ISA Bullion Privacy Policy

ISA COMMODITIES DMCC, a company incorporated in the Dubai Multi Commodities Centre, United Arab Emirates, with license number DMCC-31227 and whose registered address is at Unit No: ALMAS-39-B, ALMAS Tower, Plot No: JLT-PH1-A0, Jumeirah Lakes Towers, Dubai, United Arab Emirates, and its affiliate companies (“ISA Bullion“, “we“, “our“, “us“) respects the privacy rights of its online visitors, clients, and users of its applications ISA Bullion and ISA Bullion Pro (“you“, “your“, “yours“) and recognizes the importance of protecting the personal information collected about them.

Words with capitalised letters in this Privacy & Cookie Policy shall have the meanings as set out in the Terms and Conditions, which can be found here https://www.isabullion.com/account-terms-condition/ unless otherwise defined in this Privacy & Cookie Policy.

This Privacy & Cookie Policy, along with our Terms and Conditions describes how your personal information is collected, used, and shared when you visit www.isabullion.com (our Website), apply to create an Account with us or become our client or use our Web Application. This Privacy & Cookie Policy applies to personal information collected, stored or otherwise used by us.

By visiting or continuing to use the Platform, or by applying to create an Account with us, you are accepting and consenting to the practices described in this Privacy & Cookie Policy.

WHAT PERSONAL INFORMATION DO WE COLLECT FROM YOU?

The personal information that we collect includes but is not limited to, personal details such as name, address, date of birth, contact details, payment details, including credit card, debit card and bank account details, identity documentation and any other required ‘know your customer information’ or documentation or information required under applicable anti-money laundering legislation, and financial or other information necessary to provide the Services.

We may also collect your information in regard to your use of the Platform, such as the IP address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, and details of the operating system and platform that you use. Additional information that we may collect includes page response times, download errors, length of visits to certain pages on the Platform, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from pages on the Platform. We also collect technical information in relation to your use of your Account, including log-in and log-out frequency and times, trading activities and general page interaction and Account use.

WHEN AND HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect personal information about you in various ways including when you:

  • visit our Website or the Web Application;
  • apply for an Account (whether or not you finish and submit the application);
  • enter into a Trade Contract or make a Trade;
  • log into your Account and take any actions within your Account;
  • use or receive any Services provided by us;
  • send us any messages, emails or use any online chat function;
  • interact with any of our content or adverts on social media or generally online;
  • speak with our customer services team or other of our employees; or
  • interact in any way with our employees or authorized personnel.

We also collect information through third parties including, for example, credit reference agencies, fraud prevention agencies, banks, or other financial institutions, third-party authentication service providers and the providers of public registers.

From time to time, we may also request further information to help us improve our Services or comply with applicable laws and regulations.

MINORS

The Platform may not be used by any user under the age of sixteen (16) (“Minor”). Minors are also not permitted to open an Account with us or enter into any Contract or make any Trades with us.

We therefore do not seek any personal information (or any information at all) from or about any Minors and do not knowingly share or disclose information about Minors to third parties. If you have reason to believe that a Minor has provided us with information or information about a Minor has been provided to us, please contact us at contact@isabullion.com.

WHAT WILL YOU USE MY PERSONAL INFORMATION FOR?

We may use your personal information for the following purposes:

Necessary Administration of Accounts, Contracts and Trades. It will be necessary for us to use your personal information when you set up an Account or enter into any Trade Contract or make any Trades. It will also be necessary for us to use your personal information to administer your Account. Examples of such uses are as follows:

  • to receive and process your Account opening form and set up your Account.
  • to administer your Account with us;
  • to make Trades and receive associated payments from you;
  • to confirm any payments made, Trades executed and to provide reports to you;
  • to process and respond to any enquiries you have about our Services;
  • to audit your usage of our Services.

Legal or regulatory. We may use your personal information to comply with any legal or regulatory requirements on us such as:

  • responding to requests by government or law enforcement authorities or regulators conducting any investigation;
  • cooperating with government, taxation or law enforcement authorities or regulators on any information request;
  • complying with any applicable legislation;
  • combating money laundering and fraud.

For legitimate business interests. In some cases we may need to use your personal information for legitimate business reasons. Examples include:

  • monitoring your Trades and your general Account usage;
  • conducting market research, statistical and surveys and troubleshooting.

Marketing purposes. For example:

  • to send you information related to our products and Services, events and special offers, special promotional offers or initiatives;
  • to carry out business development including sending information about promotions and details of events.

Nominee Information: We will use your Nominee personal information in accordance with our Terms and Conditions. Please see our Terms and Conditions for more details.

Our methods of communication may include telephone, SMS, email, push notifications via our application, via social media, through our Services and or other means of direct and indirect communication that may allow us to reach you.

For further details on market communications, please see the section Marketing Opt-in and Opt-Out Provision below.

DO YOU SHARE MY INFORMATION WITH THIRD PARTIES?

From time to time it may become necessary for us to share your personal information with third parties. Examples include:

  • Where we use other companies to provide our Services, such as:
    • our technology partners who provide and administer our platform and application;
    • analytical partners whose software may carry out certain monitoring to improve our Services and assist with security;
    • customer services platform providers, such as WhatsApp;
    • payment providers;
    • debt collection agencies.
  • To our Affiliates;
  • Where it is necessary to provide the Services to you, for example to our partner banks and financing institutions;
  • In the prevention of money laundering and terrorist financing in compliance with any prevention of money laundering regulations and for the purposes of preventing any operation related to money laundering or terrorism financing, in which case we may disclose your personal information to any competent administrative or judicial authority;
  • If we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or if we are required to do so by a legal process. For example, to enforce our Terms and Conditions or for regulatory and reporting requirements to which we are subjected;
  • If we are acquired by any third party, in which case your personal information may be shared in the context of any sale or transfer of assets or any merger;
  • Where we employ third-party businesses to provide targeted marketing that is relevant to you. This is carried out through our third-party digital marketing providers. Where we undertake this kind of targeted advertising, digital advertising companies will only be able to see your email address if you already have an Account with them and they already have your address themselves;

We do not sell your details to any third-party marketing companies.

CROSS BORDER TRANSFERS

It may be necessary to transfer your personal data or information to our Affiliates and other third parties (as further detailed in the paragraph entitled “Do you Share my Information with Third Parties”) who are located outside of the country in which your personal data was collected. Where such transfers are to a country that does not provide an adequate level of protection in accordance with Applicable Law, we shall take such steps as are required under Applicable Law to ensure your personal data is safeguarded.

COOKIES

A cookie is a series of data characters that, when programmed into a website, is placed by the web server into the browser’s application folder on your computer. Once placed onto your machine, the cookie will allow the website to “recall” you as a unique individual. The Platform uses cookies to personalize information for certain segments of its customer base. In some instances, cookies are also used to associate individual customers with their information profiles where users have elected to create such a profile. For example, using cookies, the Platform can “recall” your user ID when you login to the Platform on your computer. Should you choose to do so, cookies can be removed from your hard drive and certain web browsers can be set so that cookies are not used or saved. Please check with your browser provider for more information on removing cookies.

Except where you have registered an Account with us, the log files and cookies do not allow us to determine the identity of the user. However, as noted above, this information may allow us to determine things like the URL of the website you visited before coming to this website, the type of browser or mobile device you are using to access the Platform, your IP address, language, approximate geographic location, and time zone. We, and/or our authorized third-party service providers may automatically collect this information when you access and use the Platform using electronic tools like log files and cookies. We use non-personally identifiable information to troubleshoot, administer the Platform and its services, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized third-party service providers to measure the overall effectiveness of our online tools, content, and programming.

You can delete cookies at any time. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

Information on deleting, rejecting or controlling cookies is available at https://www.allaboutcookies.org/. Please note that by deleting our cookies or disabling or rejecting future cookies you may not be able to access certain areas or features of the Platform, or certain functions may not work correctly.

If you use the Platform without deleting or rejecting some or all cookies, you agree that any cookies you have not deleted or rejected may be placed by us on your computer or on your device.

SAFEGUARDING YOUR PERSONALLY IDENTIFIABLE INFORMATION

We will take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the personal information you have provided to us.

Where possible and if required under Applicable Law, we use a Secure Socket Layer (SSL) encryption, which encrypts your information before it is sent to us, to protect it from unauthorised use.

In addition, we will take reasonable steps to ensure that third party business partners to whom we transfer any data will provide sufficient protection of that personal information in accordance with the applicable data protection laws

Data Retention and Deletion

We retain your personal information as long as necessary to provide the services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods mandated by law, contract, or similar obligations applicable to our business operations; for preserving, resolving, defending, or enforcing our legal/contractual rights; or for maintaining adequate and accurate business and financial records.

If you request to delete your personal information, please contact us at contact@isabullion.com, or you may use the account deletion form available on our website. We will endeavor to delete the information we hold about you unless we need to retain it for our legitimate business interests, such as preventing fraud or ensuring users’ safety and security. For instance, we may retain information to prevent someone who was banned for unsafe behavior from opening a new account.

Please note that legal and regulatory requirements obligate us to retain certain personal data for a minimum period after an account is closed. We are committed to deleting or anonymizing your personal data promptly after this period expires.

MARKETING OPT-IN AND OPT-OUT PROVISION

When you register on the Platform, apply for an Account (whether or not you finish and submit the application), or use the ‘Contact Us’ option on the Platform, we will collect your data and we may use it for sending you alerts or to remind you complete your Account application, for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest or one-off marketing promotions

We may send such marketing communications via phone, email, WhatsApp or SMS. By signing up for an Account you consent to us sending you marketing communications in this way.

If you would like to opt out of these communications, you can follow the ‘unsubscribe’ instructions on the communication or contact us on contact@isabullion.com. To stop receiving push notifications, please turn off push on your device. Please note that unsubscribing may not remove you from all communications because some communications are necessary for us to administer your Account with us.

CHANGES TO THIS PRIVACY & COOKIE POLICY

ISA Bullion reserves the right to amend this Privacy & Cookie Policy at any time with or without notice. Any changes will be posted on the Platform and we encourage you to check the Platform regularly. If you provide information to us, access, or use the Platform or your Account in any way after this Privacy & Cookie Policy has been changed, you will be deemed to have unconditionally consented and agreed to such changes. The most current version of this Privacy & Cookie Policy will be available on the web page at all appropriate times and will supersede all previous versions of this Privacy & Cookie Policy.

ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION

If you require further information about our Privacy & Cookie Policy or have any questions, comments or concerns or wish to know what personal information we hold about you, please contact us at contact@isabullion.com.

If for any reason you are concerned that the personal information held by us is not correct, you have the right to have this personal information changed or corrected. Should you wish to change or correct any personal information that we hold on you, please contact us at contact@isabullion.com. You can also change some of your personal information by logging into your Account and updating your profile.

THIRD PARTY SITES

The Platform and our Website may contain links to other unaffiliated third-party websites. We do not endorse or make any representations about third-party websites that are linked in the Platform or on our Website. This Privacy & Cookie Policy does not cover the personal data you choose to give to unrelated third parties.

COPYRIGHT

Copyright and other relevant intellectual property rights exist on all text relating to the Services and the full content of the Website and the Platform. Our logo is a registered trademark. We accept no liability direct or indirect from anyone misusing our logo or brand.