1. General provisions.

1.1.The Privacy Policy (hereinafter referred to as “the Privacy Policy”) is integral part of the Agreement, concluding between on-line Trading Platform of “Mynteq Trade OÜ” as one side and the Client as another side (hereinafter referred to as “the Agreement”). Text of the Agreement fixed at following link
1.2. 1.2.The Privacy Policy shall regulate all and any relations and issues between the Parties of the Agreement concerning personal data, including collection, storage, processing and deletion.
1.3.All and any provisions of the Privacy Policy shall be corresponding to the provisions of the Agreement (as it integral part) and shall be obligatory to all and any Client concluding the Agreement.
1.4.Personal data proceedings shall be provided in accordance with the acting applicable Law of the Republic of Estonia and corresponding EU Directive.
1.5.The Privacy Policy can be changed in the same way as the Agreement, according the clause 10.2. of the Agreement.

2. Personal data.

2.1. Personal information and data (hereinafter referred to as “the Personal data”) shall be include the following:
a) all and any personal records given by the Client during registration procedure and to update questionnaire;
b) any information, documents, data having corresponding limitation status (assigned by Confider – transmitting person) as “confidential”, “commercial secret”, “trade secret”, “for official use only”, “restricted” etc. on condition that such status was marked and /or such status was informed to another party – recipient;
c) any commercial, financial, accounting, tax, banking, manufacturing, scientific research, design, know-how, technologies, access data information;
d) any other information, documents, data possessing and knowledge of which can give concrete benefit and privileges, having real or potential commercial value because of its unknown and absence of free legal access to it to third person.
e) telephone conversation and messages with the Client that the Platform has the right to record (as possible evidence to settling disputes).
2.2. Cannot be considered as the Personal data the following information, documents, data:

a) fixed (published) in official public accessible sources;
b) confirming relations between the Client and the Platform;
c) well-known;
d) received from third person without obligation to limit its disclosure or distribution.

3. The Personal data security.

3.1. The Platform shall take all necessary and reasonable measures to maximum protect and prevention the Personal Data of all Clients from unauthorized illegal access, receipt, copying, keeping, passing, disclosing, leak, using, changing, loss, deleting, destruction through any and all means and measures (consciously or accidental).
3.2. The Platform shall guarantee integrity of the Personal data, that corresponding permanence of the Personal data during keeping and use.
3.3. The Platform shall provide protection of the Personal data, received by the Client by the following system complex technical measures:

a) Services provided by “Mynteq Trade OÜ”.

3.4. The Client shall take all necessary and reasonable measures to maximum protect and prevention from unauthorized illegal access, receipt, copying, keeping, passing, disclosing, leak, using, changing, deleting, destruction, loss through any and all means and measures (consciously or accidental) all and any umpty security elements associated with the him (including but not limited to login name, static password, code, personal identification number, token, smart card, mobile phone, biometric characteristics – fingerprint, face ID etc.).
3.5. If any event, defined in the clause 3.4. of the Privacy Policy has been happened, the Client immediately (during same calendar day) shall inform the Platform in written about it. The Platform shall change to the Client corresponding security element during 1 (one) working day by suspend access to the Profile of the Client and by provide new /renewal security element.

4. The Personal data regime.

4.1. The Personal data shall not be disclosed or otherwise provided to the third person without obtaining of a previous written permission of another Party.
4.2. The Party wants to discloser the Personal data shall send to another Party notice with the following:

a) clear description of the Personal data for discloser;
b) name and details of third person – possible recipient of the Personal data;
c) aim an cause of disclosing the Personal data.

4.3. Person received notice, mentioned in the clause 4.2. of the Privacy Policy, during 5 (five) calendar days (starting next day of receipt) shall reply to requesting Party own position on disclosing of the Personal data: to allow disclosing or not. Ignoring such notice (not replying to the requesting Party on case of duly receipt of such notice) shall be considered as allowing to disclosure the Personal data fixed in this notice.
4.4. Notwithstanding the clause 4.3. of the Privacy Policy, the Parties can provide information to the third Party only for execution of the applicable law or execution of the legal requirements and decision of competent state, judicial, arbitral authorities and institutions. In this case, the Party is going to provide information shall inform another Party about such actions at least for 5 (five) calendar days in advance.
4.5. The Personal Data can be in on-line, electronic and material form.

5. Collection of the Personal data from third parties.

5.1. The Platform for execution the Agreement and for registration /update procedure shall have the right to receive necessary information about the Client / a person, who wants to became a client from publicly available source only in the following cases:
a)for performing KYC and /or AML applicable procedures;
b) when the Client didn’t submit renewed information;
c) when the Platform has reasonable doubt on accuracy, authenticity and completeness of information.
5.2. In any case of lack of information according the clause 5.1. of the Privacy Policy, the Company shall have the right on own decision to refuse register as Client / open Profile or to close Profile /terminate the Agreement with acting Client on conditions of 10 calendar days previous written notice.

6. The Personal data storage and deletion.

6.1. 6.1.The Platform shall keep and storage all received Personal data concerning all and every Client during all period of acting the Agreement with every concrete Client and over the next 2 (two) years (unless a longer period shall be provided by the applicable EU law) from the date of termination the Agreement.
6.2. The Platform shall keep and storage all received Personal data concerning all and every person who wants to became a Client and who didn’t became a Client during 6 (six) months (unless a longer period shall be provided by the applicable EU law) from the date of refusal such person to became a client.
6.3.After termination the Agreement and refusal the person to became a client, the Platform can provide information to the third Party only in case, providing in the clause 4.4. of the Privacy Policy.
6.4. After expiration of the periods, defined in the clauses 6.1. and 6.2. of the Privacy Policy, the Platform shall:

a) return all keeping Personal data to the related person; and
b) erase and delete from informational storage all Personal data concerning related person without possibility to renew or recovery.

7. Liability.

7.1. The Parties shall bear liability according the provision of the Section 8 of the Agreement for all and any consciously or accidental disclosing and leak of the Personal data as breach of the provisions of the Privacy Policy.
7.2. Using of the Personal data of one party by another party with aim to receive own (or for third associated person) profit, benefit or privileges or with aim to make harm, damages, loss or expenses shall be considered as breach of the provisions of the Privacy Policy and the Agreement.