Introduction

This policy provides an overview of how Greatlakecapital.com, by Interworld Brokerage Group LTD, licensed and regulated by the Union of Comoros Offshore Finance Authority (“Comoros”) as an International Brokerage and Clearing House under License number L19908/IWBG, (“Greatlakecapital” “Interworld Brokerage Group LTD” “we” or “us”), processes Personal Information belonging to our customers, and visitors to our website.

• Personal Information has the meaning ascribed to it in the Protection of Personal Information Act, 2013.
• This document must be read with the Interworld Brokerage Group General Terms and Conditions (General Terms). Terms used in this document, but not defined herein, will have the meaning ascribed to them in the General Terms.  In the event of inconsistency between this document and the General Terms, the General Terms will take precedence.

Our Commitment

• We are committed to protecting your privacy and confidentiality. We understand that all users of our website and Services are quite rightly concerned to know that their data will not be used for any purpose, unintended by them, and/or will not accidentally fall into the hands of an unauthorised third party.
• We implement increasingly stringent measures to comply with applicable data protection legislation.
• If you have any questions, if you think our policy falls short of your expectations, or that we are failing to abide by our Privacy Policy, please contact our Information Officer, at [email protected].

Applicability

• This Policy applies to any person who visits our website, or a person who uses our Services as defined in our General Terms.
• By accepting this Policy, you are deemed to have read, understood
• d, accepted, and agreed to be bound by all its terms, and you consent to providing us with your information voluntarily.

The Personal Information we collect and where we collect it from

• The Personal Information we collect, and the manner in which we collect such information, depends on how you interact with us e.g. visiting our website, corresponding with us, registering for a trading account, or using our Services.
• Where you utilise our Services, we collect Personal Information directly from you during the registration process, including but not limited to your name, email address contact number, financial information, and physical address.
• Where you register to receive notifications and/or advertisements, we may process your name, contact details and your e-mail address.

• We may receive Personal Information about you from various third parties such as customer relationship management software; analytics providers; financial institutions; marketing platforms; and search information providers.
• You may only send us your own Personal Information. You may only send us Personal Information relating to another person, where you have their express permission to do so.

Browsing our website: Cookies

• Cookies are small text files that are placed on your computer’s hard drive through your web browser when you visit any website. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
• When you visit our website, we may automatically collect, store and use technical information about your interaction with us which is sent from your computer using Cookies.
• Like all other users of cookies, we may request the return of information from your computer, when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages that you visit whilst you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser) or may remain on your computer until you delete them, or until a defined period of time has passed.
• Although your browser software enables you to disable cookies, we recommend that you allow the use of cookies to take advantage of the features of our website that rely on their use. If you prevent their use, you will not be able to use all the functionality of our website. Here are the ways we use cookies:
  • to allow essential parts of our website to operate for you;
  • to collect information about how visitors use our website. This cookie collects information in an anonymous form, including the number of visitors to the website, where visitors have come to the website from, the pages they visited; and
  • to store your Personal Information, so that you do not have to provide it afresh when you visit the website next time.

Use of Personal Information

• We will only use your Personal Information when the law allows us to and for legitimate reasons, which you hereby expressly understand and consent to. Most commonly, we will use your Personal Information in the following circumstances:
  • where we have your express consent to do so;
  • where we need to consult with you;
  • where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
  • where we need to comply with a legal or regulatory obligation.

• We may use your Personal Information as follows:
  • in relation to the provision of our Services and/or access to the Platform;
  • to contact you as requested by you;
• to contact you regarding current or new Services or any other product offered by us (unless you have opted out from receiving marketing material from us); and/or

• research purposes; and/or
• to improve our Platform by, for example, monitoring your browsing habits, or tracking your activities on the Platform.

Complaints

• When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact another person, we may decide to give to that person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is.
• We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
• We undertake to preserve the confidentiality of all the abovementioned information and of the terms of our relationship.

Review or update your Personal Information

• At any time, you may review or update the Personal Information that we hold about you. To better safeguard your information, we will also take reasonable steps to verify your identity, before granting access or making corrections to your information.

Sharing of your Personal Information

• We may share your Personal Information with our employees, suppliers, consultants, contractors, and agents to the extent necessary for us to provide you with Services. Where we do so, we will ensure that the information is only processed in accordance with a written agreement containing the necessary data protection provisions.
• In some circumstances, we may disclose your Personal Information with regulatory authorities, by a subpoena or court order, to comply with any law, to protect the safety of any individual or the public, or to prevent violation of our General Terms.
• We may share your Personal Information with other companies within our corporate group, which includes our subsidiaries, affiliates, and parent companies, for the purposes outlined in this Privacy Policy. This sharing of data allows us to streamline our operations, improve our services, and offer you a more personalized experience across our various products and services. Any sharing of your data between group entities will be done in compliance with applicable data protection laws and regulations, and measures will be taken to safeguard your privacy and security.
• We will not sell your Personal Information.

Disclosure Of Personal Information to Third Parties

• We may disclose your Personal Information to:
  • The qualification bodies that we partner with, to provide you with the Services as further described in the General Terms on the Platform;
  • The qualification bodies that we partner with, to provide you with the Services as further described in the General Terms on the Platform;
  • Our business partners, third-party service providers and/or processors,  to provide you with access to the Platform and/or the Services, such as data storage and other necessary service providers, third-party payment processors, etc. in accordance with written agreements with these third parties;
  • Legal and regulatory authorities, upon their request, or for the purposes of reporting any breach of Applicable Law;
  • Accountants, auditors, lawyers, and other external professional advisors in terms of written agreements with them;
  • Any relevant party to the extent necessary for the establishment, exercise or defence of legal rights, criminal offences, threats to public security, etc.;
  • Any relevant third party if we sell or transfer all or any portion of our business or assets; and
  • Any relevant third-party provider where our Platform uses third-party advertising, plugins, or content.
• If we engage third-party processors to process your Personal Information, the processors will only be appointed in terms of a written agreement which will require the third-party processors to only process Personal Information in terms of our mandate, use appropriate measures to ensure the confidentiality and security of your Personal Information and comply with any other requirements set out in the agreement and required by Applicable Law.
• Our Platform may connect to various social media websites or apps, including, but not limited to, Facebook, Twitter, LinkedIn, Instagram. If you want to use the Platform for social media integration, we will share your Personal Information with the relevant social media websites or apps.
• We may transfer Personal Information to recipients (such as service providers) in other countries where the recipient is subject to a law, binding corporate rules or binding agreement which provides an adequate level of protection or is otherwise permitted by law.

Security

• We take the security of Personal Information very seriously and always do our best to comply with applicable data protection laws.
• Interworld Brokerage Group implements appropriate, reasonable, technical, and organisational measures to prevent the loss of, damage to, or unauthorised destruction of Personal Information as well as unlawful access to or process of Personal Information.

• All Personal Information is protected on our secure server and is password-protected. Only Interworld Brokerage Group senior IT technicians and our IT service provider have open access to this information.

Your Rights: Access to information

• You have the right to request a copy of the Personal Information we hold about you. To do this, simply contact us at the numbers/addresses as provided on our website and specify what information you require.  We will need a copy of your ID document to confirm your identity before providing details of your personal information.
• Please forward your request for access to our Information Officer, at [email protected].
• Please note that any such access request may be subject to a payment of a legally allowable fee.

Correction of your information

• You have the right to ask us to update, correct or delete your Personal Information. We will require a copy of your ID document to confirm your identity before making changes to Personal Information we may hold about you. We would appreciate it if you would keep your Personal Information accurate.

How long do we keep your information?

• We only keep your information for as long as it is necessary for the purpose for which we collected the data, unless:
  • retention is required or authorised by law;
  • we reasonably require the record for lawful purposes related to our functions or activities;
  • retention is required by a contract between you and us; or
  • you have consented to a longer retention of the information.

Destruction

• Any destruction or de-identification of Personal Information, will be carried out in accordance with applicable legislation.

Changes to our Privacy Policy

• We may change the terms of this privacy policy at any time by updating our website. If you continue using the website, following our change of terms, the changed terms will apply to you, and you will be deemed to have accepted the changed terms. We will notify you of any changes by placing a notice on our website.

International Transfers of Personal Information

• Due to the nature of the Services and our business being established in different countries and us working with business partners and service providers in different countries, we may need to transfer Personal Information to and from the different countries for internal business purposes.
• We may transfer your Personal Information to recipients in other countries.
• We will only transfer Personal Information to third parties in countries with adequate data protection laws or do so in terms of a written agreement with the recipient which imposes data protection requirements on that party as required by Applicable Law.
• Please note that when you transfer any Personal Information directly to a third party in another country (i.e. we do not send your Personal Information to the third party), we are not responsible.
• for that transfer of Personal Information (and such transfer is not based on or protected by this Policy). Any Personal Information that we receive from a third-party country will nevertheless be processed in terms of this Policy.