Privacy Policy
Version 1.01; effective from December 4, 2020
1. GENERAL INFORMATION
This Privacy Policy explains what personal data we collect from you when using the ACE.Trade services (hereinafter Services) and how and why your personal data is processed, where “you” or “customer” refers to the person, company, or organization that uses the Services and “ACEX”, “we”, “us” or “our” refers to the company ACEX Ltd. that offers these Services.
ACEX Ltd., a Limited liability company located at Leskoškova cesta 9E, SI-1000 Ljubljana, Slovenia, and registered in the Slovenian Business Register with identification number 8190852000 and tax number 93183496, is the data controller responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) as well as any applicable national laws.
Services offered by ACEX include the website https://ace.trade and an ACE Community mailing list.
Our Services are not intended for children and we do not knowingly collect personal data relating to individuals under the age of 18. If we learn that we have inadvertently gathered personal information from such an individual, we will take legally permissible measures to remove that information from our records.
2. WHAT PERSONAL DATA WE COLLECT
Personal data, or personal information, means any information about an individual from which that person can be identified, directly or indirectly.
We may collect and process these types of personal data about you:
- Email address
- Name and Surname
- Analytical cookies
3. HOW IS YOUR DATA COLLECTED
You may give us your email, name and surname data by manually filling-in a form on our web page and confirming your subscription to the ACE.Trade mailing list by clicking the link in the confirmation email. If you received the confirmation email by mistake, simply delete it. You will not be subscribed if you do not click on the confirmation link and your personal data will not be processed.
Analytical cookies are set and read automatically by browsing this website.
4. HOW WE USE YOUR DATA
We will use your email in the following circumstances:
- To send instructions on how to download the ACE.Trade mobile app.
- To ask for your feedback with regard to your user experience with the ACE.Trade mobile app.
- To inform you of new app features and upgrades.
- To answer any of your questions you sent us by email.
We will use your name and surname to match you with our internal list of potential customers that were invited to join the ACE.Trade trading platform.
Cookies (also called HTTP cookies, web cookies, or browser cookies) are a term for a packet of data that a computer receives and then sends back without changing or altering it. When you visit a website, the website sends the cookie to your computer which stores it in a file located inside your web browser. Cookies can be set by a website other than the one you are currently on (so-called third-party cookies). For example, a web page might have a Facebook like button which will set a cookie that can be read by Facebook.
Compulsory cookies are those that a website needs for proper operation. These are, for example, cookies that take care of sessions of logged in users. Analytical cookies are used to know where our visitors are staying, which of the content is most visited, and from where they visited our site. With the help of cookies, we can also know if you visited for the first time, or if you are our regular visitor.
Below, we provide description of the cookies we use, their issuer, purpose of use, and their duration on your computer.
| Cookie name | Set by | Purpose of use | Duration of use |
|---|---|---|---|
| cookiesDirective | ace.trade | acknowledgement to the use of cookies | 1 year |
| _ga | ace.trade | used to distinguish users in Google Analytics | 2 years |
| _gat | ace.trade | used to throttle request rate in Google Analytics | 1 minute |
| _gid | ace.trade | used to distinguish users in Google Analytics | 1 day |
Where we collect personal data by asking for your consent, you have the right to withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
5. HOW WE STORE AND SECURE YOUR DATA
Your personal data is collected and processed in compliance with the Regulation (EU) 2016/679 of the European Parliament and of the Council. It is primarily stored and processed inside the European Economic Area (EEA), but may be transferred outside the EEA, in which cases it is protected under the EU-US Privacy Shield or by signed standard contractual clauses. In these cases, we ensure that we and our partners take adequate and appropriate technical, physical, and organizational security measures to protect your data.
We limit access to your personal data to those employees and third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
5.1. Data retention
We will retain your personal data only for as long as necessary to fulfil the purposes we collected it for. The personal data we collect about you, can be removed on your request or directly by yourself (e.g. by clicking on the unsubscribe link in an email or by deleting cookies).
6. TO WHOM WE DISCLOSE YOUR DATA
Your data may be accessible to certain types of persons, employed or contracted by us that are involved with the operation of our service (e.g. administration, sales, marketing, legal, and system administration). For achieving the purposes of use set out in Section 4, we may also share your personal data with data processors listed below:
- The Rocket Science Group, LLC for managing our ACE Community mailing list by using the Mailchimp marketing platform.
- Google LLC for its analytics service.
We may also share your personal data with law enforcement, data protection authorities, government officials, and other authorities when:
- Compelled by subpoena, court order, or other valid legal procedure;
- We believe that the disclosure is necessary to prevent physical harm or financial loss;
- Disclosure is necessary to report suspected illegal activity;
- Disclosure is necessary to investigate violations of this Privacy Policy or our Terms of Use.
6.1. External services
The website may include links to third party websites, plug-ins, channels or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you with the use of cookies or web beacons (e.g. if you have opened an email addressed to you). We do not control these third-party services and we are not responsible for their privacy statements. When leaving our website, we encourage you to read the privacy notice of every website or application you visit.
7. WHAT RIGHTS YOU HAVE REGARDING YOUR DATA
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- You have the right to request that we provide you access to your personal data held by us.
- You have the right to request correction of any personal data we hold on you that is inaccurate, incorrect, or out of date.
- You have the right to request deletion of your data when it is no longer necessary, or no longer subject to legal obligations to which we are subject to.
- You have the right to request that we cease processing some of your personal data, such as personal data processed for direct marketing purposes.
- You have the right to request that we restrict the processing of your personal data (for example, while we verify or investigate your concerns with this information, or we no longer need your personal data for the purposes of the processing, but they are necessary for the establishment, exercise or defence of legal claims).
- You have the right to request an export of your personal data.
- Where you have provided your consent to our processing of personal data, you have the right to withdraw it at any time.
Requests are generally free of charge and we try to respond to all legitimate requests as soon as possible. However, we may take more time and/or charge a fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may also need to request specific information from you to help us confirm your identity and ensure your right to access your personal data.
It is important that the personal data we hold about you is accurate. Please keep us informed if your personal data changes during your contract with us.
7.1 Complaints
You also have the right to lodge a complaint regarding the processing of your personal data by us at any time with the relevant supervisory authority. In Slovenia, the relevant data protection authority is the Information Commissioner (https://www.ip-rs.si/en/). We would, however, appreciate the opportunity to deal with your concerns before you approach the authorities, so please contact us by using any of the means stated below.
8. PRIVACY POLICY UPDATES
We reserve the right to modify this Privacy Policy at any time without any notice to you, except if and when such notice is required by law. Where your explicit consent will not be needed, your continued access or use of our Services constitutes your acceptance of the latest Privacy Policy. If you disagree with the Privacy Policy, you must stop using our Services.
9. CONTACT
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you can contact us at support@ace.trade, through the Support section of the App, or by writing to us by mail at ACEX Ltd., Leskoškova cesta 9E, SI-1000 Ljubljana, Slovenia. All communication must be made in English or alternatively in Slovenian language.