Privacy
policy

GLOBAL ALLIANCE LTD PRIVACY POLICY

This Privacy Policy (“Policy”) is integral part of of Public Offer (“Agreement”) entered by and between Global alliance Ltd., reg. numb. 22180 IBC 2014 address Jaycee’s Building. Corner Leeward Highway and Stoney Ground Road. Kingstown. St Vincent and the Grenadines, VC 0100, (hereinafter called the «Company») and any Client (or You as non-registered user) within the expressed will to adhere Company’s Services under publically made proposal to open and maintain a margin trading Accounts with trading Global alliance LTD system for trading operations with CFD. thereto state regulation regarding the collection, use and disclosure of information that Company process in the course of our business as well as web-site usage.

  1. Definitions

The following terms has the meaning of:

  • «GDPR» means the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced or superseded and in force from time to time and as transposed into member-state legislation.
  • «Privacy Policy» means this Privacy Policy updated from time to time and made public on Company’s Websites and through Company’s mobile applications.
  • «Personal Data» means any information which relates to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • «You» – refers to You when You are visiting Company’s Websites, utilizing Company’s Services or communicating electronically with us.
  1. The Company

Company is represented by main website and lending pages: https:// (hereinafter jointly and separately referred as to “Website”, “us”, “Company”, or “our”)

  1. What Company does

Company’s main goal is to support and develop the GLOBAL ALLIANCE LTD Client services presentation and help further market development. To achieve this goal, Company provide information relating to the project, publish news, educate, conduct webinars, organize public events, provide technical and informational support, and help Company’s Clients to invest in the project.

Company only use the personal information for the purposes stated in this Policy.

Company share the Client’s personal information with the third parties only if it has needed to perform Company’s Services and only after the Client has explicitly expressed their consent.

Company neither collect nor process special categories of personal data (as defined in Article 9 GDPR).

  1. How to contact Company

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: [email protected] Company’s data protection officer (DPO) can be reached via this email address:  [email protected]

  1. Voluntary nature of data provision

Company strongly respect Your privacy. This Privacy Policy details important information regarding the use and disclosure of user information collected on the Website. Company provides this Privacy Policy to help You make an informed decision about whether to use or continue using of the Website.

Company reserves the right to amend the privacy policy at any time. In case of such amendment, Company shall publish a relevant notification of such changes on the official Web-Site.

Company gather Personal information (also referred as to PI, Personal Data, PD) only in scope, that is required for providing You with relevant Services and that confirms with purposes of such collection. Company gather Personal information only for purposes, that are stipulated in this Privacy Policy, or requirements, that follow from applicable law.

Company’s main purposes in gathering of information are to provide You with possibility to use and improve Company’s Website, Company’s Services, and Website’s content to allow You use Website in an appropriate way.

Company do not store PI for a longer period, than it is required for maintaining of Company’s Services for You and other users.

There is no obligation for a Client to share their personal information with the Company. However, Company cannot provide some of Company’s Services until such information is shared.

Children can only use Company’s Services under the supervision of their parents/legal guardians and Company always suggest minors (under the age of 16) not to submit any personal information to us or use the Service. Consent for processing of minor’ PI shall be given by their holder of parental responsibility over the minor.

Personal Company does not knowingly collect or maintain personally identifiable information or non-personally-identifiable information on the Company website from persons under 13 years of age, and no part of Company’s website is directed to persons under 13. If You are under 13 years of age, then please do not use or access the Company website at any time or in any manner. If Company learns that personally identifiable information of persons less than 13 years of age has been collected on the Company website without verified parental consent, then Company will take the appropriate steps to delete this information.

  1. Types of personal data

Company classify Company’s Client’s personal information into three main types:

  • Directly collected information (D)

This refers to the information which a Client directly provides himself (e.g. by filling the web- site forms).

  • Indirectly collected information (I)

This kind of information relates to the Client but he does not provide it directly (e.g. an IP address).

  • Automatically generated information (A)

This type of information is generated automatically by the system. Though such information isn’t provided by the Client himself it relates to him and according to the Article 4 (1) of the GDPR is considered to be personal data. It has 2 subtypes:

  • static A (SA). This information does not usually change once it is An internal user id is an example.
  • dynamic A (DA). This subtype changes accordingly to the actions performed by the

Company use these abbreviations below to address different types of personal information: D, I, SA, and DA.

  1. What information Company collect, when, and why

There are several points in the ‘Company-Client’ relationship at which personal information is collected:

  • Sign Up (Registration) – Step 1

When a Client first sings up the following information is requested or assigned:

#Personal DataTypePurpose
7.1.01First nameDto identify a Client
7.1.02Phone numberDused for notifications and security confirmations
7.1.03Email addressDused for notifications and alerts, serves as a login
7.1.04IP addressI

Client identification, protection of Your account from fraudulent actions of third persons.

In case if You hide Your IP address or provide us with one that doesn’t reflect Your actual location Company will not be liable for displaying information irrelevant to You, and Company wave any liability connected herewith. Company will reply only on information provided by You at Your own discretion and at Your own responsibility.

7.1.05LanguageIto communicate with the Client on his/her language
7.1.06Internal user idASto identify a Client in the system
7.1.07Date of the registrationASused for statistics
7.1.08Verification indicatorADfor internal use
7.1.09StatusADsystem status indicating the level of involvement
7.1.10Inviter’s first/last nameAS(if any) used for referral structure
  • First Log In

After the first step of the registration, a Client is automatically logged in and is requested to provide the following information:

#Personal DataTypePurpose
7.2.01CitizenshipD  used for statistics
7.2.02Host countryD
7.2.03Host cityD

7.3 Sign Up (Registration) – Step 2

When the first step of the registration is completed, a confirmation email is sent to the address (7.1.03). After following the link in the email, the Client is logged in to his personal profile and is requested to provide the following data:

#Personal DataTypePurpose / Comments
7.3.01First nameDis preset by 7.1.01, can be edited, replaces 7.1.01
7.3.02Last nameDto identify a Client
7.3.03Phone numberDis preset by 7.1.02, can be edited, replaces 7.1.02
  • Verification

Verification is an important step because most information collected will be handed over to the Payments processing partners and accountant agencies in business.

This information includes:

#Personal DataType
7.4.01First nameD
7.4.02Last nameD
7.4.03Date of birthD
7.4.04Country of birthD
7.4.05GenderD
7.4.06IDD
7.4.07ID scans (photo included)D
7.4.08AddressD
7.4.09Residence confirmationD

7.4.01, 7.4.02 update and replace 7.3.01, 7.3.02 respectively. All this information is required to successfully complete verification process.

  • Certificate Delivery

If a Client requests a hard copy of the certificate of payments and Services to be delivered to him/her and his/her current address differs from 7.4.08 Company may additionally request:

#Personal DataType
7.7.01Client’s current addressD

to deliver a hard copy of the certificate. This information is not saved, only shared once with a third party (see 9.1).

  • Parental responsibility

When a Client wants to register a child under tutors actions on their behalf they are obliged to be informed that Company do not present Services for minorities under no way, so no parental registration would be permissible even the Client would present by mistake before written email denial:

#Personal DataType
7.8.01Parental responsibility holder confirmationD

The Company doesn’t provide direct Services to minors.

  • Additional information as web-site user:

A Client can optionally share additional contact information:

#Personal DataType
7.9.01Additional phone numberD
7.9.02Skype accountD
7.9.03Additional email addressD
7.2.02Temporary Host country by IP    D

This information is not transferred anywhere and is used solely as extra communication options. The additional email address may also be used for security notifications (when a login into the Client’s account is performed).

  • Ongoing collection of information for Client and web-site users:
#Personal DataTypePurpose / Comments
7.9.1.01Information from survey’s that You fill in while answering at Your own discretions to surveys Website may initiate from time to timeDTo improve Company’s Services and offers.
7.9.1.04Computer and connection information such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platformITo improve Company’s Services and offers.
7.9.1.05Data from mobile devices (for example location).I

In order to show You documentation relevant to Your jurisdiction and in the language of the regions that You are active in.

You can hide it from us, if You do not know how to disable Your device’s location Services, Company recommend You contact Your mobile Service carrier or Your device manufacturer. In case if You hide Your location Company will not be liable for displaying information irrelevant to You, and Company wave any liability connected herewith. Company will reply only on information provided by You at Your own discretion and at Your own responsibility.

7.9.1.06BehaviorADRefer to section Automated Decision-Making and Profiling below.
7.9.2.01Other to improve Company’s web-siteI

To improve Company’s Services and offers Company might eventually analyze Your information:

operating system;

device ID;

cookie ID;

Google 360 ID;

GUID; and

information about Your technical history use of Company’s Services, scope and time uploaded of products and facilities (including information gained when You use Company’s learning tools, demo accounts and trading simulators).

This information and purposes is not exhaustive, and is laid out to give You an idea about use of fundamental collected information. The Company will record all information collected and purposes for which the Company process that data.

  • Information, which Company obtain indirectly

In some cases, Company are also provided with Your name and contact details by Company’s third party referrers.

Company also gather information relating to You and Your online behavior:

  • to help optimise Company’s website, to give You a good user experience and to personalise Your use and Company’s communications to You;
  • to help us monitor, support and improve the performance of Company’s site (by analysing Your use and experience of Company’s site);
  • to help us understand more about You and the products and Services You use and are interested in; and
  • to tailor the online advertising You receive.

Knowing more about You helps us to understand Company’s customers better, and means Company can give You recommendations about products and Services You may be interested in, and provide You with relevant advertising and customised communications that are of interest to You.

Company combine information that You provide to us with information that is publicly available and/or that Company receive from third parties such as advertisers and/or other reputable sources who have obtained Your permission to do so, or have otherwise explained to You that this may happen.

  1. Lawfulness of Processing and Disclosure

You agree to this conditions of collection, processing, transfer and storing Your personal data. When Company process Your personal data for one of the legal bases specified in this Privacy Policy, Company will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Policy. Company protect Your Personal Data under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards Company use are firewalls and data encryption, physical access controls to Our data centers, and information access authorization controls. Company also authorize access to Personal Data only for those employees or contractors who require it to fulfill their job or Service responsibilities. Company’s staff is trained on procedures for the management of personal information, including limitations on the release of information. Access to personal information is limited to those members of Company’s staff and contractors whose work requires such access. Company conduct periodic reviews to ensure that proper information management policies and procedures are understood and followed. All of Company’s

physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations.

When You provide Your personal data through Company’s Website, KYC portals, Company’s applications, this information is transmitted across the internet securely using industry standard encryption. Your personal data will be held encrypted on secure servers.

Where any third parties process Your personal data on Company’s behalf, Company require that they have appropriate technical and organizational measures in place to protect this personal data and Company will also ensure that a GDPR compliant. Data Processing Agreement is in place between Company’s Company and the third party so that both parties understand their responsibilities and liabilities pursuant to GDPR.

Company hereby informs You that the collected information may be lawfully disclosed to third parties such as:

  • Agencies that deal with: law enforcement, regulators, governmental bodies, fraud or collusion prevention. identity verification, payment processing, credit reference, financial institutions, court.
  • Introduction parties: that You permit us to introduce You to.
  • Providers and contractors/subcontractors, employees that may need information for provision of Services: such as IT maintenance, to make sure the Website is running perfectly, marketing Services on behalf of the Website, technical communication Services in order to communicate with You, data processing, external auditors and legal support Services and others.

The Company is obliged to disclose Your personal information in following cases:

  • in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements;
  • to protect, establish, or exercise Company’s legal rights or defend against legal claims, including to collect a debt; to comply with a subpoena, court order, legal process, or other legal requirement;
  • or when Company believe in good faith that such disclosure is necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to Company’s property, or violations of Terms & Conditions.
  • To Third Parties in case of: merger, restructuring, joint venture, assignment, sale part of the business or the whole business.
  1. Third Parties

Company may share some of the Client’s personal data with the following third parties (in amount limited to what is necessary in relation to the purposes):

  • 1 – The company mentioned in 7.4 (“Verification”). This is necessary for the performance of the contract (see 8. Lawfulness of Processing). The information shared: 7.4.01 – 7.4.05, 7.6.01 – 7.6.03. For the certificate delivery: 7.4.08 or 7.7.01 and 7.6.01
  • 2 – SMS-notifications Service providers. Only a Client’s phone number is disclosed (7.1.02) along with the message to be sent. The message itself does not contain any personal data.
  • 3 – Voice messaging Service providers. The same as with SMS-notifications (7.1.02).
  • 4 – Mailing Service provider. The personal information disclosed: 7.1.03, 7.1.05.
  • 5 – Other Clients who are in the same referral structure. A Client can see the details of his inviter (media sponsor) and all the Clients in his own referral structure below. This data includes: 7.4.01, 7.4.02, 7.1.08 – 7.1.10, 7.1.03, 7.3.03, 7.5.01, 7.1.07
  1. Where Company store personal data

Company store all the data in data-centers in Germany, Russia, USA, UK, Netherlands and France. These entities are the data Processors who indirectly process Company’s Clients’ personal information by Company’s request. Note, that the nature of this processing is narrowed down to the server infrastructure maintenance and does not include any first-hand processing of the personal data. Company neither disclose such information to these entities nor give them any permission to access it.

  1. How long Company store personal data

Company store personal data as long as it’s needed to provide Company’s Services, or until a Client withdraws their consent to further processing of the personal data (see 12.5). In any case for 5 years after cession of Service provision according to the Prevention of Money Laundering and Funding of Terrorism Regulations.

  1. Rights of the Client

Company’s Clients are entitled to perform a range of operations with regard to their personal data:

  • Notification

In the case of a Personal Data breach, Company shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal information breach to the supervisory competent authority, unless the personal information breach is unlikely to result in a risk to the rights and freedoms of natural persons.

If Company learns of a security systems breach, then Company may attempt to notify You electronically so that You can take appropriate protective steps. Company may post a notice on the Company website if a security breach occurs.

When the personal data breach is likely to result in a high risk to the rights and freedoms of users, the Company will inform You.

In the event that Company is acquired by or merged with a third party entity, Company reserve the right, in any of these circumstances, to transfer or assign the information Company have collected from Company’s Users as part of such merger, acquisition, sale, or other change of control. If Company become involved in a merger, acquisition, or any form of sale of some or all of its assets, Company will notify Users before personal information is transferred and becomes subject to a different privacy policy. In the unlikely event of Company’s bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, Company may not be able to control how Your personal information is treated, transferred, or used.

  • Obtain confirmation

Any Client has the right to obtain confirmation as to whether or not personal data concerning him or her are being processed.

  • Access personal data

If personal data concerning the Client is being processed by the Company, the Client has the right to access such data.

  • Demand additional information

Any Client has the right to demand the following additional information concerning their personal data:

  • 3.1 – the purposes of the processing
  • 3.2 – the categories of personal data concerned
  • 3.3 – the recepient(s) or categorie(s) of recepient to whom the personal data have been or will be disclosed
  • 3.4 – the criteria determing the period for which the personal data will be stored
  • Request rectification

Any Client has the right to obtain the rectification of inaccurate personal data concerning them (this includes to have incomplete personal data completed) from the Company without any undue delay:

  • where You disagree with the accuracy of the information, Company need to restrict the processing
  • until Company’s verified the accuracy of the information;
  • when processing is unlawful and You oppose erasure and request restriction instead;
  • if Company no longer need the personal information but You need this to establish, exercise or defend a legal claim; or
  • where You’ve objected to the processing in the circumstances detailed in paragraph (a) of “Objecting to processing”, and Company’s considering whether those interests should take priority.
  • “Be Forgotten”

Any Client has the right to withdraw their previously given consent and have the personal information erased from Company’s system. In this case third parties 9.2 – 9.4 will no longer get the personal data of a Client, and 9.5 will lose the access to such personal data. In their referral structure, (if any) other Clients will see just “Account deleted”.

However, doesn’t mean that Your data will be erased immediately it will still be stored  at Company’s facility in order to comply with numerous statutory obligations, specifically the Prevention of Money Laundering and Funding of Terrorism Regulations (LN 372/2017) Article 13, under which Company are required to store any collected information for a minimum period of five years from the closure of Your Account, for the purposes of the prevention, detection, analysis and investigation of money laundering or funding of terrorism activities. After this period has elapsed, Your Personal Data will be deleted from Company’s records.

  • Restrict processing

The Client has the right to obtain restriction of processing if the accuracy of the personal data is contested by him, for a period enabling the Company to verify the accuracy of the personal data.

  • Receive personal data

The Client has the right to receive personal data concerning them, which they have provided to the Company, in a structured, commonly used and machine-readable format.

  • Have personal data transmitted

The Client has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

  • Object

The Client has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her:

(a)  Legitimate interests

You’ve the right to object, on grounds relating to Your particular situation, at any time to processing of personal information concerning You which is based on legitimate interests.

If Company can show compelling legitimate grounds for processing Your personal information which override Your interests, rights and freedoms, or Company need Your personal information to establish, exercise or defend legal claims, Company can continue to process it.  Otherwise, Company must stop using the relevant information.

(b)  Direct marketing

You can object at any time to Your personal information being used for direct marketing purposes (including profiling related to such direct marketing).

If You sign up to receive newsletters or other e-mail messages from us, You can opt-out at any time free of charge

  • Reject to algorithm decision making systems

You’ve the right to reject be submitted under decisions based solely on automated processing software, script and actions of algorithms, including profiling, which has legal consequences for You or similarly significant effects.

As explained in the main part of Company’s Privacy Policy, Company use technology that does this and Company encourage You not to use it. Company only do so where:

  • this is necessary for entering into, or performance of, a contract between us (chat robots, search of FAQ);
  • this is stated by law in force; or
  • Company’s obtained Your agreed permission.
  • Communications

Throughout Company’s cooperation You shall receive information messages from Company. as described below, given that You where applicable “opt-in” and don’t “opt-out” from this options:

  • Messages by email
  • Messages by phone
  • Messages by push –notifications
  • Messages by email Your account
  1. Using companies to process Your information outside the EEA. All countries in the European Union have same standards of legal protection for Your personal data. The personal data that Company collect from You may be obtained from open data or third parties.  It may also be operated by staff out of EU under Company’s control or Company’s demand. Company will ensure that a similar degree of protection is afforded to it by use of model clauses approved by the European Commission, by transferring to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or by transferring to third parties who are part of the Privacy Shield.
  1. Conclusion

Please acknowledge by implementing rights given by GDPR (erasure, stop processing),You will deprive Yourself of some features of the Website and in some cases, where applicable, Company might be  forced to close Your account at the Website, launch an investigation and will reserve the right to forfeit deposited funds in case of fraudulent intentions from Your side.

Company are committed to protecting the privacy of personal data and try to disclose the processing details in a transparent and easy way.

Should You have any questions concerning the information above, please, don’t hesitate to contact Company.

Should Company lawfully receive Your Personal information from a third party You will have same rights regarding information in question as regarding to information that You have provided to us directly or Company have collected during cooperation with You.

If You reasonably believe that Company are violating Company’s responsibilities to protect Your privacy, You have a right to lodge a complaint with a relevant supervisory authority.

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