We should state that our privacy mentioned above policy applies to the processing activities of data control entities within the LSA Trading group of companies.
COLLECTION AND STORAGE OF PERSONAL INFORMATION
The personal information requested by our investors and potential investors serving within our company is as follows:
• Name, surname and contact information
• Date of birth and gender information
• Data on income and wealth status, including details on assets and liabilities, account balances, transaction postings, tax, and financial statements.
• Job and employment details
• Location information
• Data and experience in trading, risk tolerance, and risk profile
• Data on I.P. address, device details, and business experience
• Bank account, e-wallet, and credit card data
• Details of visits to the LSA Trading site or LSA Trading application, traffic information, location information, weblogs, and other contact information
• Products that you trade with LSA Trading Company
• Previous time data on your investments and investments include the amount you invested
• If the investor who makes the choices made on behalf of the selected products and services signs a new account to open or a new account, the investor must be able to understand the law in advance. Anti-money laundering laws require us to view and store the details (photographs and non-photographic documents) of the specified materials to present the standards set within the rules, as mentioned earlier. Identity documents required by money laundering laws or other legislation for the services we offer include the following:
• Driver's license;
• National identity document (if available);
• Electricity bills;
• Trust certificate (if available);
• A credit check on the individual; or
• If you are a corporate investor, we need to collect additional information such as company addresses, shareholders, directors, officers, including additional personal information about shareholders and directors. We have the right to request additional data required to complete legal and regulatory requirements. For the mentioned data; We have our websites with different possibilities by using our account opening applications, demo registration forms, webinar registration forms, website cookies, and tracking technologies included in our website. We have the right to access the data we have mentioned here to our investors. Third-party marketing lists you purchase from third parties, public sources, social media platforms, brokers and affiliates, bankers and credit card processors, subscription-based intelligence databases, and other third parties. We may request other personal data from time to time at our discretion. (for example, through market research, surveys or special offers). If you do not want to fulfil what we deem necessary to respond to your request for a selected product or service, you may not receive the product or service you want. In addition to the services we offer to the user and our relationship with the user, we can store all communications made during the services we provide to the user electronically, by phone, or in any other way. These records will only be available in our company and provide evidence of communication between the company and the investor. Such telephone conversations can record without a warning tone, direct or indirect warning. In addition to this, you can visit a place you want from our offices or facilities and meet the CCTV system that can record your picture.
How and With Whom Do We Share Your Data?
If necessary situations are determined, we can only share information of users with the following institutions:
• Companies that are included in the LSA Trading group and meet other opportunities in this direction;
• Applications of LSA Trading Company used by third parties, third-party application providers where communication systems and trading platforms used;
• Administrative, I.T., analytics and online marketing optimization, financial regulatory, compliance, insurance, research or service providers, and specialist consultants who work under contract to provide other services;
• Brokers with whom we have mutual relations and persons who provide promotional services to their associated organizations;
• Institutions providing payment services and banks which performing transactions;
• Auditors, consultants or contractors who audit any of our business purposes also Agreements with the courts, courts and competent courts, which are determined by the law and with the authorities making the relevant regulations, or with government agencies and law enforcement agencies that make other legal regulations when required by law;
• A third party to whom such assessments made to make or enforce the Terms of Service or other said agreements;
CONSENT OF THE INVESTOR
We may process your personal information with the reasons and purposes determined by our company, or in the name of legal action. The legally defined situations are as follows:
• Fulfilling contractual responsibilities towards the investor
• To comply with legal and regulatory conditions
• Protecting our legitimate interests
The investor's consent must take for the use of the personal information of our investors in violation of one of these three rules. The investor should give this permission with free will.
MANAGEMENT OF PERSONAL DATA
The data protection measures we apply are as follows:
• Our employees dealing with personal information are trained according to security measures that require them to use two-factor authentication with a password when accessing investor information and our system. In these security measures, Chinese walls are in place, and our employees can only access the personal data necessary for their role.
• Data encryption technologies are using during data transfer in internet transactions.
• There are firewalls against unauthorized persons and viruses entering our system, Client access codes are used that are transferred between networks using intrusion detection systems and virus scanning tools.
• When sending electronic data for outsourcing purposes, private, secure networks or encryption used, also a clean desk policy applying in all facilities that are institutionally kept by us and all related institutions and provide secure storage for physical records.
• Physical and electronic devices such as access cards, cameras, and guardian programs are used to protect against unauthorized access.
Storage Period of Personal Information
Although not valid in all circumstances, the rights of investors are as follows:
• Request access to personal data (commonly known as "data subject access request")
• To request the correction of the personal data you have provided to us;
• To request the deletion of personal data, we may not always comply with the request of the investor for specific legal reasons that will notify him/her. In case the investor feels uncomfortable with the processing of his / her data on the grounds which we are dependent or thinks that it will affect him/her, he/she can notify us within the scope of his / her fundamental rights and freedoms. The investor also has the right to object to where we process his / her data for direct marketing purposes. In some cases, we may show that we have legal grounds for processing information that invalidate their rights and freedoms. In the scenarios below, Investors may request us to suspend the processing of their data.
• To request limitations on the processing of their data.
• When an investor asks us to determine the accuracy of the data
• Where the use of information is unlawful but does not want us to delete it
• Unless it is needed to constitute, exercise, or defend legal claims or we are required to keep this information, the investor can tell where we should keep the data
• When the investor objects to our use of their data. However, we need to verify if it invalidates legal reasons to use it.
• To request the transfer of personal data to him/her or a third party. We will present their data to the investor or a third party of their choice in a structured, commonly used, and machine-readable format.
• The investor should note that this right only applies to automated information (e.g., not
for hard copies) that we have consented to use for him/ her or where we use the information to
enter into a contract with him/ her. The investor should know that this right is valid under the
following conditions: Information that he/she consents to use only for himself/herself or
automated information (for example, not for hard copies) we use to contract with him/her
If you do not want your personal information to be processed, you can request us to withdraw your consent.
Investor complaints and requests
We try to respond to all requests within 1 (one) month. If the investor's claim is complicated or extra, our response time may take longer than 1 (one) month. In this case, we inform our investor within 1 (one) month from the receipt of the request and keep the situation updated. We may charge a reasonable fee when a claim is unfounded, excessive or repetitive, or when we receive an offer to provide more copies of the same data. In this case, we will submit a request for a fee before processing the investor's demand; if he/she approves, the transaction will proceed. Alternatively, we may refuse to comply with the investor's request in these cases. If the investor is not satisfied with our response to his/her complaint; if he/she is the investor of LSA Trading Limited, he/she has the right to file a complaint with the Information Commissioner's Office (ICO). If he/she is an investor in any of the remaining LSA Trading assets, alternatively, he/she has the right to complain to the data protection authority of his country of residence.