EU countries) is not knowingly or intentionally collected. If you are under that age, you are not permitted to use the App, register to any Members Features, or use any aspect of Swiftic Solution.

  1. Brand Owner’ Operating Partner

9.1.     The Brand Owner may use the services of an operating partner which will operate Swiftic Solution for or on behalf of the Brand Owner (“Operating Partner”). The Operating Partner will have the same rights as of the Brand Owner with respect to your information, provided that the Operating Partner is obliged to use your information for the same purposes as the Brand Owner and for the benefit of the Brand Owner only.

9.2.     If the Brand Owner uses an Operating Partner Services, information that we collect or obtain through Swiftic Solution (including the App), will be shared with the relevant Brand Owner Partner(s), for its operation and administration of Swiftic Solution licensed to the Brand Owner and/or the App and executing Brand Owner’s and/or our requests with respect to Swiftic Solution and/or the App functionality and respected services and/or features.

  1. Use of collected information

The information we collect, and which is shared with us will be used for the following purposes:

10.1. Sharing it with or transferring it to others, as the case may be, as detailed in the next section (“Sharing and transferring collected information“);

10.2. To provide you with Swiftic Solution’s (including the App) functionality, features and services, send you, from time to time, push notifications, SMS text messages and/or commercial emails from the Brand Owner, us and/or other various Brand Owners whose Apps you use and which are powered by us;

10.3. To provide you with the specific and/or personalized activity, promotions, advertisements, features and/or service via the App, including, but not limited to, sending you, from time to time, push notifications, SMS text messages and/or commercial emails regarding your use of such specific activity, promotion, feature and/or service;

10.4. To provide you with Location Based Services;

10.5. To remotely update the App on your mobile device when a new version or update is released;

10.6. To improve and customize the experience of using the App and the offerings made through the App;

10.7. To develop new services update or upgrade existing services;

10.8. To manage the administrative and operational aspects of our Swiftic Solution, including the App (such as Brand Owner and advertisers’ payments);

10.9. To enforce this Policy and the Terms and prevent unlawful activities and misuse of the App;

10.10. To comply with any applicable law and assist law enforcement agencies when we have a good faith belief that our cooperation with them meets the applicable legal standards; and

10.11. To take any action in any case of dispute involving you with respect to the App.

  1. Sharing and transferring collected information

The information outlined in the preceding sections, may be shared with, or transferred to others, as the case may be, in any of the following instances:

Sharing with: What information is shared? Information will be used to:
The Brand Owner / Brand Owner Operating Partner All information processed about you within the scope of the respective Swiftic Solution licensed to the Brand Owner (such as: Registration Form; participation in Swiftic Solution; usage of the App; purchases made and location). Manage Swiftic Solution licensed to the Brand Owner (such as the Brand Owner Program or the App); identify you personally and apply to you in a personal manner by using Swiftic Solution; customize Members Features; provide you with promotions, offering and ads customized to you.
Third Parties which provide Third Parties Services Information provided through the Registration Form; relevant information for usage by the Brand Owner at its premises. Enable the respective third party to identify you and attribute to you the services and functionalities enabled by the third party, including purchase, ordering and scheduling; operate, maintain and provide you with these Third Parties Services customized to you.

In addition to the above, we may share the information as follows:

11.1. If you have breached the Terms or this Policy, abused your rights to use the App, or violated any applicable law, or in any other case of dispute, or legal proceeding of any kind involving you with respect to the App, your information may be shared with competent authorities and with any third party, as may be required;

11.2. We may share information that we collect or obtain through the App with the relevant authorities, entities or persons if we reasonably believe that we are required by law to share or disclose your information;

11.3. Personal identifiable information may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly), but their use of such information must comply with this Policy; and

11.4. Upon bankruptcy, dissolution or other liquidation or insolvency events or in the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization or reconstruction in our ongoing business, the information that we receive, collect or obtain, as outlined in the preceding sections, may be shared with or transferred to, that respective entity, provided that it will undertake to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, that entity will assume full and exclusive responsibility for all subsequent use and processing it makes of the information and we will be released from any liability to you, regarding the succeeding entity’s use and processing of the information by it.

11.5. In any case other than the above mentioned in this Policy, your personally identifiable information will be shared with others only if you provide your consent.

  1. Information collected from Registered Member of several Brand Owners

If you are a Registered Member of more than one Brand Owner, we will unite your information which you provide, is collected by or shared with us in the scope of Swiftic Solution licensed to these Brand Owners. This unified information will be used by us to better advise, assist and support these Brand Owners in customization their services, offering and promotions to you, to improve our services to them, as well as for other purposes outlined in Section 10 (“Use of collected information”). Provided however that, we will not share details provided by you in a Registration Form of one Brand Owner or your actual purchased items at that Brand Owner with another Brand Owner.

  1. Aggregated or anonymized information

The App collects anonymized as well as aggregated information, which does not identify you personally. In addition, we may anonymize your information and/or aggregate it with other End Users’ information. Such anonymized or aggregated information will be used by us in any way, including by posting, disseminating, transmitting, sharing or otherwise communicating or making it available to the Brand Owner, Operating Partner as well as any other third party.

  1. Use of Automated Decision-Making

You hereby agree to the use of automated decision-making, based on the information you provide us and your usage of Swiftic Solution (including the App, if applicable), including number of transactions, frequency and volume. You will be identified by Swiftic Solution as such, and receive different offerings that the Brand Owner or we pre-customize to your profile.

  1. Third Parties Services

15.1. You may provide information through certain areas, features, frames or sections of the App, that are operated by or for third parties. Those third parties may include, e-commerce platforms, scheduling partners, payment services providers and payment processors (“Third Parties” and “Third Parties Services”).

15.2. It is those Third Parties, and not Swiftic, that are responsible for their data collection practices associated with such Third Parties Services. We encourage you to read the privacy policy of each Third Party.

15.3. Third Parties Services will share with us information they collect from you or you voluntarily provide to them which is related to or within the scope of Swiftic Solution (including the App).

  1. Transfer of Data Outside Your Territory

The App, by its nature as an online service, may store and process information in Europe, the United States and in other various locations throughout the globe. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you hereby provide your express and unambiguous consent to such transfer.

  1. Legal basis for processing of data

17.1. Process (including: collection, use and share) of information you provide us through the Registration Form is based on your consent, granted through submission of the Registration Form.

17.2. Consent is personal. You must not provide other person’s information or register on behalf of another person.

17.3. If you intentionally provide us or the Brand Owner any information not through and in lieu of a submitting a Registration Form, we will consider that action as your consent for sharing this information with us (or the Brand Owner, as applicable), storing and using it for the purpose of identifying you personally on later occasions, including sharing this information with third parties (which provide Third Parties Services) for that purpose.in that case the legal basis for processing this information will be based on fulfilment of contract to provide you services.

17.4. Information we process about you in accordance with this Policy, which is not based on your consent, is processed on the basis of (i) fulfillment of contract to provide you services under Swiftic Solution you joined (including the App you downloaded, if applicable); and/or (ii) our legitimate interests of in order to perform services requested by you from the Brand Owner or us.

  1. Brand Owner Unique Terms

The Brand Owner may choose to make available additional terms for its customer loyalty program (“Brand Owner Terms”) which may include, inter alia, provisions with respect to the information collected by the Brand Owner and/or shared with it by Swiftic. Swiftic is not responsible for the Brand Owner Terms. In any discrepancy between this Policy and the Brand Owner Terms this Policy shall prevail.

  1. Your Rights with the Data

19.1. You have the right to exercise any of the following rights, as well as other rights granted to you in accordance with the laws apply to you (“End User Right(s)”):

(a)     Consent Withdraw: you may withdraw your consent granted to us to collect and process your personal information pursuant to the terms of this Privacy Policy.

(b)     Right to object: you may object to the processing of your personal data.

(c)     Right to erasure (right to be forgotten): you have the right to request us to delete or remove the personal information collected through your use of Swiftic Solution licensed to the Brand Owner (including the App and/or the Brand Owner loyalty program).

(d)     Right of access / Right to data portability: you have a right to receive a copy of the data collected about you in the course of using Swiftic Solution licensed to the Brand Owner.

Following receipt of a copy of the data collected about you, you may ask us to rectify or erase the data collected about you in the course of using Swiftic Solution licensed to the Brand Owner.

19.2. You can exercise End User Right(s) by (a) clicking the respective checkbox which is implemented in the App profile page (if available to you, considering the laws apply to the App); or (b) sending us an email to: support@swiftic.com. Your email subject shall include the End User Right(s) you would like to exercise (such as: “Consent Withdraw”). The email message shall include your full name, mobile number, the email address used for registration to Swiftic Solution licensed to the Brand Owner (such as the loyalty program or the App) and the name of the Brand Owner. We may have to communicate with you in order to process your request, including to verify your identity. By sending us an email you hereby agree that we will communicate with you for that purpose.

19.3. If you choose to exercise any End User Right(s) (a)-(c), the following shall apply (“Profile Anonymization”):

No later than 14 days from receiving your request, we will (i) delete your personal data from our Operational Database (the database which is available to Brand Owners in the course of using Swiftic Solution and processed by Swiftic for providing analytics and data insights to the Brand Owner); (ii) you will be disconnected from Swiftic Solution licensed to the Brand Owner and cease to be a Registered Member; and (iii) you will be able to redeem your benefits/assets accumulated until such exercise (if any) directly with the Brand Owner only. You will not be able to accumulate any additional benefits/assets as from exercise of these rights. We encourage you to make a screenshot of your benefits/assets before you submit your request in order to be able to present them to the Brand Owner upon redeem.

Exercise of any End User Right(s) (a)-(c) will not affect the lawfulness of processing based on consent before they were exercised. We may continue to process information which your consent is not required for, subject to any applicable law.

19.4. If you choose to exercise End User Right (d), we will send you a copy of the data collected about you in the course of using Swiftic Solution licensed to the Brand Owner. The copy will be sent to the email address you used for registration to Swiftic Solution licensed to the Brand Owner (such as the loyalty program or the App) or to other email you will submit to us upon exercise of your right (which will be used by us for that purpose only). You hereby agree that we will send you an email with that data and we may communicate with you in order to process your request, including to verify your identity, if required.

You may request that we will rectify or erase your data. We will notify you in writing if rectification or erasure of portion of the data is not feasible. In such case you shall have the option to erase the entire data, by exercising End User Right (c) above.

19.5. Please note that if you have registered yourself to a Brand Owner’s Program more than once (for example by using different phone numbers or different emails), you will have to exercise the above rights with respect to each registration separately. In addition, if you are a Registered Member of more than one Brand Owner, you will have to exercise the above rights with respect to each Brand Owner separately. Please contact us at support@swiftic.com if you want to exercise the above rights with respect to all licenses of Swiftic Solution and to apply your Profile Anonymization with respect to Swiftic entirely.

19.6. In addition to the above you have the right to lodge a complaint with a supervisory authority.

  1. Data Retention

20.1. We will perform the above Profile Anonymization procedure of your personal data, which is available on our Operational Database at any of the following: (a) if you exercise any of End User Right(s) (a)-(c) above; or (ii) upon the lapse of eighteen (18) months as of termination of the Brand Owner engagement with us, whose Swiftic Solution you are registered to.

20.2. Be advised that (i) following Profile Anonymization, you will no longer be registered as a Registered Member in our systems, however, some personal information may still reside in our systems in archived form in such areas which we do not access for using such information; and (ii) certain features or services of the App will not be available or function if such information is deleted or removed.

20.3. Please note that removal of the App from your device does not cause a deletion or anonymization of the information you voluntarily provided or information that we collected in accordance with this Policy. In addition, if you are a Registered Member of several Brand Owners or submitted your personal information within different Apps supported by us, Profile Anonymization within one Brand Owner will not cause the anonymization of your personal information within other Brand Owners.

  1. Information Security

Security measures are implemented to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures are unable to provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed and you cannot reasonably expect that the App and its related databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or other kinds of abuse and misuse.

  1. Changes to this Policy

22.1. This Policy may be changed from time to time. Substantial changes will take effect 30 days after an initial notification is posted through the App. Other changes will take effect 7 days after their initial posting within the App and in the following link: http://app4mobilebiz.wpengine.com/swiftic-mobile-app-end-user-privacy-policy.html. However, if the Policy is amended to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required. The most up-to-date Policy is accessible through the App’s settings or information menu and in the following link: http://app4mobilebiz.wpengine.com/swiftic-mobile-app-end-user-privacy-policy.html.

22.2. You agree to be bound by any of the changes made to this Policy. Your continued use of the App after the changed take effect will indicate your acceptance of the amended Policy. If you do not agree with the amended Policy, you must uninstall the App and avoid any further use of it.

  1. Contact Us

You may send requests, responses, questions and complaints the following email address: privacy@swiftic.com.

For your convenience, this Policy is translated from English to several other languages. Please note that in any discrepancies between the translation available to you (if any) and the English version, the English version (available at: http://app4mobilebiz.wpengine.com/swiftic-mobile-app-end-user-privacy-policy.html) shall prevail.

24. YouTube

By visiting and using the Swiftic website, the website you agree to be bound by the YouTube terms of service which can found in the following link: https://www.youtube.com/t/terms

25. YouTube and Google

By using the website you acknowledge that the Swiftic website uses the YouTube API services. By using those services you also acknowledge and agree to the connected use of the Google Privacy Policy which can be found through the following link: https://policies.google.com/privacy

Last Updated: 22.6.2020

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We do not recommend the use of technical analysis as a sole means of trading decisions. We do not recommend making hurried trading decisions. You should always understand that PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS.

Privacy Policy

With the complete awareness of the value of privacy, we develop all our apps which care about every individual’s privacy. Our apps always comply with the standards set by Google, which are well researched and meticulously set to protect the privacy of the customers.

User data

We state clearly in our disclosure about the collection of data. We are transparent in the handling of user data. Information provided by the user, information collected about the user and information collected by the use of the application by the user is handled properly and we adhere strictly to our disclosure. In certain cases, we take care about the land of the law to comply with the rules and regulations. Forex Signals APP

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Personal and sensitive information

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When our app handles personal or sensitive data, as per the guidelines given by Google,

  • We post a privacy policy in both the designated field in the Play Developer Console and from within the Play distributed app itself.
    • And we handle the user data securely, including transmitting it using modern cryptography (for example, over HTTPS).

In our disclosure, we clearly state the way of using the personal data when data collected are not relevant to the app.

In case of handling, financial or payment information or government identification numbers, we never publicly disclose any personal or sensitive user data related to financial or payment activities or any government identification numbers.

In case of non-public phone book or contact information, we don’t disclose people’s non-public contacts.

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In case of antivirus or security functionality, we clearly explain in our disclosure about the collection of user data, the way of transmission and the types of parties with which data are shared.

Violation of devices and networks

COPY TRADING SOFTWARE DISCLAIMER

Telegram FX copier software or any similar types of software is a third party affiliate link only. Using telegram copier software is at your own risk again fully and we take no responsibility whatsoever as FxPremiere are strictly intermediate marketing signal sending services ONLY!

Risk Disclosure

Our Apps don’t damage, disrupt or interfere with any device and its functions. Our apps never involve in the unauthorized access of the user’s device, other devices or computers, servers, networks, application programming interfaces (APIs), or services, including but not limited to other apps on the device, any Google service, or an authorized carrier’s network.

Our Apps also comply with the default Android system optimization requirements as per the guidelines drafted by Google.

  • We don’t interfere with other apps working functionalities.
    • Our apps don’t provide instructions about hacking other services and to violate security protections.
    • Our apps don’t violate the terms of service. Forex Signals Apps

Conforming activity

Our apps are not malicious and behave perfectly by conforming to the guidelines set by google. Our apps don’t steal data, harm the users and don’t do secret monitoring.

Why You Shouldn’t Be Using Free Forex Signals

In case of modifying, replacing or updating our apps we assure to follow the Google Play’s update mechanism and never violate the user data policy. Forex Signals Service

Security and Disclosure

FxPremiere.com self employed and third party firms (Online Services) respects each individual’s right to privacy. We value our relationship with you, and we take pride in maintaining loyalty and respect with each individual client by providing you with security. The provisions of this notice apply to former clients as well as our current clients.

Personal Information

When you apply for or maintain a live account with FxPremiere.com, we collect personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing customer service. Such information may include:

  • Name
  • Email Address
  • Phone Number
  • The broker you are using

About Cookies

Cookies are small files containing information that a Web site uses to track its visitors. FxPremiere.com may set and access FxPremiere.com cookies on your computer, enabling us to learn which advertisements and promotions bring users to our Web site. FxPremiere.com or any of its divisions may use cookies in connection with FxPremiere.com products and services to track your activities on our Web sites. Such information that we collect and share would be anonymous and not personally identifiable.

Security Technology

FxPremiere.com uses Secure Socket Layer (SSL) encryption technology in order to protect certain information that you submit. This type of technology protects you from having your information intercepted by anyone other than FxPremiere.com while it is being transmitted to us. We work hard to ensure that our Web sites are secure and that they meet industry standards. We also use other safeguards such as firewalls, authentication systems (e.g., passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data. Sharing Information With

Third Parties

FxPremiere.com does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with FxPremiere.com, including those that provide professional, legal, or accounting advice to FxPremiere.com Non-affiliated companies that assist FxPremiere.com  in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that FxPremiere.com dictates.

We may also disclose your personal information to third parties to fulfill your instructions or pursuant to your expressed consent.

We want you to know that FxPremiere.com will not sell your personal information.

Regulatory Disclosure

Under limited circumstances, FxPremiere.com may disclose your personal information to third parties as permitted by, or to comply with, applicable laws and regulations. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property. Except as described in this privacy policy, we will not use your personal information for any other purpose, unless we describe how such information will be used at the time you disclose it to us or we obtain your permission.

Opt-Out

You are not required to supply any of the personal information that we may request; however, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete, and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

If you do not wish to have your personal information disclosed to our affiliates or other third parties as described in this Policy, please contact us via e-mail at: support@fxpremiere.com

NOTICE: FXPREMIERE.COM is an intermediary to the Forex Signals arena. We as FxPremiere.com combine all Signals from around 50 sources online as ONLINE AFFILIATES ONLY, then distribute to YOU (purchaser of subscription) for a small fee instead of subscribing to several forex signal sites. We do not analyse the market. We are strictly online affiliates combining our sources to send to you *forex signals* for a set fee as online affiliates as a digital online services for informational and educational purposes only!

FXPremiere are intermediate Online Affiliates in the Forex Signals Arena. We as FxPremiere are not financial analysts whatsoever. Solely intermediate to over 50 Signals sources of Forex Signals online. We source over 50 Signal Sources and send to our members from packages starting from $37 per month.

www.fxpremiere.com and www.fxsignals.services or www.fx-premiere.com are not representing itself as a registered investment advisor or broker dealer nor is it offering to buy or sell any of the financial instruments mentioned in any service offered.

NO REFUNDS POLICY
Under no circumstance will www.fxpremiere.com and www.fxsignals.services or www.fx-premiere.com provide refunds neither for RealTime Notification packages nor for any premium signals service subscriptions.

Who we are
Our website address is: https://www.fxpremiere.com.

What personal data we collect and why we collect it
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms
Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics
Who we share your data with
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data
Visitor comments may be checked through an automated spam detection service.

Your contact information
Additional information
How we protect your data
What data breach procedures we have in place
What third parties we receive data from
What automated decision making and/or profiling we do with user data
Industry regulatory disclosure requirements

This site utilizes caching in order to facilitate a faster response time and better user experience. Caching potentially stores a duplicate copy of every web page that is on display on this site. All cache files are temporary, and are never accessed by any third party, except as necessary to obtain technical support from the cache plugin vendor. Cache files expire on a schedule set by the site administrator, but may easily be purged by the admin before their natural expiration, if necessary.

FxPremiere.com is an informational site platform for exchanging Forex related information. All information contained on this website (fxpremiere.com) is a personal opinion or belief of the author/s. None of these data is a recommendation or financial advice in any sense or form.
Terms And Conditions Apply.

Terms of Service
All Subscription charges are non-refundable from the date of purchase. Following from the date of purchase. FxPremiere.com or www.fx-premiere.com makes no representation or warranty regarding
its compliance with local laws in foreign jurisdictions, or regarding the appropriateness of the Web site’s content or its compliance with such local laws. You agree that
FxPremiere.com or www.fx-premiere.com shall not be liable for any losses or damages you incur as a result of the unavailability of The FxPremiere.com Web site from foreign countries. Once you have subscribed, payments are instantly recurring payment. if you wish to cancel you
may do so by sending info@fxpremiere.com a 30 days notice of cancellation. Only once 30 days have cancelled may you cancel your recurring payment profile via one of the payment processors yourself. if you cancel your recurring payments before a written 30 days notice you will be in liable to pay us 1 month worth of subscription. This Agreement will be effective only upon our approval of your Subscription. FxPremiere.com further reserves the right to reject a Subscription Application for any reason. FxPremiere cannot guarantee Telegram  ONLY!  Delivery as 1% of subscribers may not be able to receive the Telegram / ONLY!  to their mobile due to the Line they have not accepted our welcome EMAIL. However 99% of our members do receive these. If you are in the 1% we can try deliver to any other mobile. If not then the Email is the backup . ( 99% of the Public now own a SMART PHONE, therefore Telegram  delivery works including Telegram /, The possibility exists that you could sustain a loss of some or all of your initial investment and therefore you should not invest money that you cannot afford to lose. You should be aware of all the risks associated with foreign exchange trading and seek advice from an independent financial advisor if you have any doubts. Any opinions, news, research, analyses, prices or other information contained on this website or linked to from this website are provided as general market commentary and do not constitute investment advice. FxPremiere does not accept liability for any loss or damage, including without limitation to, any loss of profit, which may arise directly or indirectly from use of or reliance on such information. There are a lot of countries where rules of forex trading are different from other countries, for example, USA has FIFO rule. There are some countries where forex trading is unavailable or limited, for example India. Countries which don’t avail forex trading in their jurisdiction, have specific rules for outward remittances. Therefore, everyone should check and understand rules & regulation of his/her country before starting forex trading out of their country. Our service is not for people of any particular country, rather it is worldwide. We are not responsible for violation of any rule of a particular country by any resident of that country. Forex Signals Trading has large potential rewards, but also large potential risk. You must be fully aware and be willing to accept them in order to invest in the financial capital market. Our Forex Signals are strictly for demo and informational purposes only. Trading leveraged products such as forex, commodities and CFDs carries extreme levels of risk and so may not be suitable for every investor, prior to trading consider your investment objectives as well as risk appetite. FxPremiere will not be held liable whatsoever for the services it offers. By Using our Site you are fully abiding by our Terms of Services. The owners of the website and the website hereby waive any liability whatsoever due to the use of the website and/or information. Use of the website, the content and the information is made on the user’s sole liability. The user hereby releases the owners of the website from any liability for damage caused to his computer, in any, through the use of the website and/or its content and/or its various services. The user hereby releases the owners of the website, the website, their partners, agents, employees, officers, managers, directors, shareholders, etc. from any liability for losses and/or financial damages and/or personal bodily damages and/or fraud, caused through the use of the website. FxPremiere.com or www.fx-premiere.com are not financial advisers sites. They are strictly educational sites for the forex market to purchase forex signals and to place on DEMO accounts only. All Our Referrals for opening a Live Account are at the subscribers full responsibility. The Brokers we do refer clients to are ALL Regulated! If you do not agree with any of these terms, you are prohibited from using or accessing this site whatsoever . We are strictly on intermediary to the forex signals world as affiliates offering you a combined service.

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

*cftc rule 4.41 – hypothetical or simulated performance results have certain limitations. Unlike an actual performance record, simulated results do not represent actual trading. Also, since the trades have not been executed, the results may have under-or-over compensated for the impact, if any, of certain market factors, such as lack of liquidity. Simulated trading programs in general are also subject to the fact that they are designed with the benefit of hindsight. No representation is being made that any account will or is likely to achieve profit or losses similar to those shown.

By using www.fxpremiere.com | www.fxsignals.services or www.fx-premiere.com you acknowledge that you are familiar with these risks and that you are solely responsible for the outcomes of your decisions. We accept no liability whatsoever for any direct or consequential loss arising from the use of this product. It’s to be noted carefully in this respect, that past results are not necessarily indicative of future performance. Signals, charts, news and financial markets are gathered around the web and www.fxpremiere.com | www.fxsignals.services or www.fx-premiere.com takes no responsibility for its accuracy.
It is at your own discretion to make use of the information published within the site. Please read Terms and Conditions for more information.

Furthermore, there is no guarantee that every signal delivered by www.fxpremiere.com | www.fxsignals.services or www.fx-premiere.com will be traded in our accounts. There is no guarantee being given that the use of www.fxpremiere.com | www.fxsignals.services Forex Signals or other Content will result in trading profits or not result in losses. Past results are not indicative of future returns and User results will vary. The User agrees to accept full responsibility for any trading decisions and the results of these decisions. Our staff may hold positions in various financial instruments mentioned in any of the services we offer and have no obligation to disclose when a position was acquired, the amount of position held or when a position is closed. Any decision to act upon suggestions made in any service we offer is the sole responsibility of the member.

You expressly understand and agree that www.fxpremiere.com | www.fxsignals.services shall not be liable for any direct, indirect, incidental, special, or consequential damages, including but not limited to, damages for loss or profits, goodwill, use, data or other intangible losses.
No guarantee is being made that an account will or is likely to achieve profits or losses comparable to those shown. You must be both aware of the risks and willing to accept them before investing in the Forex markets. Never trade with money you cannot afford to lose. Nothing in our course or website should be deemed a solicitation or an offer to buy or sell Forex lots or contracts. No guarantee is being made that any account will or is likely to achieve profits or losses analogous to those discussed on our site.

Under no circumstances shall the Site or its Associates be accountable for any direct, indirect, incidental, special, or consequential damages that result from the use of or inability to use the Site. This is including but not limited to reliance by the user on any information obtained from the Site, or that results from mistakes, omissions, interruptions, deletion of files or email, errors, defects, viruses, delays in operation or transmission, or any failure of performance, whether or not resulting from acts of God, communications failure, theft, destruction or unauthorized access to the Site records, programs or services. You hereby acknowledge that this paragraph shall apply to all Content, merchandize and services available through the Site.
There is the risk of substantial loss when trading in any financial market and as such it is not suitable for all investors. Any type of trading in all market conditions is extremely risky and can quickly result in substantial financial losses. Any transaction involves considerable exposure to risks including, but not limited to, the potential for changing political and/or economic conditions that may substantially affect the price or liquidity of a trade. Privacy Policy

DISCLAIMER
“We do not store credit card details nor do we share customer details with any
3rd parties other than our merchants.
•VISA USA – (CISP – Cardholder Information Security Program)
•VISA International – (AIS – Account Information Security)
•MasterCard Worldwide – (SDP- Site Data Protection)
•American Express – (DSOP -Data Security Operating Policy)
•Discover Network – (DISC – Discover Information Security and Compliance)
•JCB – Fully supports the PCI DSS mandate

Please note that this certificate does not substitute for the need to register with the card brands directly in order to be listed on their websites and for them to confirm you as compliant per their individual programs
For GDPR Laws: –
This Privacy Policy describes how FxPremiere.com or www.fx-premiere.com collects and uses information through its website https://www.fxpremiere.com/, and any other related websites and applications, including among others, FxPremiere.com Members Area if available or live. This Privacy Policy does not apply to websites operated by any other organisations and/or other third parties. We Are Committed to Protecting Your Privacy FxPremiere.com respects the privacy of any users who accesses its website(s), and it is therefore committed to taking all reasonable steps to safeguard any existing or prospective clients, applicants and website visitors.

What Personal Information Do We Collect?
In order to open an account with us, you must first complete a payment via PayPal and or Card which then takes you to the FxPremiere.com thank you page in which you adhere tour terms of service including privacy policy and risk disclosure fully. The information you provide may also be used by FxPremiere.com to inform you regarding its services. Moreover, your personal information may also be collected through any correspondence made with us by phone, e-mail or otherwise, including personal data that you enter when you register to use our website, subscribe to our services or any other activities carried out on our website or any connected applications.

FxPremiere.com shall not disclose any of its clients’ confidential information to a third party, unless required to do so by a regulatory authority of a competent jurisdiction. FxPremiere.com will endeavor to make such disclosures on a ‘need-to-know’ basis, unless otherwise instructed by a regulatory authority. Under such circumstances, FxPremiere.com shall expressly inform the third party regarding the confidential nature of any such information.

Disclosure of Your Personal Information
FxPremiere.com or www.fx-premiere.com may share your personal information with any members of our group of companies, which means that any of our ultimate holding companies and their respective subsidiaries may receive such information. We may also share your information with certain third parties, including service providers and specialist advisers who have been contracted to provide us with administrative, financial, insurance, research or other services, as well as with business introducers, business parties, courts, tribunals and regulatory authorities as agreed or authorised by law. In the event that FxPremiere.com discloses your personal information to business parties, such as card processing companies or banks, in order to perform the services requested by clients, such third parties may store your information in order to comply with their legal and other obligations.

Choice to Opt Out Submitting Your Personal Information
Should you not want us to use your personal information, you must inform FxPremiere.com or www.fx-premiere.com in writing to info@fxpremiere.com. If you decide to do so, we may
not be able to continue to provide information, services and/or products requested by you and we will have no liability to you in this respect. Privacy Policy

Updating Your Information
You may inform FxPremiere.com or www.fx-premiere.com at any time that your personal details have changed by e-mailing us at info@fxpremiere.com . FxPremiere.com will change your
personal information in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof, i.e. personal information that we are required to keep for regulatory or legal purposes. Changes in this Privacy Statement Our Privacy Policy Statement is reviewed from time to time to take into account new laws and technologies, changes to our operations and practices, and to ensure that it remains appropriate to the changing environment. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy Statement and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Privacy Policy
Payment Flow and Delivery Policy – delivery time frame for when the customer will receive the goods/service Once Payment is taken in full, All Signals arrive as Telegram / ONLY! Privacy Policy
[FxPremiere.com & Affiliates] may ask for some personal details from its staff and volunteers. This ensures that we can contact you and take account of your anti-fraud prevention precaution.
[FxPremiere.com & Affiliates] take our responsibility for looking after information seriously. We follow the data Protection Act at all times when asking for or handling
your information. Sometimes sensitive information may also be asked for e.g. anti fraud prevention of card details. We will always ask for explicit consent before collecting or using this information. A copy of this statement will be brought to the attention of all employees and volunteers. Privacy Policy
Forex trading is highly speculative and risky. Anyone found to be passing our signals to non paying customers will be taken to stage 2 investigation. We are not financial advisors, so please consult your financial advisor before trading, we only provide hypothetical forex signals & analysis, so trade at your own risk. Privacy Policy Forex Signals By registering/subscribing as a member/client on fxpremiere.com or www.fx-premiere.com you are agreeing to the Terms and Conditions & Risk Disclosure FULLY FxPremiere.com respects each individual’s right to privacy. We value our relationship with you, and we take pride in maintaining loyalty and respect with each individual client by providing you with security. The provisions of this notice apply to former members as well as our current members | using forex signals

Using our Trade Copier Service  – FxPremiere.com or www.fx-premiere.com take no responsibility whatsoever using third party sites or services.

Our Affiliate Program from TradeCopier Telegram / again is trading automated signals at your own risk fully using third party firms.

All Payments are recurring until cancelled and we offer no refunds. By proceeding with your order you agree to our Terms & Conditions

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