Privacy Policy

This Privacy Policy together with the Cookie Policy sets out the Data that we collect, use and otherwise process in connection with your use of the Site. The Data we process will depend on how you use our Site. The Site is not intended for children and we do not knowingly collect information relating to children.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice 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 the other notices and is not intended to override them.

The categories below describe the Data collected about you and the sources from which we collect.

Personal Identifiers

Sources: You.
Description:

• Personal information for individuals: first name, last name, country, country of tax residence, national identity number, birth date, contact details, bank details;
• Information about investing entities: [name, country, registration number, legal address, tax residency, bank details]; information about representative: [first name, last name, national identity number, country of tax residence, birth date, contact details]; details of beneficial owners owning more than 25% of the shares of the legal entity.
• Transactional information: records of payments made to and received from us, records of invested funds, investments, net annual return, and available funds;
• Information provided voluntarily by filling in forms on our Site, registering an account, contacting us through the “Contact Us” section on our Site (which may from time to time include requesting information from us or submitting comments) and/or when you meet with us.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Device and Online Identifiers

Sources: You; devices associated with you; third-party information providers.

Description: IP address; session ID (session start time).

Internet, Browser, and Network Activity

Sources: You; devices associated with you; third-party information providers.

Description: clickstream/online website tracking information; data related to user activity, e.g., browser visits, page views, visits, and unique visitors data; and cookies or other similar technologies.

Location Data
Sources: You; devices associated with you; third-party information providers.

Description: Region, country, and city

We collect and process information about you for the purposes of complying with our legal duties and for other legitimate purposes. We may use your Data, collected from direct interaction, automated forms and third parties to:

• Ensure that content from our Site is presented in the most effective, responsive and compatible manner for you and for your computer or device;
• Respond to your requests for information and other communication or correspondence you may submit to us;
• Provide you with general information on our Site and to provide you with personalized services;
• Provide marketing information and special offers with your consent;
• Enable you to log in to the Site and our web platform, using your email address, username and the password that you have chosen;
• Provide you with information about your registration or accounts;
• Provide you with the information or services that you request from us;
• Carry out statistical analysis, customer surveys and market research;
• Allow you to participate in interactive features of our Site when you choose to do so;
• Carry out activities necessary to the running of FEB, including systems testing, network monitoring, staff training, improving technical systems and IT infrastructure, and quality control;
• Notify you about changes to our Site, services or policies;
• Legal obligations and identity checks in order to comply with the applicable laws and international agreements;
• In order to conclude and execute a contract with the Client, ensuring the accuracy of the data by checking and updating internal and external data sources and to be able to fulfill the obligations of the contract between the user and FEB;
• For the interests of the client and/or FEB; and to know the quality of the services provided, and to provide evidence of commercial transactions and other commercial communication;
• To prevent the abuse of dishonest use of services and to provide the proper provision of services;
• To sanction and control the access to digital channels, to prevent unauthorized access and to ensure information security.

For some processing activities, we consider that more than one lawful basis may be relevant – depending on the circumstances.

The following are the basis for the processing of your personal data:

• It is necessary for the purposes of our contract with you or to take steps for entering into our contract with you;
• It is necessary to comply with our legal obligations;
• 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; and
• Consent, where the personal data relates to the person supplying it to us and has been supplied to us voluntarily.

We consider your Data to be private and confidential. From time to time, we may collect and share your Data with third parties, including third-party service providers or other entities. We may access and/or disclose your Data if required to do so by law or in good faith and belief that such action is necessary to: (a) conform with the law or comply with legal process served on us; (b) protect and defend our rights or property including, without limitation the security and integrity of our network and systems; or (c) act under exigent circumstances to protect the personal safety of users of our services or members of the public.

We may share your information with the following types of entities:

Service Providers:
We use third-party service providers who work for us in the provision of our services, for example, communications, marketing, IT service providers, verification agencies and other business support companies. In providing the services, your Data will, where applicable, be processed by the service provider on our behalf. Data disclosed for these purposes may include device and online identifiers, information about your internet, browser, and network activity, and location data.

Other entities related to legal process and emergency situations:
We may disclose your Data to third parties as permitted by, or to comply with, applicable laws and regulations. Examples include responding to a subpoena or similar legal process, protecting against fraud and cooperating with law enforcement or regulatory authorities. Data disclosed for these purposes may include device and online identifiers, information about your internet, browser, and network activity, and location data.

We keep your personal data for as long as it is necessary to do so to fulfill the purposes for which it was collected as described above, including for the purposes of satisfying any legal, accounting, or reporting requirements. This may mean that some information is held for longer than other information, for example, we may need to retain some Data for up to ten years. The criteria we use to determine data retention periods for personal data include the following:

• Local laws;
• Business obligations;
• Claims.

The following additional information will be of interest to you as a visitor to this Site:

“Cookies” are small text files that may be placed on your Web browser when you visit our Site or when you view advertisements we have placed on other websites. For more information about cookies, how our Site uses them, and your options with respect to their use, please see our Cookie Policy.

“Clickstream” data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by FEB itself, or by our service providers, using cookies, web beacons, page tags, or similar tools that are set when you visit the Site or when you view an advertisement we have placed on another website. Clickstream data and similar information may be shared internally within FEB and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with the Site; and as otherwise permitted by applicable law or regulation. This information may be processed by us for the purposes described above, or on our behalf by other entities, solely in accordance with our instructions.

This Site is not currently configured to respond to “do not track” signals or similar mechanisms.

Links to other websites

FEB may make available on this Site third-party applications such as content linking or sharing facilities or links to and from other websites and web platforms. Information collected by providers of such applications is governed by their privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those third-party applications.

We do not accept, and we disclaim, any responsibility for the privacy policies and information protection practices of any third-party website (whether or not such website is linked on or to the Site). These links are provided to you for convenience purposes only, and you access them at your own risk. It is your responsibility to check the third-party website's Privacy Policy before you submit any personal data to their websites.

Security

We will use appropriate technical and physical security measures to protect your personal data which is transmitted, stored or otherwise processed by us, from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access.

Access is only granted to Data on a need-to-know basis to those people whose roles require them to process your personal data. In addition, our service providers are also selected carefully and required to use appropriate protective measures.

As effective as modern security practices are, no physical or electronic security system is entirely secure. The transmission of information via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to the Site. Any transmission of Data is at your own risk. Once we receive your Data, we will use appropriate security measures to seek to prevent unauthorized access. We will continue to revise policies and implement additional security features as new technologies become available.

If you would like to contact us in respect of any element of this Privacy Policy, including, without limitation and subject to applicable law, where you wish to access a copy of your personal data or where you wish to raise a complaint or grievance, please contact us at [email protected].

We reserve the right to change this Privacy Policy at any time at our sole discretion. If we make changes to this Privacy Policy, they will be posted on the Site so that you are always aware of what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our Site after we post any such changes, you accept and agree to this Privacy Policy as modified.