Privacy Policy — Puma Broker

Puma Broker respects your privacy and is committed to protecting and respecting your personal data. This privacy policy aims to give you information on how we collect and process any personal data — i.e. information about a Client (as defined below) who is a natural person on the basis of which that Client can be identified (data) — in accordance with the applicable data protection legislation and best practice.

We strive to create the most secure infrastructure of any broker in the world. In this privacy policy we would like to tell why you can trust us with your data and rest assured that your data is safe.

It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing your data about you so that you are fully aware of how and why we are using your data.

In this Privacy Policy, unless the context otherwise requires, expressions defined herein shall have the meaning ascribed to them in the terms and conditions which can be found here: pumabroker.com/legal/terms.

Please note that this Privacy Policy is addressed to current and prospective Clients. If you are an [RAZÃO SOCIAL] employee, contractor or a third-party service provider, your personal information will be used in connection with your employment contract, your contractual relationship or in accordance with our separate policies which are available by contacting us at the contact details listed in the section Our Contact Details below.

If you are participating in our affiliate program and/or introducing broker program, we will process the data provided under our agreement with you to exercise our rights and perform our obligations under or in connection with the relevant agreement, and the term Client in this Privacy Policy shall be read to include the term affiliate and/or introducing broker (as applicable).

Who we are

Puma Broker is a brand operated by [RAZÃO SOCIAL], a company registered in [JURISDIÇÃO] with company registration number [Nº DE REGISTRO] having its registered address at [ENDEREÇO] ([RAZÃO SOCIAL] and/or Company). [RAZÃO SOCIAL] is the controller and responsible for the data of the Client disclosed to us in order to register for a Trading Account, Demo Account and/or to make use of any other services offered by [RAZÃO SOCIAL] through the website pumabroker.com (Website) (this term shall at all times include Website's desktop and mobile versions).

This Privacy Policy is issued on behalf of [RAZÃO SOCIAL], the company responsible for collecting and/or processing your data when you use the Trading Platform through the Website, either for a Trading Account or a Demo Account (Service). At [RAZÃO SOCIAL] we respect your privacy and we are committed to protect your data, which we collect, use and/or have access to.

The Company takes measures to implement advanced data protection policies and procedures and to update them from time to time for the purpose of safeguarding the Client's data and the Client's account. Your data is protected by the legal, administrative and technical measures that we take to ensure the privacy, integrity and accessibility of data. To prevent security incidents with your data, we use a mixed organizational and technical approach based on the results of annual risk assessment.

The Company shall not divulge any private information of its Clients and former Clients unless the Client approves in writing such disclosure, or unless such disclosure is required under applicable law or is required in order to verify the Client's identity, or it is required for [RAZÃO SOCIAL] to perform its contractual obligations under any agreement concluded with the Client. The Clients' information is processed only by the employees of the Company and/or trusted third parties which provide specific support services. All such information shall be stored on electronic and physical storage media according to applicable law.

Data usage

We may collect, use, store and transfer different kinds of data about you which we have grouped together as follows:

Identity Data includes first name, last name, and patronymic (if available), date of birth, gender, passport, ID, driver's number, and copy of photo.
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes bank account, payment card details and tax identification number (including but not limited to social security number, income tax identification number, national insurance number).
Transaction Data includes details about the transactions performed by you, details about payments, withdrawals, exchanges, trading history, profit, balance, deposit and withdrawal methods, and any other details in relation to the services you have made use of through our Website.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, and other technologies on the devices you use to access the Website and use of cookies stored on your device.
Profile Data includes your Client's account details, username and password, transactions made by you, your interests, preferences, feedback and/or information received through your interaction with us within the course of providing our services and survey responses.
Usage Data includes information about how you use the Website, products and services, registration date, account category, trading cluster, number of complaints, number of requests filed and IP history.
Marketing and Communication Data includes your preferences in receiving marketing from us and your communication preferences.
Special Categories of Data / 'Sensitive' Data includes details about your religious belief, annual income, biometric data and/or criminal convictions and offenses.
Conformity Data includes details about your education, employment status, trading experience, self-assessment test.
Banking Data includes details of the number of payment wallets and/or information of your bank card, including information of the issuing bank, card number, cardholder name, card expiration date, payment system, card validation code (CVV2 / CVC2), and photos of both sides of the bank card.
Data in KYC (Know Your Customer) includes identity document information, including copies of recently dated utility bills, identity card, passport, and/or driver's license.
Economic Profile Data includes details on occupation, purpose of investment, annual income, net wealth, expected annual amount of investment and sources of funds.
Location Data includes details on your actual location when interacting with our Website (for example, a set of parameters that determine regional settings of your interface, namely residency country, time zone, and the interface language).
Audio Data includes full voice recordings of calls that you receive from us or make to us.

(the above collectively referred to as Personal Data)

Aggregated Data includes statistical or demographic data for any purpose. Such data can be derived from your data but may not be considered personal data in law as it will not directly or indirectly reveal your identity. An example of such Aggregated Data could be that we aggregate your Usage Data to calculate the percentage of users accessing a specific website feature and/or services/product preference.

Notwithstanding the above, if [RAZÃO SOCIAL] combines Aggregate Data with data in a way that the end result can in any way identify the data subject, [RAZÃO SOCIAL] shall treat such combined data as data which will be treated as per the provisions herein contained.

Processing of your data is carried out by [RAZÃO SOCIAL] following the principles of lawfulness, fairness, transparency, and always adhering to the intended purpose of data processing, the principle of data minimization, accuracy, limited data storage, data integrity, confidentiality and accountability.

In general, [RAZÃO SOCIAL] collects and processes the Personal Data for any of the following reasons:

To perform its contract with you;
To comply with its legal obligations including without limitation to applicable anti-money laundering and terrorist financing laws and regulations (hereby referred to as Money-Laundering Law); and/or
To safeguard its legitimate interest.

The Client acknowledges that all or part of the data concerning the Client's account and related transactions will be stored by [RAZÃO SOCIAL] and may be used by the Company in case of dispute between the Client and the Company.

The Client is responsible for updating any data provided to us in case of any change. Although we will strive to keep your data up to date and review and inspect any information provided by you, we may not be able to always do so without your help. The Client acknowledges that [RAZÃO SOCIAL] holds neither commitment nor responsibility to the Client due to any aforesaid review or inspection of information.

How is your personal data collected?

We use different methods to collect data from and about you, including through:

Direct Interactions

You will provide to us your Identity, Contact and Financial Data online through the Website and/or by filling in online forms and/or by corresponding with us by emails or otherwise. Data may be submitted to us by you when you wish to:

Register for a Trading Account;
Register for a Demo Account;
Subscribe to our publications and ongoing updates;
Request marketing and promotions to be sent to you;
Enter a competition, promotion or survey; and/or
Give us feedback or contact us.

We require to collect the above data in order that we are able to (i) provide our services efficiently, (ii) comply with our ongoing legal obligations, including, inter alia, to prevent fraud and money laundering acts.

If you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during your relationship with us.

Automated Technologies or Interactions

When using our services, your device automatically transmits to us its technical characteristics. Locale (a set of parameters that determine regional settings of your interface, namely residence country, time zone and the interface language) is used for the purpose of providing you with the best possible service within our platform. Using the information about IP address, cookies files, information about browser and operating system used, the date and time of access to the site, and the requested pages addresses allows us to provide you with the optimal operation on our web application, mobile and/or desktop versions of our application and monitor your behavior for the purpose of improving the efficiency and usability of our Services.

We use web analytics tools to track performance of our website and marketing source of users by cookies in order to optimize our marketing costs and provide users with better experience. You may at any time request that we refrain from any such transmissions (to the degree this is possible and subject to any of our legal obligations) by sending your request to the support team using our details in the Our Contact Details section below using the registered email address you disclosed and registered with us through your Account. We will address your request within 30 business days.

About Cookies

A cookie is a small amount of data that often includes a unique identifier that is sent to your computer or device browser from a website's computer and is stored on your device's hard drive for tracking site usage. A website may send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows. When you visit our Website, our system automatically collects information about your visit, such as your Technical Data, including inter alia, your browser type, your IP address and the referring website.

Cookies stored may determine the path the Client took on our site and are used to anonymously identify repeat users of the website and what pages were most popular for Clients. However, the Company protects the Client's privacy by not storing the Client's names, personal details, emails, etc. Using cookies is an industry standard and is currently used by most major websites. Stored cookies allow the Website to be more user-friendly and efficient for Clients by allowing [RAZÃO SOCIAL] to learn what information is more valued by Clients versus what isn't. You can set your browser not to save any cookies of this website and you may also delete cookies automatically or manually. However, please note that by doing so you may not be able to use all the provided functions of our website in full.

Please see our Cookies Policy for further details.

Purpose for which we will use your data and on what legal basis

We process the aforementioned data in compliance with the applicable legislation as amended from time to time in order to (i) be able to perform our contractual obligations towards the Client and offer them the best possible service, (ii) provide our Services efficiently, (iii) comply with our legal obligations, including, inter alia, to prevent fraud and money laundering acts, and (iv) protect our legitimate interests and your vital interests.

We process all data based on the following legal bases:

For compliance with our legal obligations;
For the performance of our contractual obligations towards the Client;
For the purposes of safeguarding our legitimate interests, where your interests and fundamental rights do not override those interests; and/or
On the basis of your consent.

Indicatively we set out below a description of all the ways we plan to use your data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process the data for more than one lawful ground depending on the specific purpose for which we are using your data.

If you are an existing Client of the Website where we have a legitimate interest in communicating with you, or if you have given us your consent, we will collect and process your personal data to communicate with you in case of support and/or sending newsletters, push messages and calls to keep you in touch with our new features, news and events and the efficient provision of the full scope of our services. We will also use your data to send you marketing information regarding our services that we believe may be of interest to you via email or otherwise.

Our Website is not intended for children and we do not knowingly collect data relating to children. As we do not allow users under the age of 18 to use our services, we need to obtain your birth date in order to confirm the Client's age checks.

Opting out

If you do not want to receive any marketing newsletters or transmit your data to third parties for marketing purposes, you can configure your preferences. Such configuring can be done when (i) opening an account, (ii) when receiving such advertising content, or (iii) by logging in and going to My Account > Personal Details > Notification Settings. You may also send to the Company, at any time, an email to support@pumabroker.com using the registered email address you disclosed and registered with us through your Account asking the Company to cease from sending such advertising content or sending your data to third parties for marketing purposes. The aforesaid mark removal and/or email received by [RAZÃO SOCIAL] will oblige us to cease sending advertisement content to you within 7 (seven) business days.

Disclosure of data

We may share your data with the parties for the purposes set out above.

We require all [RAZÃO SOCIAL] affiliated and/or related companies and any third parties processing data on our behalf to respect your data and to treat it in accordance with the provisions of the General Data Protection Regulation and applicable local legislation as amended from time to time. We take all reasonable steps so that our third-party service providers do not use your personal data for their own purposes and only permit them to process your data for specific purposes and in accordance with our instructions.

In general, your data is used by the processors of [RAZÃO SOCIAL].

In addition, a transfer of your data to another legal entity may occur as part of a transfer of our business or parts thereof in the form of a reorganization, sale of assets, consolidation, merger or similar.

With regard to the transfer of data to recipients outside the related and/or affiliated entities of the Company, we note that we strive to maintain discretion with respect to client related matters and assessments of which we acquire knowledge. We may disclose data that concerns you only if (i) we are legally required to do so; (ii) when you expressly order us to process a transaction or any other service; (iii) it is required for the provision of our services under our contractual relationship; and/or (iv) protection of our legitimate interests and applicable legislation as amended from time to time.

External Third Parties

Your data is shared with third-party organizations/entities including but not limited to:

Service Providers. We may share your data with our trusted third-party service providers, who, on our behalf, operate, maintain and/or support our IT systems and IT infrastructure, our websites, manage our payment solutions, perform statistical analysis, marketing and advertising purposes, sending newsletters, provide customer support and perform other important services for us.
Other [RAZÃO SOCIAL] affiliates / related companies. We may also disclose your data to other [RAZÃO SOCIAL] affiliates and/or related companies in order for them to provide us with the relevant services.
State authorities. The Client's details that are provided and/or that will be provided by the Client during his/her activity on the site may be disclosed by the Company to official authorities. The Company will make such disclosure only if required to be disclosed by the Company by applicable law or court order and to the minimum required extent.
Other disclosures. In addition to where you have consented to a disclosure of the data or where disclosure is necessary to achieve the purpose(s) for which it was collected, data may also be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise or defense of legal claims.

Data retention

We store your data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting or reporting requirements. 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 your data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal, tax, accounting and other requirements.

We shall keep your data (including call recordings) during our contractual relationship and for a minimum period of 7 (seven) years from the date of termination of the Platform/Service used by the Client.

In general, all other data is stored for a period of 30 (thirty) business days after the date of termination of the provision of our services unless there is any other legal reason to keep it.

At the expiration of the data retention period, the data is erased by irreversible destruction and we also inform all third parties to whom the data was transferred regarding such erasure and request implementation of similar actions on their part.

Your rights and how to withdraw consents and unsubscribe

We ask you to provide us with true, accurate and updated information on your identity and not misrepresent yourself to be another individual or legal entity. Any changes in your identifying details shall be notified to the Company immediately and in any case no later than the 7th day from the date of such changes. If your data is incorrect or incomplete, please contact our support services at the contact details listed in the section Our Contact Details below in order to change your data.

Under certain circumstances, you have rights in accordance with applicable legislation and our policies as amended from time to time. Some of the rights are rather complex and include exemptions, thus we strongly advise you to contact us. You can find a summary of your rights below:

The right to access. You have a right to obtain the confirmation as to whether or not your data is being processed by us. In addition, you have a right to obtain more detailed information about the data kept and the processing undertaken by us and under certain circumstances the right to receive a copy of this data.
The right to rectification. You have the right to have inaccurate data about you rectified, and, taking into account the purpose of the processing, to have incomplete data completed.
The right to erasure. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please 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.
The right to restriction of processing. You have the right to request the restriction of processing of your personal data (a) if it is not accurate; (b) where processing may be unlawful but you do not want us to erase your data; (c) where you need us to hold the data even if we no longer require it; or (d) where you may have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
The right to data portability. To the extent the legal basis for the processing is your consent, and such processing is carried out by automated means, you have the right to receive your data in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others and/or in case it may be technically impossible to do so.
The right to object. Subject to the legal basis on which the processing activity is based, you may object to the processing of your personal data. Please note that in some cases, we may have compelling legitimate grounds to process your information which we need to comply with.
The right to withdraw consent. To the extent that the legal basis for the processing is your consent, you have the right to withdraw from that consent at any time. The withdrawal from your consent will in no event affect the lawfulness of processing based on consent before its withdrawal.
The right to complain to the data protection supervisory authority. We do our best to ensure that we protect your data, keep you informed about how we process your data and comply with the applicable data protection regulation. In case you are not satisfied, then we urge you to inform us in order for us to improve.

We try to respond to all legitimate requests within one month. Occasionally it could take longer if your request is particularly complex or you have made a number of requests. We may charge you a reasonable administrative fee for any unreasonable or excessive requests and for any additional copies of the data you may request.

Data security

We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you of a breach where we are legally required to do so.

Encryption of your data in transit. Encryption provides a high level of security and privacy for your data. When you enter your data in our platform we use strong encryption technologies (such as Transport Layer Security) to protect your data during transmission from your devices to our servers.
Protection of your data in our infrastructure. We make it a priority to develop services that are secure "by default". The "default" security of our services means that all new services and features are designed with strict security requirements in mind before we even begin development.
Threats protection. Our Company is highly knowledgeable about modern threats to data security and privacy, and we are well prepared to combat them. All events that occur in our infrastructure are continuously monitored, analyzed and responded to.
Employee awareness of data security. Our employees may handle your data in order to provide you with first-class service. To guarantee the security and confidentiality of your data, we monitor all employees' actions with access to your data and grant access strictly on a "need to know" basis.

Our contact details

If you have any questions about this privacy policy, including requests relating to the data, please contact our support team using the details set out below.

The entity responsible for your data processing is [RAZÃO SOCIAL] and you can contact us using the details set out below.

Address: [ENDEREÇO]
Email: support@pumabroker.com

To enable us to process your request, please contact us using the registered email address you disclosed and registered with us through your Account. We may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification.

Links to other websites

We may provide links to third-party websites in our Website. These linked websites are not under our control, and we therefore cannot accept responsibility or liability for the conduct of third parties linked to our websites, including without limitation to the collection or disclosure of your data.

Changes to this Privacy Policy

This Privacy Policy was last updated December 2023. We reserve the right, at our discretion, to add, modify or remove portions of this Privacy Policy in the future to ensure that the information herein provides relevant and adequate information about our collecting and processing of your data.

In case of updates, we will post the revised Privacy Policy on our website. Changes will take effect as soon as the revised version is made available on our website.