1.1 Client - Means any natural or legal person who has entered into a client relationship with Dev Global LLC and is actively using, or has used, the services of Dev Global LLC until the termination of the client relationship. A prospective client is a natural or legal person who intends to use the services of Dev Global LLC and has made the initial registration for such use of services via the Trader’s Room (without concluding the client relationship)
1.2 Client Data - Means information that is known to Dev Global LLC about the client and that is processed by Dev Global LLC. When this document refers to ‘personal information’, it means information from which the client`s identity is reasonably apparent. The various categories of client data are specified in point 5 of this document.
1.3 Processing of Client Data - Means any action that is performed with the client data, including gathering, recording, structuring, safe keeping, changing, forwarding, deleting, archiving, etc.
1.4 Data Processor - Legal entities within Dev Global LLC Group. Dev Global LLC provides investment services and is the data processor of client’s personal information in relation to those services. In case a client holds trading accounts under multiple Dev Global LLC investment firms, there will be more than one Data Processor within the Group
1.5 Authorized Processor - Dev Global LLC may also use authorized external processors for client data processing, based on concluded service agreements, which are governed by instructions from Dev Global LLC for the protection of client related dat
2. Consent to Process Data
2.1 Initial registration - Dev Global LLC may also use authorized external processors for client data processing, based on concluded service agreements, which are governed by instructions from Dev Global LLC for the protection of client related dat
2.2 Cancellation of the initial registration - When a person cancels the registration process and does not complete it, that person ‘s data will not be retrieved by Dev Global LLC and will, therefore, not be saved for further processing in the future.
3. The Purposes of the Collection of Client Data
When a person cancels the registration process and does not complete it, that person ‘s data will not be retrieved by Dev Global LLC and will, therefore, not be saved for further processing in the future.
4.1 To form a profile. In order to comply with legal obligations, Dev Global LLC creates a profile about the client, once the full application for a Live trading account has been reviewed and approved by Dev Global LLC. Dev Global LLC needs to apply the principles of KYC (Know-Your-Client) before entering into a client relationship in order to prevent malicious actions, such as money laundering or terrorist financing, and also to perform other duties imposed by law.
4.2 To assess the level of a Client’s investment knowledge. Dev Global LLC must assess clients’ investment knowledge, experience and expertise to deem the suitability and relevance of the offered service for the client.
4.3 Internal business purposes and record keeping.Dev Global LLC needs to process clients’ personal information for internal business and record keeping purposes. Such processing is in Dev Global LLC’ own legitimate interests to comply with its legal obligations. This may include any communications that Dev Global LLC has with a client in relation to the services it provides. Dev Global LLC will also keep records that ensure that a client complies with its obligations, defined in the Terms of Business of a relevant Dev Global LLC investment firm.
4.4 Marketing. Dev Global LLC may use client data, such as location or trading history to deliver tailored content, such as news, analysis, research, reports, campaigns and training opportunities that may interest the client, to their registered email address. A client always retains the ability to change their preference if they wish or no longer wish to receive such communications.
4.5 Improvement of Dev Global LLC products and services. Dev Global LLC may, from time to time, use client data to help it analyse and improve its products and services.
4.6 To investigate or settle enquiries or disputes. - Dev Global LLC may need to use collected client data in order to comply with applicable laws, court orders, or other judicial process or requirements of any applicable regulatory authorities. Personal data can also be processed to settle disputes with the client.
4.7 To send client surveys. Dev Global LLC may send client surveys as part of its customer feedback process as it is in its legitimate interest to ask for feedback to ensure that it provide the best service to its clients.
4.8 Website data analysis. Please find detailed review about website data analysis from Dev Global LLC Cookie Disclosure.
4.11 Security. If a client enters into any Dev Global LLC premises, Dev Global LLC may record the client’s image on its cameras, for security purpose. Dev Global LLC may also use client details to keep a record of who has entered Dev Global LLC premises on any given day. It is in Dev Global LLC’ legitimate interest to do this to maintain a safe and secure working environment.
5. Categories of Client Data
If a client enters into any Dev Global LLC premises, Dev Global LLC may record the client’s image on its cameras, for security purpose. Dev Global LLC may also use client details to keep a record of who has entered Dev Global LLC premises on any given day. It is in Dev Global LLC’ legitimate interest to do this to maintain a safe and secure working environment.
5.1 Identification data – such as name, date of birth, personal identification code and data regarding the identification document (such as copy of the passport or ID card).
5.2 Contact data – such as physical address, email address, telephone number and language of communication.
5.3 Family data – such as information about the client’s family, heirs and other related person’s (only in cases if a client is related to a politically exposed person or the client has passed away).
5.4 Professional data – such as educational and employment details.
5.5 Financial data – such as income, assets and liabilities, collected in order to understand the client’s resources and trading activity (for the prevention of any illegal activity).
5.6 Data about the origin of assets or wealth – such as data regarding the client`s transaction partners and business activities (for the prevention of, for example, money laundering or the financing of terrorism).
5.7 Data that enables Dev Global LLC to perform its due diligence measures regarding the prevention of money laundering and terrorist financingand to ensure compliance with international sanctions, including the purpose of the business relationship, true beneficiaries and whether the client is a politically exposed person.
5.8 Data about the client’s tax residency – such as country of residence, tax identification number and citizenship.
5.9 Communication and activity data – such as visual and/or audio communication data recordings collected when the client visits any Dev Global LLC branches, including data related to the client’s visit to Dev Global LLC websites.
5.10 Data related to Dev Global LLC’ services – such as the performance data related to the services of the agreements or the failure thereof, executed transactions, submitted applications, requests, complaints and applied service fees.
5.11 Data about habits, preferences and satisfaction – such as data about preferences, satisfaction and activeness of using the services, services used, personal settings, survey responses, etc.
5.12 Data about participation in campaigns – such as the points gained and prizes won in games or campaigns.
5.13 Data about client’s classification category, level of expertise and previous exposure to the financial market– including the client’s investment knowledge and experience, investment objectives, etc.
6. Contacting Dev Global LLC by Email or Via Live Chat
When you email Dev Global LLC (via the ‘Contact Us’ page), or using the Live Chat feature, a person may be requested to provide some additional personal data, like their name or email address. Such data will be used to respond to their query and verify their identity. Emails are stored on Dev Global LLC’ standard internal contact systems which are secure and cannot be accessed by unauthorized external parties.
7. Recipients of Client Data
If necessary, client data is shared with other recipients, such as:
7.1 Authorities, such as law enforcement authorities, bailiffs, notary offices, tax authorities, supervision authorities and financial intelligence units.
7.2 Legal entities within Dev Global LLC Group. Dev Global LLC businesses are supported by a variety of the Dev Global LLC Group’s teams and functions. Dev Global LLC may make personal data available to them, if necessary, for the provision of services, trading platform administration, sales and marketing, customer and technical support. All Dev Global LLC employees are required to follow data privacy and security policies when handling personal data.
7.3 Institutions providing financial services, for example banks, payment systems, institutions participating in the trade execution, settlement and reporting cycle (for example regulated markets as execution venues, multilateral trading facilities, organized trading facilities, trade repositories, local and foreign brokers).
7.4 Auditors, legal and financial consultants, or any other processor authorized by Dev Global LLC.
7.5 Third parties maintaining registers (such as to credit registers, population registers,commercial registers, securities registers or other registers holding or intermediating client data).
7.6 Debt collectors upon assignment of claims, courts and bankruptcy or insolvency administrators.
7.7 Other persons related to the provision of services of Dev Global LLC, such as service providers of archiving and postal services.
7.8 Dev Global LLC may use other external authorized processors for processing client data. In such cases, Dev Global LLC takes the needed steps to ensure that such data processors process client data under the instructions of Dev Global LLC with adequate security measures.
7.9 9 Dev Global LLC may share client data in the event of a merge, sale, restructure, acquisition, joint venture, assignment, transfer or other disposition of all or any portion of Dev Global LLC’ business, assets or stock (including in connection with any bankruptcy or similar proceedings)
8. Client Rights
Dev Global LLC respects clients’ rights to access and control their personal data. Dev Global LLC will respond to requests concerning personal data processing and, when applicable, Dev Global LLC will give access to, correct or delete such personal data.
8.1 Dev Global LLC respects clients’ rights to access and control their personal data. Dev Global LLC will respond to requests concerning personal data processing and, when applicable, Dev Global LLC will give access to, correct or delete such personal data.
8.2 If the personal information Dev Global LLC holds concerning the client is inaccurate or incomplete, the client is entitled to have it corrected by Dev Global LLC. Dev Global LLC may request additional information and documentation required to validate the need for the requested change of data.
8.3 A client may ask Dev Global LLC to restrict the use of client data for marketing purposes. The client can change its preferences for receiving such notifications in the Trader’s Room, when choosing ‘Subscriptions’.
8.4 A client may ask Dev Global LLC to delete the personal data that it holds. The request to delete an individual’s personal data will result in the closure of their account(s), removal of their data from active processing and a termination of the client relationship. However, Dev Global LLC is required to maintain the client’s personal data to comply with its legal and regulatory requirements, as well as in accordance with internal compliance requirements in relation to the maintenance of records. Dev Global LLC shall preserve data for at least five years following the termination of the client relationship, unless other terms for the preservation of data or documents are prescribed by law. Unnecessary client data shall be deleted or destroyed.
9. Automated Decision-Making
If Dev Global LLC has made a decision about a client based solely on an automated process (e.g. through automatic profiling) that affects the client’s ability to use the offered services or has another significant effect on the client, the client may ask to not be made subject to such a decision unless Dev Global LLC can demonstrate to the client that such a decision is necessary for entering into, or the performance of, a contract between itself and the client. Even where a decision is necessary for entering into or performing any obligations arising from the client relationship, the client may contest the decision and request human intervention. Automatic decisions made by the data processing system, without participation of the client, shall be permitted only on the conditions and pursuant to procedures specified by law.
10.Organizational, Physical and IT Security Measures
Dev Global LLC ensures, within the framework of applicable laws, that client data is safeguarded with the appropriate technical and organizational measures to prevent unauthorized access, unlawful processing or disclosure, accidental loss, modification or destruction. Dev Global LLC shall implement the organizational, physical, IT and other necessary security measures to ensure the protection of Client Data and to monitor the processing of Client Data. Among other things, such security measures shall include the following activities:
10.1 Implementation by Dev Global LLC through its internal rules of the requirements for processing, registering and recording client data as well as procedures for checking the compliance with those requirements.
10.2 Authorization of Dev Global LLC employees to access only necessary client data in a client database, which is strictly in accordance with the job duties performed.
10.3 Imposing an obligation of confidentiality on Dev Global LLC employees responsible for handling client data
10.4 Unauthorized processing of data (including recording, alteration, deletion, reading, copying, (transmission), unauthorized transportation of records and any other unauthorized use of data (not prescribed by official duties) shall be prohibited
10.5 Adequate security measures, including encryption of data where necessary, shall be implemented upon transmission of data by means of data communication equipment or in the transport of records.
10.6 Every user of the client database shall be issued a personal means of authentication, enabling them to use the database.
10.7 Dev Global LLC shall implement adequate and sufficient measures to ensure that every data processing operation leaves a trace, which would afterwards enable identification of the person who performed the operation, the nature and time of the operation and any other relevant facts, including when, by whom and which data were recorded, altered or deleted, or when, by whom and which data in the data processing system were accessed, as well as information on any transmission of data. A possibility for restoring the content of the data before modifications shall be available when any modifications are made to the data or documents.
10.8 The personal information that the client provides in connection with registering itself as a user in the Trader’s Room is classified as registered Information. Registered Information is protected in many ways. Clients can access the Trader’s Room with their username (Client’s email) and password selected by the client. It is the clients’ responsibility to ensure that the login and password is known only to the client itself.
10.9 Transmission of information via regular email exchange is not always completely secure. Dev Global LLC however exercises all endeavors to protect clients’ personal data, yet it cannot guarantee the security of client data that is transmitted via email; any transmission is at the clients’ own risk. Once Dev Global LLC has received the client information it will use procedures and security features in an attempt to prevent unauthorized access.
11. Data Portability
The client has the right to obtain personal information held by Dev Global LLC, provided that Dev Global LLC has this in a structured, commonly used and machine-readable format, and to reuse it elsewhere or ask Dev Global LLC to transfer this to a third party of the client’s choice. In case of the forwarding of data to a third party, a clear written consent from the client must be received and verified
12. Contact Details
12.2 The general contact details of Dev Global LLC investment firms are available on Dev Global LLC website: www.Dev Global LLC.net, selecting the ‘Contact Us’ page
12.3 The client has the right go to court or to escalate their complaint to the data protection regulator in their jurisdiction for the protection of rights, unless the applicable laws prescribe a different procedure for handling such claims