Endow Bull Trading respects your privacy and is committed to protecting your personal data. This privacy policy aims to give you information on how we collect and process any personal data and how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. i.e. information about a Client (as defined below) who is a natural person on the basis of which that Client can be identified (hereinafter the data) in accordance with the applicable data protection legislation and best practice. This version of the Privacy Policy takes effect on May 25, 2018.

We strive to create the most secure infrastructure of any broker in the world. In this privacy policy, we would like to tell you why you can trust us with your data and rest assured that your data is safe.

It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing your data about you so that you are fully aware of how and why we are using your data.

1. WHO WE ARE Endow Bull Trading, is a company registered in London, United Kingdom and having its registered address at Binary Solution is a product of Investment Solutions Limited incorporated in Mauritius (hereinafter Endow Bull Trading). Endow Bull Trading is the controller and responsible for the data of its Client disclosed to it in order to register for a Trading Account, Demo Account and/or to make use of any other services offered by the Endow Bull Trading Group (as defined in Appendix A) through the website (hereinafter “Website”) (this term shall at all times include Website’s desktop and mobile versions). Endow Bull Trading exercises control over the processing of data in undertakings affiliated to it and which belong to the Endow Bull Trading Group of companies.

This Privacy Policy addresses the privacy issues of the Endow Bull Trading Group so when we mention “Endow Bull Trading”, “Company”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Endow Bull Trading group responsible for collecting and/or processing your data when you use the Trading Platform through the Website, either for a Trading Account or a Demo Account (or their mobile/desktop versions) (hereinafter the Service(s)). In Endow Bull Trading we respect your privacy and therefore all companies within the Endow Bull Trading group are committed to protecting your data, which it collects, uses and/or has access to.

The Company takes measures to implement advanced data protection policies and procedures and to update them from time to time for the purpose of safeguarding its Client’s data and the Client account. Your data is protected by the legal, administrative and technical measures that we take to ensure the privacy, integrity and accessibility of data. To prevent security incidents with your data, we use a mixed organizational and technical approach based on the results of the annual risk assessment.

The Company shall not divulge any private information of its Clients and former Clients unless the Client approves in writing such disclosure or unless such disclosure is required under applicable law or is required in order to verify the Client’s identity or it is required for Endow Bull Trading to perform its contractual obligations under any agreement concluded with the Client. The Clients’ information is processed only by the employees of the Company and/or employees of the Endow Bull Trading group and/or trusted third parties which provide specific support services, dealing with the specific Client’s Accounts and necessary for the provision of our services. All such information shall be stored on electronic and physical storage media according to applicable law.

2. DATA USAGE We may collect, use, store and transfer different kinds of data about you which we have grouped together as follows:

Identity Data includes first name, last name, patronymic (if available), date of birth gender, passport, ID, Driver’s number, and copy of photo. Contact Data includes billing address, email address and telephone numbers. Financial Data includes bank account and payment card details. Transaction Data includes details about the transactions performed by you, details about payments, withdrawals, exchanges, trading history, profit, balance, deposited and withdrawal amount methods, and any other details in relation to the services you have made use of through our Website. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, and other technologies on the devices you use to access the Website and use of cookies stored on your device. Profile Data includes your Client’s account details, username and password, transactions made by you, your interests, preferences, feedback and/or information received through your interaction with us within the course of providing our services and survey responses. Usage Data includes information about how you use the Website, products and services, registration date, account category, trading cluster, number of complaints, number of requests filed and IP history. Marketing and Communication Data includes your preferences in receiving marketing from us and your communication preferences. Special Categories of Data/ ‘Sensitive’ Data includes details about your religious belief and/or criminal convictions and offences. Conformity Data includes details about your education, employment status, trading experience, and self-assessment test. Banking Data includes details of a number of payment wallets and/or information of your bank card, including information of the issuing bank, card number, cardholder name, card expiration date, payment system, card validation code (CVV2 / CVC2), and photos of both sides of the bank card. Data in KYC (Know your customer) includes identity document information, including copies of recently dated Utility Bills, Identity Cards, Passports, and/or Driver’s Licenses. Economic Profile Data includes details on annual income, net profit, expected annual amount of investment, and sources of funds. Location Data includes details on your actual location when interacting with our Website (for example, a set of parameters that determine regional settings of your interface, namely residency country, time zone, and the interface language) Audio Data includes full voice recordings of calls that you receive from us or make to us. (the above is collectively referred to as Personal Data) Aggregated Data includes statistical or demographic data for any purpose. Such data can be derived from your data but may not be considered personal data in law as it will not directly or indirectly reveal your identity. An example of such Aggregated Data could be that we aggregate your Usage Data to calculate the percentage of users accessing a specific website feature and/or services/product preference. Notwithstanding the above, if Endow Bull Trading combines Aggregate Data with data in a way that the end result can in any way identify the data subject, Endow Bull Trading shall treat such combined data as data which will be treated as per the provisions herein contained.

Processing of your data is carried out by Endow Bull Trading following the principles of lawfulness, fairness, transparency, and always adhering to the intended purpose of data processing, the principle of data minimization, accuracy, limited data storage, data integrity, confidentiality and accountability.

In general Endow Bull Trading collects and processes Personal Data, for any of the following reasons:

To perform its contract with you, To comply with its legal obligations including without limitation to applicable anti-money laundering and terrorist financing laws and regulations (hereby referred to as Money-Laundering Law), and/or To safeguard its legitimate interest The Client acknowledges that all or part of the data concerning the Client’s account and related transactions will be stored by the Endow Bull Trading and may be used by the Company in case of dispute between the Client and the Company.

The Client is responsible for updating any data provided to us in case of any change. Although we will strive to keep your data up to date and review and inspect any information provided by you, we may not be able to always do so without your help. The Client acknowledges that Endow Bull Trading holds neither commitment nor responsibility to the Client due to any aforesaid review or inspection of information.

3. HOW IS YOUR PERSONAL DATA COLLECTED? We use different methods to collect data from and about you including through:

Direct Interactions. You will provide us with your Identity, Contact and Financial Data online through the Website and/or by filling in online forms and/or by corresponding with us by emails or otherwise. Data may be submitted to us by you when you wish to:

Register for a Trading Account; Register for a Demo Account; Subscribe to our publications and ongoing updates; Request marketing and promotions to be sent to you; Enter a competition, promotion or survey; and/or Give us feedback or contact us. We require to collect the above data in order that we are able to (i) provide our services efficiently,(ii) to comply with our ongoing legal and regulatory obligations, including, inter alia, (a) to prevent fraud and money laundering acts and/ or (b) conduct the assessment of suitability and appropriateness test.

If you fail to provide the data when requested we may not be able to perform the contract we have or trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during your relationship with us.

Automated Technologies or Interactions. When using our services, your device automatically transmits to us its technical characteristics. Locale (a set of parameters that determine regional settings of your interface, namely, residence country, time zone and the interface language) is used for the purpose of providing you with the best possible service within our platform. Using the information about IP address, cookies files, information about the browser and operating system used, the date and time of access to the site, and the requested pages addresses allows us to provide you with the optimal operation on our web application, mobile and/or desktop versions of our application and monitor your behaviour for the purpose of improving the efficiency and usability of our Services. We use web analytics tools to track the performance of our website and marketing source of users by cookies in order to optimize our marketing costs and provide users with better experiences. You may at any time request that we refrain from any such transmissions (to the degree this is possible and subject to any of our legal obligations) by sending your request to the DPO using our details in the OUR CONTACT DETAILS below. We will address your request within 30 business days.

About Cookies.

A cookie is a small amount of data that often includes a unique identifier that is sent to your computer or device browser from a website’s computer and is stored on your device’s hard drive for tracking site usage. A website may send its own cookie to your browser if your browser’s preferences allow it, but, to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows. When you visit our Website, our system automatically collects information about your visit, such as your Technical Data, including inter alia to, your browser type, your IP address and the referring website.

Cookies stored may determine the path the Client took on our site and used to anonymously identify repeat users of the website and what pages were most popular for Clients. However, the Company protects the Client’s privacy by not storing the Client’s names, personal details, emails, etc. Using cookies is an industry standard and is currently used by most major websites. Stored cookies allow the Website to be more user-friendly and efficient for Clients by allowing Endow Bull Trading to learn what information is more valued by Clients versus what isn’t. You can set your browser not to save any cookies of this website and you may also delete cookies automatically or manually. However, please note that by doing so you may not be able to use all the provided functions of our website in full.

Please see our cookies policy for further details.

4. PURPOSE FOR WHICH WE WILL USE YOUR DATA AND ON WHAT LEGAL BASIS We process the aforementioned data in compliance with the applicable legislation as amended from time to time in order to (i) be able to perform our contractual obligations towards the Client and offer them the best possible service, (ii) provide our Services efficiently, (iii) comply with our legal and regulatory obligations, including, inter alia, (a) to prevent fraud and money laundering acts and/ or (b) conduct the assessment of suitability and appropriateness test, and (iv) protect our legitimate interests and your vital interests.

We process all data based on the following legal basis:

For compliance with our legal and regulatory obligations; For the performance of our contractual obligations towards the Client; For the purposes of safeguarding our legitimate interests and your interests and fundamental rights do not override those interests; and/or On the basis of your consent. Indicatively we set out below, a description of all the ways we plan to use your data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process the data for more than one lawful ground depending on the specific purpose for which we are using your data.