This policy is the property of Aeron. The reproduction in whole or in part in any way including the reproduction in summary form, the reissue in a different manner and any changes in the original manual or any translated version is strictly forbidden and is only allowed with the prior written consent of Aeron.trade.
As part of our day-to-day business we need to collect personal information from our customers and potential customers to ensure that we can meet their needs for a range of financial services and provide them with information about our services.
Your privacy is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals. This policy outlines how we manage your personal information supplied to us by you or a third party in connection with our provision of services to you or which we collect from your use of our services and/or our app(s) or website(s). It also details your rights in respect of our processing of your personal information.
All personal data is:
Information collected by us
In the course of your registration as a client for a demo or live account with AERON or filling any other form on our Website, subscribing to our services, news or offers, marketing communications or posting material, the following information about you (“Your Data”) will be collected and stored for administrative, service related and/or legal purposes.
We will limit the collection of personal information to what is necessary to administer our business and carry out our regulated activities in an effort to provide you with superior service.
Information that you provide to us directly:
However, the meaning of data ‘provided to’ AERON is not limited to this. It is also personal data resulting from observation of your activities (eg where using a device or service). This may include:
Your e-mail address may be used by AERON in relation to its products and services (including any marketing campaigns related to these products or services). If you do not wish to receive such marketing material and marketing communications, you can opt-out at any time by clicking on ‘unsubscribe’ or by sending an email stating so to email@example.com
Personal Data We Collect
If you are an actual or potential customer, we may collect the following types of information about you:
We obtain this information in a number of ways through your use of our services or other dealings with us including through any of our websites, apps, the account opening applications, our demo sign up forms, webinar sign up forms, subscribing to news updates and from information provided in the course of ongoing customer service correspondence. We may also collect this information about you from third parties either through bought-in third party marketing lists, publicly available sources or through our refer a friend scheme.
We also keep records of your trading behaviour, including a record of:
|Personal information such as gender, name, date of birth and address||To meet our anti money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. To verify your identity using our verification processes.|
|Contact information (email address and phone number)||In order to send you correspondence in relation to the services provided and to fulfil our regulatory and compliance obligations|
|Employment information, financial information, relevant education and trading experience||In order to comply with KYC obligations and in order to meet our regulatory obligations relating to assessing the appropriateness of our products and services|
|Ethnicity, citizenship and social security numbers or national identity and passport numbers||In order to comply with KYC and regulatory trade reporting and other AML obligations|
|Proof of photo ID, address verification||In order to comply with KYC and regulatory trade reporting and other AML obligations|
|Unique device number (IP address) and device information including version of web browser you use||When you visit our website, navigate through the pages or fill in any forms, we may collect your unique device number or IP address in order to set up your profile.|
|Financial sanctions and credit header information||In order to perform our electronic AML screening checks and to comply with other fraud detection policies. This may generate further information on your credit history, criminal convictions or political interests leading to us making decisions based on the results of these checks|
We use information held about you in the following ways:
to ensure that the content in our website is presented to you in the most effective manner and to improve the content of our website.
As part of using your personal information for the purposes set out above, we may disclose your information to:
Generally, we require that organisations outside our Group who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with the all relevant data protection laws and this privacy notice. Third party service providers such as credit referencing agencies may keep a record of any searches performed on our behalf and may use the search details to assist other companies in performing their searches. Please note that the use of your personal information by external third parties who act as data controllers of your personal information is not covered by this privacy notice and is not subject to our privacy standards and procedures.
Where our use of your personal information requires your consent, such consent will be provided in accordance with the applicable customer agreement available on our website(s) or any other contract we may have entered into with you or as set out in our communication with you from time to time.
Under the General Data Protection Regulation you have a number of important rights. In summary, those include rights to:
If you would like to exercise any of those rights, please:
Reasons we can collect and use your personal information: Lawful basis for processing
Under Mauritian data protection law, there must be a lawful basis for all processing of personal data (unless an exemption or derogation applies). We rely on:
Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract to conduct regulated activities, when processing is necessary for the entry into, or performance of contract with the data subject or in order to take steps at this or her request prior to the entry into a contract.
Processing is necessary for compliance with our legal obligation. AERON has the necessity for compliance with a legal obligation.
Data will only be processed where it is necessary for the purposes of the legitimate interests pursued by AERON, and these interests or fundamental rights are not overridden by the interests of the data subject. AERON will, when deciding to process data to ensure that the legitimate interests do not override the rights and freedoms of the individual and that the processing would not cause unwarranted harm. For instance, it is a legitimate interest of AERON to process personal data on potential client in order to expand the business and develop new business relations. The data subject must be given information on the specific legitimate interest if a processing is based on this provision.
Your Data is stored and kept confidential according to the legislation on protection of personal data and processing thereof applicable in the jurisdiction in which AERON with which you have signed up is located.
We always take appropriate technical and organisational measures to ensure that your information is secure. In particular, we train our employees who handle personal information to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal where necessary.
We have appropriate security measures in place to prevent personal information from being accidentally lost, misused, modification, disclosure or accessed in an unauhorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We are constantly striving to improve functionality on this site through technology changes. This may mean a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy will be notified in this privacy notice at the time of the change.
Our websites or our apps may have links to external third-party websites. Please note, however, that third party websites are not covered by this privacy notice and those sites are not subject to our privacy standards and procedures. Please check with each third party as to their privacy practices and procedures
This privacy notice was published on November 2020 and last updated on November 2020.
If you have a concern about any aspect of our privacy practices, you can make a complaint. This will be acted upon promptly. To make a complaint, please contact us via one of the methods set below.
If you have a complaint about our use of your information, you can contact the Office of the Data Protection Commissioner via their website at http://dataprotection.govmu.org/ or write to them at: The Data Protection Commissioner Data Protection Office 5th Floor SICOM Tower Wall Street Ebène.
If you have a privacy concern, complaint or a question for the Data Protection Officer, please contact us via email at firstname.lastname@example.org. We will respond to questions or concerns within 30 days.