Privacy Policy
This Privacy Policy describes Caracol Ltd’s policies and procedures on the collection, use and disclosure of your information (including personal data) when you use the Stockity Trading Platform via the stockity.id website (hereinafter referred to as the "Website") and/or the Stockity Mobile Application and tells you about your privacy rights and how the law protects you. All further references to the Stockity Website and Mobile Application are equivalent.
This Privacy Policy is an integral part of Stockity Client Agreement.
The information you provide is collected and processed by Caracol Ltd, a company registered in accordance with the laws of the Republic of the Marshall Islands, located at Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands, MH 96960 (hereinafter - "Company," or "We"), which provides access to the Stockity Trading Platform.
We assure you that We take all necessary measures to ensure the confidentiality of the personal data you provide to Us.
We urge you to read this Privacy Policy carefully. By registering on the Website, you fully and unconditionally agree to its terms.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have the meanings set out in the following definitions.
The following definitions shall have the same meaning regardless of whether they appear in the singular or in the plural.
Definitions
For the purposes of this Privacy Policy:
"Cookie" means a small file placed on your computer, mobile device or other device by a website, which contains details of your browsing history on that website.
"You" means the individual accessing or using the Stockity Trading Platform.
Other terms shall be construed in accordance with Stockity Client Agreement.
1. Information You Provide to Us
1.1. Like most websites, We use Cookies.
Some Cookies are necessary for the normal operation of the Website and are used without obtaining additional permission from You. These files include the following:
a) cookies required to identify the source from which the transition to the Website was made;
b) Cookies containing Your session ID on the Website.
We also collect and process data about Your device, including Your IP address (Internet Protocol address), browser type, browser version, browser configuration (hereinafter referred to as "Usage Data").
1.2. When registering on the Website, We ask You to provide Us with Your email address. Later, you will have the option to enter your first and last name, date of birth, gender, phone number and country in your Personal Account on the Website.
1.3. When you fund your Account on the Stockity Trading Platform, you provide Us with information containing your payment details, including your bank card number, expiration date and CVC/CVV code, information about the credit/financial institution and/or issuer, and other data according to the payment method, as well as your first and last name, your passport/ID number, address, phone number, date of birth and email address.
1.4. When you fund your Account on the Stockity Trading Platform, Our partners (financial institutions and Payment System Providers) receive and process information containing your payment details, including your bank card number, expiration date and CVC/CVV code, information about the credit/financial institution and/or issuer, and other data according to the payment method, as well as your first and last name. In addition, upon request from the payment system or Payment System Provider, We may provide them with your passport data or other identity document, email address, and phone number (if this data is specified in your Personal Account).
Payment System Providers process such information during the period of your use of the Company’s services and delete it after achieving the purpose of processing, unless the law requires or allows to establish a longer period for storing such personal data.
A prerequisite for Our cooperation with Payment System Providers is that they meet the requirements of the law on personal data protection.
1.5. As part of the verification, We ask You to provide:
- a photo of Your passport or identity card;
- a photo of Your bank card/screenshot of Your e-wallet;
- a photo of You with the documents indicated above in Your hands.
In order to comply with the law intended to combat the legalization of illegally obtained funds, the Company may ask you to submit additional documents, such as:
- utility bills;
- bank reference letters;
- bank statements;
- documents confirming the source of your wealth/funds (e.g. salary agreement, sale of property, loan agreement, inheritance notice);
- 2nd identity document.
Verification procedures are explained in more detail here.
1.6. We collect and store data about your financial and other actions on the Stockity Trading Platform, as well as information contained in web server reports (including interface language, browser type, and the date and time of the last visit).
1.7. If you become a winner of Our promotion, We may ask you to provide Us with your first and last name, address, and telephone number, so that We can send you the prize.
1.8. From time to time, we may ask you to fill out a questionnaire to improve the quality of our services, for statistical purposes, or to comply with applicable laws.
Sometimes when filling out a form, you will be asked to provide your name and email address.
1.9. When contacting the Company Support Service, We ask you to include your first and last name, and email address.
1.10. In order to comply with international laws on combating the laundering of proceeds from crime (Anti-Money Laundering, AML), and following the KYC principles, We have the right to ask You for information and other data, as stipulated by relevant laws, including information about the source of Your income.
We collect and process Your personal data only in the following situations:
i) it is necessary to enter into an agreement on the provision of services (Client Agreement) in accordance with Your request and its subsequent execution; or
ii) You have given Us Your consent to the collection and processing of such data, including through acceptance of the terms of the Client Agreement and Privacy Policy when registering on the Website; or
iii) such collection and processing is necessary to comply with applicable legal requirements; or
iv) such collection and processing is due to Our legitimate interests, although We always strive to maintain a balance between Our legitimate interests and the confidentiality of Your personal data.
Please note that in many cases, if You do not provide the required information, We will not be able to provide You with the services You have requested.
2. How We use the information You provide to Us
2.1. The information We receive about You allows Us to provide quality services, develop Our existing services and create new ones.
2.2. Your data obtained using Cookies and similar tools ensures the functionality of the Website and improves the quality of the services provided.
2.3. The data collected when visiting the Website is necessary for the operation of the Stockity Trading Platform and its subsequent analysis, as well as to provide You with information in the most convenient way for You.
For example, such data allows to determine the appropriate language of the user interface and currency of the Stockity Trading Platform Account.
2.4. The data provided during registration and verification (including last name, first name, middle name (if any), gender, date of birth, citizenship and email address) are used to contact you and to provide you with the most accurate and personalized information.
In addition, the data obtained by Us during verification (including information from your bank documents) is necessary to ensure the legality and security of the Company’s services.
2.5. For Your convenience, We store the information You provide to Us when You fund Your Account on the Stockity Trading Platform, and fill it in automatically during Your next deposit (except for Your bank card number, expiration date and service code, and information related to security). Thus, You do not need to enter the data again. If this information changes, We will update it and delete the old data.
2.6. Information about Your financial and other activities on the Stockity Trading Platform, as well as information from web server reports, is used to protect Your funds and block fraudsters from accessing Your account.
2.7. We may use the information you provide, including your name, email address, and phone number, to send you system notifications and advertising materials via phone calls, text messages, and other methods not prohibited by applicable law.
You have the right to unsubscribe from the Company’s mailing list at any time by clicking on the "Unsubscribe" link in emails from the Company, by disabling the appropriate option in your personal account on the Website, or by contacting the Company’s Support Service. The Client has the right to unsubscribe from calls and text messages from the Company at any time by contacting the Company’s Support Service.
We are committed to promptly responding to your request to unsubscribe from all types of emails (except for transaction-related notifications), as well as not receiving calls and text messages.
2.8. From time to time, We may send you email notifications about changes in the operation of the Website or the terms of service provision.
2.9. In addition, We need your data to personalize the content of the Website and show you relevant advertisements.
2.10. The data you provide when contacting the Company is needed to determine the status of your request and provide a complete answer in the shortest possible time.
If We need to use the information provided for other purposes, We always ask for your consent.
In the event of automated processing of personal data, We ensure that such processing does not impact you.
3. Retention of Your Personal Data
We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.
Any personal data that We process for any purpose will not be retained for longer than is necessary for that purpose.
4. Your rights
4.1. Your main rights regarding your personal data are as follows:
(a) Right of access
This enables you to receive a copy of the personal data that We hold about you;
(b) Right to rectification
This enables you to correct any incomplete or inaccurate data that We hold about you; however, We may need to verify the accuracy of the new data that you provide to Us;
(c) Right to erasure
This enables you to ask us to delete or remove your personal data where there is no good reason for us to continue processing it;
(d) Right to restrict or object to processing
This enables you to initiate a suspension of the processing of your personal data;
(e) Right to withdraw consent
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
This list of rights is not exhaustive and may include other rights set out by applicable law.
Please note that your right to ask us to suspend or stop processing your personal data and/or delete it is not absolute and may be limited by applicable law, including (but not limited to) AML & KYC legislation.
In addition, exercising this right may serve in some cases as grounds for terminating the provision of services to you.
5. Transfers of your personal data
5.1. Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction, where the data protection laws may differ than those from your jurisdiction.
5.2. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
5.3. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to one organization or a country unless there are adequate controls in place, including the security of your data and other personal information.
6. Disclosure of your personal data
6.1. Your personal data may be disclosed for the following purposes:
- Business Transactions
If the Company is involved in a merger, acquisition, or asset sale, your personal data may be transferred. We will provide you with notice before your personal data is transferred and becomes subject to a different privacy policy.
- Law Enforcement
Under certain circumstances, the Company may be required to disclose your personal data if required to do so by applicable law or in response to valid requests by public authorities (e.g., a court or a government agency).
- Other Legal Requirements
The Company may disclose your personal data in the good faith belief that such action is necessary to:
• comply with a legal obligation; and/or
• protect and defend the rights or property of the Company; and/or
• prevent or investigate possible wrongdoing in connection with the use of the Stockity Trading Platform; and/or
• protect the personal safety of Our Clients; and/or
• protect against legal liability.
7. Information We Provide to Third Parties
7.1. We do not share your personal data with third parties that are not affiliated with your activity on the Website.
7.2. Any third party to whom We may transfer your personal data will process it on Our behalf and strictly in accordance with the terms, instructions and Privacy Policy of this Program.
Such third parties may include:
1) a limited number of Our employees and employees of Our affiliates;
2) professional auditors;
3) professional dispute resolution organizations;
4) payment systems;
5) Payment System Providers;
6) verification service providers;
7) service providers that significantly affect the performance and operation of the Stockity Trading Platform.
7.3. To verify you and your payment details, We engage Sum and Substance Limited, a company incorporated and registered in England, with registration number 09688671, to which We transfer the personal data provided by You.
For more information about the handling of personal data by Sum and Substance Limited, please visit their Privacy Policy: https://sumsub.com/privacy-notice
7.4. For promotional purposes, as well as for statistical purposes, We provide information that does not contain Your personal data as follows:
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data they collect to track and monitor the use of Our services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize ads from its own advertising network.
For more information about Google’s privacy practices, please visit Google’s Privacy & Terms webpage: https://policies.google.com/privacy?hl=id
7.5. Cloudflare
CloudFlare is a cloud service for transferring and storing information, including your personal data. In addition, the information is stored on servers in the European Union and the United States.
For more information about CloudFlare’s privacy practices, please visit CloudFlare’s Privacy webpage: https://www.cloudflare.com/privacypolicy/
7.6. Zendesk
Zendesk is a service (system) that tracks, prioritizes, and executes tickets assigned to requests. Therefore, if you contact Our Support Service, the Zendesk service has access to the personal data you provide upon request.
For more information about Zendesk’s privacy practices, please visit the Zendesk Privacy webpage: https://www.zendesk.com/company/agreements-and-terms/privacy-policy/
7.7. If you are the winner of Our promotion, We may provide Your first and last name, address and telephone number to the postal or courier service to deliver the prize to You.
7.8. We may also transfer information to countries outside the European Economic Area. The level of personal data protection in these countries may vary.
However, Our partners in such jurisdictions are always bound by contractual obligations to maintain an adequate level of protection for the data transmitted and We take all reasonable steps to ensure the confidentiality of the information You provide.
If the Company is involved in a merger and acquisition transaction, it may be necessary to transfer your personal data to Our subsequent partners, and We guarantee the confidentiality of such data.
7.9. With Your consent, We may provide information about You to companies, organizations, or individuals not listed in this Privacy Policy.
8. Protecting technical information
8.1. In order to ensure the security of the information You provide, We have implemented special rules and technical measures to protect such information.
8.2. We use the Secure Sockets Layer (SSL) encryption system for transmitted data. Thus, all operations carried out on the Website are well protected.
9. Password
9.1. When registering on the Website, You provide Your email address and set Your own password for Your Account.
9.2. We have no right to make changes to such data and cannot be held responsible for how you guarantee its confidentiality.
9.3. We ask you to immediately report any unauthorized or suspicious activity related to the use of your account.
10. Use of Our services by minors
10.1. The Website is an open source, but is not intended for use by persons under the legal age in accordance with applicable law.
10.2. If We find that a minor has provided or attempted to provide their personal information to register on the Website, We delete such information from the Company’s servers.
11. Changes
11.1. From time to time, we may make changes to this Privacy Policy, but the content of such changes will not limit Your rights in relation to Your personal data to a greater extent than is required by applicable law.
11.2. In the event of a change, the change shall be effective from the time the text of the changed Privacy Policy is posted on the Website, unless a different deadline is specified for the change to take effect. We will notify You of such changes by email.
11.3. If you do not agree to the revised edition of the Privacy Policy, We ask you to stop using the Website and block your Account through the interface in your Account or by contacting Our Support Service using the contacts listed in the Stockity Client Agreement, after previously withdrawing funds from your Account on the Stockity Trading Platform.
11.4. In the event of any discrepancy between the text of this Privacy Policy in English and the text in another language, the English version of the Privacy Policy shall prevail.
12. Contact
If you have any questions or would like to obtain additional information regarding the processing of your personal data, to learn what is being processed, or to withdraw your consent to such processing, you may contact us at: dataprotection@stockity.id.
Effective from January 1, 2024