Privacy Policy

At PIC INVESTMENT FINANCEE, we fully understand how important it is to protect our clients’ personal information. This document sets out our Privacy Policy commitment in respect to the information that we hold about our clients and what we do with such information. We recognise that any personal information we collect about the client will only be used for the purposes we have collected it for, or as allowed under the applicable acts of legislation. This Privacy Policy is a unified policy for the investment firms providing services under the PIC INVESTMENT FINANCEE trademark, belonging to the PIC INVESTMENT FINANCEE Group AS consolidation group. The investment firms within the PIC INVESTMENT FINANCEE Group consist of the following: PIC INVESTMENT FINANCEE AS, PIC INVESTMENT FINANCEE Ltd., PIC INVESTMENT FINANCEE Cyprus Ltd. and PIC INVESTMENT FINANCEE PTY Ltd. (jointly referred to here as “PIC INVESTMENT FINANCEE”).

PIC INVESTMENT FINANCEE respects the privacy of any user that accesses its websites, therefore, we are committed to taking all reasonable steps in order to safeguard information related to any existing or prospective clients, applicants or visitors. Before submitting any personal data, a person should examine the given terms and should only continue by agreeing with the Terms in the given Privacy Policy with principles set for data transfer, storage and processing.

PIC INVESTMENT FINANCEE is entitled to unilaterally amend the given principles at any time by notifying the clients no later than 14 days prior to any significant amendments via the PIC INVESTMENT FINANCEE website, emails or through the Trader's Room. In issues not regulated by the given Privacy Policy, the parties shall be guided by the General Terms and Conditions of a respective investment firm.

1. Definitions

1.1 Client - means any natural or legal person who has entered into a client relationship with PIC INVESTMENT FINANCEE and is actively using, or has used, the services of PIC INVESTMENT FINANCEE until the termination of the client relationship. A prospective client is a natural or legal person who intends to use the services of PIC INVESTMENT FINANCEE and has made the initial registration for such use of services via the Trader’s Room (without concluding the client relationship).

1.2 Client Data - means information that is known to PIC INVESTMENT FINANCEE about the client and that is processed by PIC INVESTMENT FINANCEE. When this document refers to ‘personal information’, it means information from which the client's identity is reasonably apparent. The various categories of client data are specified in point 5 of this document.

1.3 Processing of Client Data - means any action that is performed with the client data, including gathering, recording, structuring, safe keeping, changing, forwarding, deleting, archiving, etc.

1.4 Data Processor - Legal entities within PIC INVESTMENT FINANCEE Group AS. PIC INVESTMENT FINANCEE provides investment services and is the data processor of client’s personal information in relation to those services. In case a client holds trading accounts under multiple PIC INVESTMENT FINANCEE investment firms, there will be more than one Data Processor within the Group.

1.5 Authorised Processor - PIC INVESTMENT FINANCEE may also use authorised external processors for client data processing, based on concluded service agreements, which are governed by instructions from PIC INVESTMENT FINANCEE for the protection of client related data.

2. Consent to Process Data

2.1 Initial registration - In order to open a Live trading account with PIC INVESTMENT FINANCEE, a person must make an initial registration via an PIC INVESTMENT FINANCEE website’s registration form, or directly through their Trader's Room and agree with the terms listed in the given Privacy Policy. The Client confirms acceptance of these terms by ticking the corresponding box on the registration form. If such consent is not given, PIC INVESTMENT FINANCEE cannot process a person's data, nor provide any services to the person in question.

2.2 Attending courses and participating in campaigns - The client’s data will be processed when registering for the offered webinars or seminars, or when landing on any of PIC INVESTMENT FINANCEE’ campaign pages that require registration – as PIC INVESTMENT FINANCEE will need to use a client’s personal information to perform its services and comply with its obligations.

2.3 Cancellation of the initial registration - When a person cancels the registration process and does not complete it, that person’s data will not be retrieved by PIC INVESTMENT FINANCEE and will, therefore, not be saved for further processing in the future.

2.4 Declining the option to be contacted via phone - A person always has the right to request not to be contacted via telephone by an PIC INVESTMENT FINANCEE representative. This request will be saved within PIC INVESTMENT FINANCEE’ internal systems and acts as a separate restriction which PIC INVESTMENT FINANCEE will respect.

3. Subscription to Marketing Related Emails

3.1 During the initial registration to the Trader’s Room, a person has the right to choose whether or not to receive marketing related emails (such as company news, information about campaigns and other similar updates to enhance client knowledge related to the financial markets, etc.) to their submitted email address. Such a preference can also be changed at any time through the Trader's Room, under the ‘Subscriptions’ panel.

4. The Purposes of the Collection of Client Data

PIC INVESTMENT FINANCEE needs to collect various data in order to set a person up as a client, as well as provide various aspects of its services. This data is collected for the below mentioned reasons:

4.1 Verification of identity. PIC INVESTMENT FINANCEE is obligated to verify a person's identity before entering into a client relationship and creating a trading account for the person. For this, PIC INVESTMENT FINANCEE can use third parties which carry out identity checks on its behalf.

4.2 To assess the level of a Client’s investment knowledge. PIC INVESTMENT FINANCEE must assess clients’ investment knowledge, experience and expertise to deem the suitability and relevance of the offered service for the client.

4.4 Internal business purposes and record keeping. PIC INVESTMENT FINANCEE needs to process clients’ personal information for internal business and record keeping purposes. Such processing is in PIC INVESTMENT FINANCEE’ own legitimate interests to comply with its legal obligations.

4.5 Transaction reporting. PIC INVESTMENT FINANCEE is obligated to regularly report to the respective authorities on the market share products and the services held by client groups, as well as other financial figures.

4.6 Marketing. PIC INVESTMENT FINANCEE may use client data, such as location or trading history to deliver tailored content, such as news, analysis, research, reports, campaigns and training opportunities that may interest the client, to their registered email address.

4.7 Improvement of PIC INVESTMENT FINANCEE products and services. PIC INVESTMENT FINANCEE may, from time to time, use client data to help it analyse and improve its products and services.

4.8 To investigate or settle enquiries or disputes. PIC INVESTMENT FINANCEE may need to use collected client data in order to comply with applicable laws, court orders, or other judicial process or requirements of any applicable regulatory authorities.

4.9 To send client surveys. PIC INVESTMENT FINANCEE may send client surveys as part of its customer feedback process.

4.10 Website data analysis. Please find detailed review about website data analysis from PIC INVESTMENT FINANCEE Cookie Disclosure.

5. Categories of Client Data

Client data may be collected from the client, from the client’s use of the services and from external sources, such as public and private registers. Client data categories which are primarily collected and processed by PIC INVESTMENT FINANCEE consist of the following:

• 5.1 Identification data – such as name, date of birth, personal identification code and data regarding the identification document (such as copy of the passport or ID card).
• 5.2 Contact data – such as physical address, email address, telephone number and language of communication.
• 5.3 Family data – such as information about the client’s family, heirs and other related persons (only in cases if a client is related to a politically exposed person or the client has passed away).
• 5.4 Professional data – such as educational and employment details.
• 5.5 Financial data – such as income, assets and liabilities, collected in order to understand the client’s resources and trading activity (for the prevention of any illegal activity).
• 5.6 Data about the origin of assets or wealth – such as data regarding the client's transaction partners and business activities (for the prevention of, for example, money laundering or the financing of terrorism).
• 5.7 Due diligence data – data that enables PIC INVESTMENT FINANCEE to perform its due diligence measures regarding the prevention of money laundering and terrorist financing and to ensure compliance with international sanctions.
• 5.8 Data about the client’s tax residency – such as country of residence, tax identification number and citizenship.
• 5.9 Communication and activity data – such as visual and/or audio communication data recordings collected when the client visits any PIC INVESTMENT FINANCEE branches or websites.
• 5.10 Data related to PIC INVESTMENT FINANCEE’ services – such as the performance data related to the services of the agreements or the failure thereof, executed transactions, submitted applications, requests, complaints and applied service fees.
• 5.11 Data about habits, preferences and satisfaction – such as data about preferences, satisfaction and activeness of using the services.
• 5.12 Data about participation in campaigns – such as the points gained and prizes won in games or campaigns.
• 5.13 Classification & expertise data – data about client’s classification category, level of expertise and previous exposure to the financial market.

6. Contacting PIC INVESTMENT FINANCEE by Email or Via Live Chat

When you email PIC INVESTMENT FINANCEE (via the ‘Contact Us’ page), or using the Live Chat feature, a person may be requested to provide some additional personal data, like their name or email address. Such data will be used to respond to their query and verify their identity.

7. Recipients of Client Data

If necessary, client data is shared with other recipients, such as:

• 7.1 Authorities, such as law enforcement authorities, bailiffs, notary offices, tax authorities, supervision authorities and financial intelligence units.
• 7.2 Legal entities within PIC INVESTMENT FINANCEE Group AS. All PIC INVESTMENT FINANCEE employees are required to follow data privacy and security policies when handling personal data.
• 7.3 Institutions providing financial services, for example banks, payment systems, institutions participating in the trade execution, settlement and reporting cycle.
• 7.4 Auditors, legal and financial consultants, or any other processor authorised by PIC INVESTMENT FINANCEE.
• 7.5 Third parties maintaining registers (such as credit registers, population registers, commercial registers, securities registers).
• 7.6 Debt collectors upon assignment of claims, courts and bankruptcy or insolvency administrators.
• 7.7 Other persons related to the provision of services of PIC INVESTMENT FINANCEE, such as service providers of archiving and postal services.
• 7.8 External authorised processors under strict security instructions.
• 7.9 In connection with corporate mergers, acquisitions, or restructuring.

8. Client Rights

8.1 Review of client data processing. Upon request by the client, PIC INVESTMENT FINANCEE shall provide a review of the gathered client data which is available in its client database.

8.2 Correction of data. If the personal information PIC INVESTMENT FINANCEE holds concerning the client is inaccurate or incomplete, the client is entitled to have it corrected by PIC INVESTMENT FINANCEE.

8.3 Restrict processing. A client may ask PIC INVESTMENT FINANCEE to restrict the use of client data for marketing purposes.

8.4 Deletion. A client may ask PIC INVESTMENT FINANCEE to delete the personal data that it holds, subject to statutory retention periods of at least five years following termination of the client relationship as required by financial regulations.

10. Organisational, Physical and IT Security Measures

PIC INVESTMENT FINANCEE ensures, within the framework of applicable laws, that client data is safeguarded with appropriate technical and organisational measures to prevent unauthorised access, unlawful processing or disclosure, accidental loss, modification or destruction, including encryption, role-based access control, confidentiality obligations, and audit logging.

11. The Geographical Area of Processing

11.1 As a general rule, client data is processed within the European Union/European Economic Area (EU/EEA), with appropriate safeguards in place for any international processing.

12. Data Portability

The client has the right to obtain personal information held by PIC INVESTMENT FINANCEE, provided that PIC INVESTMENT FINANCEE has this in a structured, commonly used and machine-readable format, and to reuse it elsewhere or ask PIC INVESTMENT FINANCEE to transfer this to a third party of the client’s choice.

13. Contact Details

In case of questions about the content of this Privacy Policy, if an individual would like a copy of the data PIC INVESTMENT FINANCEE has collected on them, or would like to raise a complaint or other comment with regards to data processing, please contact PIC INVESTMENT FINANCEE’s Data Protection Officer via email at [email protected] or visit our Contact Us page.