SIPA Group

Privacy Policy

Who is in charge of your personal information ?

SIPA is responsible for personal information that we may collect as described below. SIPA includes SIPA Group SA, Rue Lion d’Or 6, 1003 Lausanne, Switzerland; SIPA Bulgaria, 22 Slivnitsa Blvd. 9000 Varna, Bulgaria; and their respective affiliates (the “SIPA Entities”). Specifically, your personal information will be controlled by the SIPA Entity that provides these services or communication to you. Your personal information may be controlled by more than one SIPA Entity.

How do we collect your personal information and what data do we collect ?
  • SIPA collects and processes personal information about you. In particular:
  • information provided during the SIPA account application process or while using the SIPA website (e.g., your name, e-mail address, telephone number, date of birth, social security number, investment goals, etc.);
  • information acquired in connection with transactions you conduct through the SIPA system or in connection with services offered by SIPA (if you participate in the management program).
  • Information received from consumer research agencies;
  • information collected through Internet cookies (for more information regarding the use of cookies, please see the Cookie Usage Policy).

Are you required to provide Personal Information ?

In order for you to use our services, you will provide us with your personal information voluntarily. In most cases, SIPA cannot perform certain actions without some of your personal information, for example, if it is required to process your instructions or orders, or to enable you to access our services or marketing content. In most cases, it will be impossible for us to provide you with the benefits of these services without the relevant personal information.

What do we use your personal information for ?

  • We may use your personal information for the following purposes (“Permitted Purposes”):
  • To provide you with brokerage and other services available on our platforms, and/or to process your requests;
  • To fulfill a legitimate interest, including to carry out, monitor and analyze our business or operations;
  • As part of our recruitment process;
  • To contact you (unless you tell us you prefer not to be contacted) about features that may be of interest to you;
  • To enter into or perform various contracts;
  • To follow up with you, by us or others acting on our behalf, using various methods: (i) the use of “smart” automated tracking tools; or (ii) via random tracking of systems, e.g. systematically via electronic communication logging tools; (iii) specific tracking of systems in connection with e.g. investigations, regulatory requests, subject access requests, litigation, arbitration or mediation, or; (iv) data tracking, data analytics tools that extract data from disparate sources in order to establish linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analytics); and/or (v) the use of other similar tracking technologies that may arise from time to time;
  • To comply with any applicable laws or regulations of any country;
  • For any other purpose for which your personal information has been provided to us.

We may process your personal information for the following purposes after obtaining your express consent where legally required:

  • To communicate with you, through the channels you have approved, to keep you informed of the latest updates, announcements and other information regarding SIPA services, products and technologies;
  • To conduct customer surveys, marketing campaigns, market analysis or promotional activities;
  • To collect information about your preferences in order to create a user profile to personalize and enrich the quality of our communication and interaction with you (e.g., through newsletter tracking or analytical data).
  • Where we are legally required to provide marketing-related communications, we will only provide you with this information after you have given your prior consent and we will also offer you the opportunity to unsubscribe at any time if you do not wish to receive marketing-related communications from us. We want to keep our customers, staff and other relevant third parties informed of company developments, including information about SIPA that may be of interest to them. If you do not wish to receive publications or information about events or seminars that may be of interest to you, please inform us by following this link: https://www.sipagroup.com. Where required by law, we will not use your personal information to make automatic decisions that affect you or create profiles other than those described above.
  • Depending on the permitted purposes for which we use your personal information, we may process your personal information on one of the following legal bases:
  • Because processing is necessary to carry out a customer instruction or other contract with you or your organization;
  • To comply with legal obligations (for example, to hold pension information, or for tax purposes):
  • Because processing is necessary to carry out a customer instruction or other contract with you or your organization;
  • To comply with legal obligations (for example, to hold pension information, or for tax purposes):
  • Because its processing is necessary for our legitimate interests or those of a third party recipient who receives your personal information, provided that such interests do not conflict with your interests or fundamental rights and freedoms.
  • Because their processing is useful or necessary, at our discretion, and is not prohibited under the law of the relevant jurisdiction.
  • In addition, their processing may be based on your consent when you have expressly given it to us.

With whom do we share this personal information and under what circumstances ?

We may share personal information in the following circumstances:
  • We may share your personal information among SIPA entities on a confidential basis as permitted by applicable law or as necessary to provide products or services and for administrative, billing and other business purposes. A list of countries where SIPA entities are located is available on our website;
  • We may share personal information with companies that provide services in areas related to fraud, crime prevention and similar services, including financial institutions such as market intelligence firms and regulatory agencies;
  • We may share your data with third parties to assist you in your recruitment process;
  • In accordance with applicable law, we may share personal information with courts, law enforcement agencies, regulatory agencies, attorneys or other parties when necessary for the establishment, exercise or defense of legal or equitable claims or in connection with alternative confidential dispute resolution;
  • We may also use aggregated personal information and statistics to track website usage and to help develop our website and services.

In other circumstances, we will only disclose your personal information if you instruct or authorize us to do so, when we are permitted or required to do so under applicable laws and regulations, upon judicial or official request, or if required in connection with an investigation of suspected fraudulent or criminal activity.

Personal information you provide to us about other people

If you provide us with information about someone else (for example, one of your directors, employees or a person with whom you have a business relationship), you must ensure that you are authorized to disclose their personal information to us and that, without our having to take any further steps, we can collect, use and disclose their personal information as described in our Privacy Policy. In particular, you must ensure that the individual is aware of the matters detailed in the Privacy Policy as they relate to them, including matters relating to who we are, how to contact us, the purposes for which we collect information, our practices in terms of disclosing personal information, and the consequences if personal information is not provided (such as our inability to provide these services).

Protection of your personal information

To the extent required by law, we will take the necessary technical and organizational measures to keep your personal information confidential and secure in accordance with our internal procedures covering the storage, disclosure and access to personal information. Personal information may be stored in our computer systems, those of our contractors or in paper files.

Transfer of your personal information outside the EEA (if GDPR applies)

With respect to personal information subject to the General Data Protection Regulation (EU) 2016/679 (“GDPR”), we may transfer your personal information outside the EEA for the Permitted Purposes described above. Some of these countries may not provide the same level of protection as those offered by the laws of your country (for example, laws in Europe or the United States). We will ensure that international transfers are made in accordance with appropriate and relevant safeguards as required by the General Data Protection Regulation or other applicable laws. You may contact us at any time using the contact information below if you would like more information regarding these measures.

If personal information is transferred to countries or territories outside the European Economic Area (“EEA”) that are not recognized by the European Commission as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms to ensure the protection of personal information.

Update your personal information

If any of the personal information you have provided to us changes, for example, if you change your e-mail address or if you wish to cancel a request you have made to us, please contact SIPA’s customer service department via the SIPA website at sipagroup.com/help. We will not be responsible for any losses caused by inaccurate, false, insufficient or incomplete personal information provided by you.

How long do we keep your personal information ?

We retain your personal information in an identifiable form in accordance with our internal policy which sets out the general standards and procedures for the retention, processing and destruction of personal information. Personal information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if we need to preserve your personal information in connection with litigation, investigations and proceedings.

Other rights of individuals or information covered by the GDPR

With respect to residents of the EEA and where your personal information is processed by SIPA entities established in the EEA (“Covered Persons”).

If you are a Covered Person, you have a number of rights under the GDPR relating to the personal information we hold about you. These rights include:
  • Obtaining information relating to the processing of your personal information and access to personal information we hold about you. Please note that, in certain circumstances, we may refuse requests for access to copies of personal information (including information relating to legal employment privileges).
  • Requests to correct your personal information if it is inaccurate or incomplete;
  • Requests for deletion of your personal information in certain circumstances. Please note that in certain circumstances, you may ask us to delete your personal information but we are legally required to retain it;
  • Object to, and request that we restrict, the processing of your personal information in certain circumstances. Again, in certain circumstances, you may object, or ask us to restrict the processing of your personal information where we are legally obliged to refuse your request;
  • Withdraw your consent, although in some circumstances we may lawfully continue to process without your consent if we have other legitimate reasons (other than your consent) for doing so.

We have appointed a Data Protection Officer (“DPO”) to improve and promote compliance and understanding of the principles of privacy and data protection. If you wish to proceed as described above, please email us at dpo@sipagroup.com.

We may request that you prove your identity by providing us with a copy of valid means of identification so that we can comply with security obligations and prevent unauthorized disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests for access to your data and for additional copies of personal information you request.

We will investigate all requests and complaints we receive and respond to you promptly. If you are not satisfied with our response, you may file a complaint with the appropriate private regulatory body. At your request, we will provide you with information about your regulatory body.

Updates to the Privacy Policy

The Privacy Policy was last updated on May 19, 2022. We reserve the right to update and modify this Privacy Policy from time to time, for example, to reflect any changes in the way we treat your personal information or related to legal requirements. If such changes occur, we will post the Privacy Policy on our website, or it will be posted in another manner. The changes will take effect when they are posted on our website.

How to contact us ?

We welcome your comments regarding our website and our Privacy Policy. If you have any questions about this Policy, please contact the Data Protection Department at dpo@sipagroup.com or IB Customer Service via the SIPA website at sipagroup.com/help.

SIPA Group Cookie Usage Policy

What is a cookie or web beacon ?

Cookies are small files that a website transfers to a user’s computer to collect data. Web beacons are invisible pixel images used to collect information about website usage, e-mail response and tracking. Generally, cookies may contain information about your Internet Protocol (“IP”) addresses, the region or geographic area where your computer or device accesses the Internet, browser type, operating system, and other information about website usage, including the history of pages you visit.

How do we use cookies and web beacons ?

SIPA Group collects information from cookies and web beacons that are stored in an internal database. This information is stored in accordance with our privacy policy. This website uses the following cookies and web beacons:

  • Strictly necessary cookies
    These cookies are necessary for the website to function properly and cannot be disabled in our systems. Generally, they are used only in response to actions on your part that are consistent with a request for services, such as determining your privacy preferences, logging in, or completing forms. You can set your browser to block cookies or to alert you to their presence, but some areas of your website will not function properly. These cookies do not store personal information.
  • Performance cookies and web beacons
    These cookies and web beacons allow us to count the number of visits and sources of traffic so that we can measure and improve the performance of our site. They help us to know which pages are most or least popular and to see how visitors navigate the site. All information that these cookies and web beacons collect is aggregated and therefore anonymous. If you do not allow these cookies and web beacons, we will not know when you have visited our site and we will not be able to record your visit.

    The website uses Google Analytics, an analytical data service provided by Google Inc. (“Google”). Google Analytics uses cookies to help analyze how this website is used. The information generated by the cookie about your use of this website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by them.

  • Functional cookies
    These cookies enable the website to provide enhanced functionality and personalization. They may be placed by us or by third-party vendors whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function properly.
  • Cookies and targeting web beacons
    These cookies and targeting tags may be placed on our site by advertising partners. They may be used by these companies to profile your interests and display relevant ads on other sites. They do not store any personal information directly and only identify your browser and internet device. If you do not allow these cookies and web beacons, your ads will be less targeted. The website does not track users when they visit third party websites, does not provide targeted advertising to them, and therefore does not respond to “Do Not Track” signals.
  • Manage your cookie preferences
    There are several options for managing cookies on your computer. All major browsers give you the ability to block or delete cookies from your system. However, if you choose to disable cookies, you may not be able to access certain areas of our website or the website may not function properly. To learn more about your options for managing cookies and web beacons and how you can disable them, see the privacy features of your browser or visit www.allaboutcookies.org.

    This website may direct you to a third party website that may also use cookies and web beacons over which we have no control. We recommend that you check the third party’s privacy policies for information regarding the cookies and web beacons that may be used.

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