Who are we?

Say Trade 22 Ltd administers and maintains an online platform for sharing and accessing information, news, statistics, tips regarding Forex trading and investments, as well as financial consultations.

  1. In order to provide you with our Services, we need to collect personal information for you. In each case, we are committed to ensuring that the information we collect and use is appropriate for that purpose and does not constitute an invasion of your privacy.

1.1. The personal data we need to process for you is as follows:

Personal data type:

Name and Family name

Phone number

Telegram profile information

Bank account number (IBAN)

Names of bank account holder

IP Address

Website traffic information

Personal data type:

Data subject

Data subject

Data subject

Data subject

Data subject

Generated upon visiting the website

Generated upon visiting the website

1.2. On our website, we use cookies, which are small files that are downloaded to your computer to improve your experience as a user of the website. You can find out more on our https://saytrade22.com/legal/cookies-policy. ‍

1.3. The personal data we collect will be used for the following purposes:

  • Providing access to the platform through the Website.
  • Provision of consultancy services.
  • Subscribing for to information and advice related materials regarding investments, trading, Forex via Telegram.
  • Personalizing and improving user experience, user communication.
  • Marketing, advertising and newsletters if you have explicitly subscribed to them. In this case, you can unsubscribe at any time.
  • Responding to Website enquiries.
  • Billing and accounting.
  1. Our legal basis for processing for the personal data:
  • Processing is necessary for the performance of a contract to which the data subject is already a party or in order to take steps at the request of the data subject prior to entering into a contract;
  • Data subject’s consent
  • Executing a legal obligation
  • In some cases, for the purposes of the legitimate interests pursued by us as a Controller.
  1. Any legitimate interests pursued by us, or third parties we use, are as follows:
  • To improve the customer service, the content and features of our website according to the interests of our users and.
  • To ensure and improve customer satisfaction.
  • To avoid legal disputes or defend our rights in the occurrence of such.

2. Consent

Where the processing of your personal data is not necessary for the performance of a contract, legal provision, legitimate interest of the Controller, Consent is required for Say Trade 22 Ltd to personal data, but it must be explicitly given. By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

You may withdraw consent at any time by deleting the information (in case of it is part of your personal profile) or you can ask us to do so by sending us an e-mail.

3. Disclosure

3.1. Say Trade 22 Ltd will pass on your personal data to third parties. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities.

Third party name

Google Analytics

Personal data category

Website traffic information and IP address

Purpose

Анализ на поведението на клиентаAnalysing customer’s behaviour

4. Transfers of data in third country:

Occasionally, Say Trade 22 Ltd will have to transfer your personal data to third countries. In such cases appropriate data protection safeguards will be taken.

Third parties (outside EEA) / international organizations

Google Inc. (USA)

Appropriate data protection safeguards

EU’s Standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679

5. Retention period

Say Trade 22 Ltd will retain your personal data as follows

Personal data

Data necessary for the performance of contractual obligations or the conclusion of a future contract (Name and Family Name, Email address, Phone number, Telegram profile, IBAN, IBAN holder’s name)

Billing and accounting

Website traffic data (Google AdWords, Google Analytics)

Direct marketing data

Retention period

The data shall be kept for the period of performance or termination of the contract – termination of registration; upon termination and liquidation or bankruptcy of one of the parties of the contract; by mutual agreement of the parties in writing; unilaterally by notice from either party in the event of failure of the other party to perform its obligations; in the event of objective impossibility of either party to the contract to perform its obligations; 5 years thereafter, if necessary for tax purposes, defence of claims, responses to complaints.

Until the execution of the financial operation and 10 years later

Until cookies and other tracking technologies are deleted from data subject’s browser

Until the data subject’s consent is withdrawn.

6. Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Say Trade 22 Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below. Right to judicial review: in the event that Say Trade 22 Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

7. Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Say Trade 22 Ltd, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Say Trade 22 Ltd’s data protection representatives

The details for each of these contacts are:

Contact Name:

Address line 1:

Email:

Telephone:

Supervisory authority contact details

Commission for personal data protection

1592 Sofia, 2 Professor Tzvetan Lazarov Boulevard

+359291-53-518

GDPR Owner contact details

Georgi Vasilev Aleksandrov

5G prof. Mihail Andreev street, Sofia, Bulgaria

0899147155

8. Frequently asked questions

How will Say Trade 22 Ltd use the personal data it collects about me?

Say Trade 22 Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Say Trade 22 Ltd is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Say Trade 22 Ltd contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.

Can I find out the personal data that the organisation holds about me?

Say Trade 22 Ltd at your request, can confirm what information we hold about you and how it is processed. If Say Trade 22 Ltd does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Say Trade 22 Ltd or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What identification will I need to provide to access information about my personal data?

In cases where you are unable to contact us via the contact details you have left (e-mail or telephone), SAY TRADE 22 Ltd accepts the following identification documents when information about your personal data is required: Personal ID card, driving license.

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