1.1. Ensuring the privacy and security of our clients’ and Website visitors’ personal and financial information is one of our top priorities. This Privacy Statement outlines how we gather and protect your information. By creating an account or using our Website, you consent to the collection and use of your personal information as detailed in this Privacy Statement.

1.2. Under the Data Protection Acts of 1988 and 2003, the data controller is Avan Trade (“we”, “us”, “our”).

2.1. We collect the necessary information to open an account, facilitate transactions, and protect your assets and privacy. This allows us to understand your needs and preferences more effectively.

2.2. The information we gather directly from you includes details required for communication, such as your name, mailing address, phone number, and email address, as well as information to verify your identity. Additionally, we collect demographic information when you open an account, such as your birth date, education, occupation, etc., along with transaction details. We also evaluate your trading experience, estimated annual income, and net worth to better understand your financial situation.

We use personal information solely for the purpose of delivering quality service and ensuring security. For instance, we may use the information you provide to verify your identity and contact details. This information also helps us create and set up your trading account, generate an account number and secure password, track account activity, and communicate relevant account information. Additionally, it allows us to enhance our services, personalize your browsing experience, and notify you about other products, services, or promotions that may be of interest to you.

We may share information with affiliates when it is necessary to provide the product or service you have requested or to give you the opportunity to engage with products and services offered by our affiliates. Additionally, we may form partnerships and alliances, including joint marketing agreements, with other companies that offer high-quality products and services potentially beneficial to our clients. To ensure that these products and services meet your needs and are delivered effectively, we may share some information with our partners, affiliates, and alliances. This helps them better understand which offers are most relevant and useful. The use of your personal information will be strictly limited to the purposes outlined in our relationship with the respective partner or affiliate.

5.1. All the information you provide to us is stored on secure servers. Payment transactions are encrypted using SSL technology. If we provide you with (or you choose) a password to access certain sections of our Website, you are responsible for keeping that password confidential. We advise you not to share your password with anyone.

5.2. Unfortunately, transmitting information over the Internet is not completely secure. While we make every effort to protect your personal data, we cannot guarantee the security of any data transmitted to our Website; such transmission is done at your own risk. Once we receive your information, we employ strict procedures and security measures to help prevent unauthorized access.

You have the right to request a copy of the information we hold about you. We may charge a fee for this, which will not exceed €5.00. You also have the right to access your data, correct any inaccuracies in the information we have about you, object to the use of your data, and block any specific uses of your data by submitting a written request to Iceberg Analytics Ltd.

If you choose to purchase a product or service from another company, any personal information you share with that company will no longer be governed by our Privacy Statement. We are not responsible for the privacy policies or content of external sites we link to and have no control over how your information is used or protected by those sites. When you choose to visit a co-branded Website or a linked site, you may be asked to provide registration or other information. Please be aware that the information you provide will be sent to a third party, and we recommend that you review their privacy policy before sharing any personal details.

8.1. We may use your data to inform you about our products and services that may interest you. We or our agents may contact you via mail or phone regarding these offerings.

8.2. If you are an existing customer, we will only contact you through electronic means (such as email, voicemail, or SMS) with information about goods and services similar to those you have previously purchased from us.

8.3. If you prefer not to have your data used in this manner, please select the relevant options when we collect your marketing preferences. You can update your preferences at any time by reaching out to a Client Services representative. An opt-out choice made by one account holder on a joint account applies to all account holders. You must make a separate opt-out request for each account you hold with us.

9.1. We use cookies to help secure your trading activities and improve the performance of our Website. Cookies are small text files sent from the Web server to your computer. The cookies we use do not contain any personal, account, or password information. They simply allow the site to recognize that the request for a page is coming from a user who has already logged in.

9.2. We may share Website usage data with reputable advertising companies to target our Internet banner ads on this and other websites. To do this, pixel tags (also known as clear gifs or web beacons) may be employed to track the pages you visit. The information collected by the advertising company through these pixel tags is not personally identifiable.

10.1. We do not sell, license, lease, or disclose your personal information to any third party for any reason, except as outlined below.

10.2. We reserve the right to disclose your personal information to third parties when required by law, regulatory authorities, law enforcement, or other government bodies, or when necessary to protect our rights or property.

10.3. To enhance our services, we may engage other businesses to assist with internal functions such as account processing, order fulfillment, client service, client satisfaction surveys, or other support and data collection activities related to our business. Information we collect from you may be transferred to, and stored at, locations outside the European Economic Area (“EEA”), including the United States. It may also be processed by staff outside the EEA who work for us or one of our suppliers. Additionally, we may provide client information to third parties from our database to assist us in analyzing client needs and informing clients about relevant product and service offerings. The use of this information is strictly limited to the task we request and for no other purpose. All third parties with whom we share personal information are required to protect it in a manner similar to how we safeguard it.

From time to time, we may update this Privacy Statement. If we make any changes, the updated Privacy Statement will be posted on our Website, and we will notify you of the changes through a notice on the Website. By continuing to use our Website, you agree to accept the revised Privacy Statement as notice to you. Any disputes regarding our Privacy Statement are governed by this notice and our Customer Agreement. We encourage you to periodically review this policy to stay informed about the information we collect, how we use it, and to whom we disclose it. If you have any questions that are not addressed in this statement, please contact a Client Services representative.