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Introduction

Exness Global Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you, and sets out the information that Exness Global Limited must provide to you for the purpose of the EU General Data Protection Regulation (“GDPR”) which is applicable as of 25 May 2018 and the law providing for the protection of natural persons with regards to the processing of personal data and for free movement of such data (Law 125(I) /2018). 

PRIVACY NOTICE

Important information and who we are

Purpose

This privacy policy aims to give you information on how Exness Global Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up and participate in the prize draw and drawings, and on delivery of the prizes should you become a winner. The prize draw is also open to children however the collection and use of children’s personal data is subject to parental/guardian consent.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Exness Global Limited, a Cyprus registered company, registration number 326879, with its registered office at 1 Siafi, Porto Bello, Office 401, 3042, Limassol, Cyprus, is the controller and responsible for this site, the prize draw and your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy team who is responsible for overseeing questions in relation to this privacy policy.

If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact our data privacy team at [email protected]

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. The new version of this policy will be available on the Company’s website.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, age and date of birth, and number of your ID, passport or residential number
  • Contact Data includes billing address, delivery address, email address and telephone numbers
  • Documentary Data includes information about you that are stored in different documents in various forms or copies of them, including things like your passport, identity card, driver license or Alien Registration Card, consent form, documents in regards to guardianship for the winner in case you are a minor
  • Vaccination details (Medical Data) includes without limitation confirmation from a General Practitioner and confirmation from Gesy and or copy of your Cyprus vaccination certificate, your EU Digital COVID Certificate and any other document which by law is regarded as right documentation for vaccination (for the winners only)
  • Video-recording Data includes voice, image and likeness and/or any interview statements from the winners in publication, advertising or other media activities (including the internet and television) (for the winners only)
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
  • Usage Data includes information about how you use our website.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to register you for the prize draw). In this case, we may have to reject your registration to participate but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal information by registering for the prize draw, filling in forms or by corresponding with us by post, phone, email or otherwise if you become a winner. This includes personal data you provide when you register for the prize draw, enter a competition, promotion or survey; or give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns, upon your consent. We collect this personal data by using cookies [server logs] and other similar technologies. Please see our cookie policy for further details.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract under the terms and conditions of the prize draw, we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
  • Where we require your consent.

By reading and agreeing to this Privacy Notice, you are giving us permission to process your personal data specifically for the purposes identified. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

Where our use of your personal information does not fall under one of the three Lawful bases above and we require your consent. Such consent shall be freely given by you and you have the right to withdraw your consent at any time by contacting us using the contact details set out in this Privacy Notice. If you decide to register your child for participation in the prize draw, we will require your parental consent. If we ask for your consent to use your child’s personal data, you can take back this consent at any time. Any use of your child’s personal data before you withdraw your consent remains valid.

If you withdraw your consent, we may not be able to enter you in the draw or verify and validate you as a winner. We will advise you if this is the case at the time you withdraw your consent. In that case, all processing operations that were based on your consent and took place before the withdrawal of the consent remains valid.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal 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 your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register as/a participant to the prize draw

(a) Identity

(b) Contact

 

Performance of a contract with you (term and conditions of the prize draw) as per art 6.1 (b) of the GDPR

 

 

To contact you, process and deliver your prize if you are a winner

 

(a) Identity

(b) Contact

 

(a) Performance of a contract with you (term and conditions of the prize draw)

(b) Necessary for our legitimate interests (to develop and promote the prize draw)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy (if applicable)

 

(a) Identity

(b) Contact

 

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to keep our records updated and to study how users use the prize draw)

To oversee and confirm the draws, verify and validate the winners

(a) Identity

(b) Contact

(c ) Documentary data

(d) Vaccination details (Medical Data)

(a) Necessary for our legitimate interests (to prevent fraud and running the prize draw and ensure delivery of the prizes)

(b) Performance of a contract with you

(c )Consent

 

To administer and protect the prize draw and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

 

(a) Technical

(a) Necessary for our legitimate interests (for running the prize draw, provision of administration and IT services, network security, to prevent fraud)

 

To use data analytics to improve our website, the prize draw, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of participants for prize draw, to keep our website updated and relevant, to develop our website and to inform our marketing strategy)

To present the results of the draws, to announce the winners and the prizes

(a) Identity

(b) Contact

(c) Video-recording Data

(a) Necessary for our legitimate interests (to prevent fraud and running the prize draw and ensure delivery of the prizes)

(b) Performance of a contract with you

(c ) Consent


Marketing and communication

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We shall ask for your consent for your name to be published in connection with announcing the winners and also for your picture, image, voice and a video to be taken and used for the purpose of announcement.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above. We require those parties who handle or obtain personal information to acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all relevant data protection laws and this privacy notice.

We may pass your personal data on to third-party service providers contracted to Exness Global Limited in the course of dealing with you, as well as sponsors, donors, car dealer, couriers for delivering of the prizes as applicable or posted on the website. We endeavor to disclose to these third parties only the minimum personal data that is required to perform their contractual obligations to us.

If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

The following third parties may receive your personal data for the purpose (s) set above as part of their processing activities:

 

 

Name

Address

Purpose

Deloitte Limited (as a Processor)

Maximos Plaza, Tower 1, 3rd Floor, 213 Arch. Makariou III Avenue, CY-3030 Limassol, Cyprus

Overseeing and confirming the prize draws, verifying and validating the winners 

 

Bolton Technologies Ltd (as a Processor)

195 Makarios III Avenue, CY-3030 Limassol, Cyprus

creating and hosting the prize draw’s website

 

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do not transfer your personal data outside the Republic of Cyprus.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected for, including the purpose of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider among others, the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data- you have the right to request a copy of the information that we hold about you
  • Request correction of your personal data- you have a right to correct data that we hold about you that is inaccurate or incomplete
  • Request erasure of your personal data- in certain circumstances you can ask for the data we hold about you to be erased from our records
  • Object to processing of your personal data- you have the right to object to certain types of processing such as direct marketing, automated processing and profiling
  • Request restriction of processing your personal data- where certain conditions apply to have a right to restrict the processing
  • Request transfer of your personal data- you have the right to have the data we hold about you transferred to another organisation
  • Right to withdraw consent- where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to enter you in the draw or verify and validate you as a winner. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected]

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contacting us about this Policy

If you have any queries about the content of this Privacy Notice, or wish to inform us of a change or correction to your personal data, would like a copy of the data we collect on you or would like to raise a complaint or comment, please contact us using the details set out below.

Full name of the Company: Exness Global Limited

Email: [email protected]

If you are not satisfied with our response to your complaint, you have the right to lodge a complaint directly with our supervisory authority, the Office of the Commissioner for Personal Data Protection (the “Commissioner”) details below:

Address:  1 Iasonos str., 1082 Nicosia
P.O.Box 23378, 1682 Nicosia,

Tel: +357 22818456
Fax: +357 22304565

Email: [email protected]

Further information is available on the Commissioner website at http://www.dataprotection.gov.cy

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