Privacy Policy


Introduction

Welcome to U-Safe Trading Ltd’s privacy policy.

U-Safe Trading Ltd 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 (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. Important information and who we are

Purpose of this privacy policy

The registered office of U-Safe Trading Ltd is at Kalymnou 1, Office 602, 6037, Larnaca, Cyprus and we are a company registered in the Republic of Cyprus with Company number HE-392697.

This privacy policy aims to give you information on how U-Safe Trading Ltd collects and processes your personal data through your use of this website and what we do to ensure that it is kept private and secure.

U-Safe Trading Ltd gathers and processes your personal information in accordance with this privacy notice and relevant data protection legislation. It is important that you read this privacy policy as it provides you with the necessary information regarding your rights and obligations and how and why we are using and processing your data.

Controller

U-Safe Trading Ltd. is the controller and responsible for your personal data (collectively referred to as U-Safe Trading Ltd, we”, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy, please contact us using the details set out below.

Our full details are:

  • Full name of legal entity: U-SAFE TRADING LTD.
  • Email address: support@usafe-global.com
  • Postal address: Kalymnou 1, Office 602, 6037, Larnaca, Cyprus

You have the right to make a complaint to a Data Protection Authority about our collection and use of your personal data. If you are based in the European Economic Area (EEA), please contact your local data protection authority in the EEA.  If you are based outside the EEA, you have the right to lodge your complaint with the relevant Data Protection Authority in your country of residence.  If you have any questions, please contact us at support@usafe-global.com

 


Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated on 17 August 2020.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  1. 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, title, date of birth and gender.
  • Contact Data includes address, email address and telephone numbers.
  • Financial Data includes bank account details.
  • Technical Data includes internet protocol (IP) address, 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.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Usage Data includes information about how you use our website.
  1. 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 Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise or through face to face meetings, for example, at events you may attend. This includes personal data you provide when you contact us.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out:

Technical Data from the following parties:

  • analytics providers;
  • advertising networks; and
  • search information providers.
  • Identity, Contact, Financial and Transaction Data from our business partners and providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators
  • Identity and Contact Data from publicly available sources.
  1. How we use your personal data

We will only use your personal data where we have a legal basis to do so. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal obligation.
  • To efficiently manage our business relationships (including communication).
  • To inform you about our products and services.
  • Where you have given consent to the processing of your personal data.

Please see the glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

  1. Disclosures of your personal data

We may disclose your personal data to the parties set out below but only for the purposes detailed in clause 4 above:

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

  1. International transfers

We share your personal data within the U-Safe Trading Group. This will involve transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Information on the standard contractual clauses is available via this website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

A list of countries that have received an adequacy decision is available via this website: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.

  1. 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.

  1. 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 it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

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.

To determine the appropriate retention period for personal data, we consider 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.

In some circumstances you can ask us to delete your data: see “request erasure of your personal data” below for further information.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary find out more about the following rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at support@usafe-global.com

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.

  1. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time 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 provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.