PERSONAL DATA PROTECTION POLICY OF "AXIOM INVEST" Ltd.
(amended by decision dated 30.06.2022) "Axiom Invest" Ltd. ("Company", "Administrator", "We") realizes the need to implement adequate protection of personal data of data subjects ("You", "Your" , "You", "Your"), striving to respect your privacy. This Privacy Policy ("Policy") is designed to help you understand how We collect, use and protect your personal data, including when you agree to use Our Website.
For the purposes of its activity as a licensed investment intermediary, the Company processes your personal data in strict compliance with Regulation (EU) 2016/679 (General Data Protection Regulation) (GDPR), the Personal Data Protection Act and other applicable regulations and Politics.
According to the General Data Protection Regulation:
"Personal Data" means any information relating to an individual or an individual who can be directly or indirectly identified ("data subject").
"Processing" means any operation or set of operations performed on personal data or a set of personal data by automatic or other means.
"Administrator" means a natural or legal person, public body, agency or other structure that alone or jointly with others determines the purposes and means of processing personal data.
"Processor of personal data" means a natural or legal person, public body, agency or other structure that processes personal data on behalf of the controller;
"Recipient" means a natural or legal person, public body, agency or other structure to which personal data is disclosed, whether or not it is a third party.
This Policy provides information regarding:
Data that identify the Administrator and contact details
Data subjects whose personal data are processed
Categories of personal data
For what purposes are personal data processed?
On what legal basis are personal data processed?
Recipients of personal data
The terms of storage of personal data
Rights of data subjects and how to exercise them
Giving consent and withdrawing consent
Right of appeal to the supervisory authority
Personal data security measures
Data that identify the Administrator and contact details
(amended by decision dated 30.06.2022 and 17.04.2024) The personal data administrator is "Axiom Invest" Ltd, address: Sofia, 133 Vitosha St., floor 11, e-mail: backoffice@axiominvest.eu; website – www.axiominvest.eu; Phone: 0896757855
Categories of personal data
(amended by decision dated 30.06.2022) If a potential client decides to open a trading account with "Axiom Invest" Ltd., he will be asked for certain information. This information includes, but is not limited to, personal data such as:
· Three names, unique civil number, date and place of birth, ID number and date of issue, address, telephone number, email address, bank account, income and its origin, information on citizenship and tax status, photographs, family position, professional experience, labor relations.
The purpose of collecting this information is to identify the potential customer and assess whether the requested service is suitable for him, before entering into a contract.
Periodically, the provision of additional information may be required, which, on the one hand, will help to improve the services that the Company provides, and on the other hand, is necessary to fulfill the statutory obligations to maintain the data through which the Company identifies the user of the website as its own client in current form and volume.
(amended by decision dated 30.06.2022) "Axiom Invest" Ltd. collects information from the following direct sources:
online application form for opening an account for trading in financial instruments;
documents for opening an account for trading in financial instruments;
(amended by decision of 30.06.2022) made online transactions in connection with the services offered by "Axiom Invest" Ltd;
Declaration for the purposes of the automatic exchange of financial information on the basis of Art. 142t, para. 1 of the Tax and Insurance Procedural Code (DOPK)
Declaration on the origin of client funds under Art. 66, para. 2 of the Law on Measures Against Money Laundering (AML);
(amended by decision of 30.06.2022) correspondence by e-mail and chat, as well as communication by telephone from and to "Axiom Invest" Ltd.;
(amended by decision of 30.06.2022) visits to the website of "Axiom Invest" OOD;
Internet Protocol (IP) address;
browser type;
OS;
Internet Service Provider (ISP);
banner ads seen, etc.
(amended by decision of 30.06.2022) Axiom Invest OOD collects information indirectly through the use of cookies.
(amended by decision dated 30.06.2022) In order to ensure the security of the transfer of information, "Axiom Invest" Ltd. uses an SSL certificate to encrypt information transmitted by or to the visitor through the website
a.
Special categories of data we process:
(amended by decision dated 30.06.2022) With a view to fulfilling its obligations under the ZMIP, "Axiom Invest" Ltd. collects and processes information that can be considered to a certain extent as information about your political views (representing a special category of personal data according to Regulation 2016/679). These personal data are collected based on the fulfillment of a legal obligation and therefore their processing by "Axiom Invest" OOD is lawful.
Data subjects whose personal data are processed
The administrator processes personal data of the following categories of data subjects:
· Clients - legal entities and individuals;
For what purposes are personal data processed?
(amended by decision dated 30.06.2022) "Axiom Invest" Ltd. uses the non-public information, containing personal data, collected from customers to open and service customer accounts for trading in financial instruments.
(amended by decision of 30.06.2022) "Axiom Invest" Ltd. will use the data collected from the client to verify his identity according to the applicable law, as well as to conclude a contract with the client for the provision of the services offered by the company. The collected data will also be used to classify the customer as professional or non-professional - and in this connection to provide him with the legally established set of documents and other information, as well as to determine the tax status of the customer for the needs of the automatic exchange of financial information in the field of taxation.
(amended by decision dated 30.06.2022) Unless the client is informed otherwise, the non-public information and personal data that "Axiom Invest" Ltd. stores and processes are also used for:
analyzing the client's current needs;
fraud and money laundering prevention;
improving the services and products offered to the client;
(amended by decision of 30.06.2022) provision of current information or opportunities that "Axiom Invest" Ltd. considers to be of interest to the client;
Marketing and advertising information;
Maintenance and security of the Company's website and information systems;
Protection of legitimate interests of the Administrator.
On what legal basis are personal data processed?
The processing is necessary to comply with our legal obligation arising from the following legal acts:
Law on Measures Against Money Laundering (AML); Regulations for the implementation of the ZMIP (PPZMIP); Law on Measures Against the Financing of Terrorism (TFT); Law on Public Offering of Securities (IPO Law); Financial Instruments Markets Act (MAFI); Ordinance No. 38 of 25.07.2007 on the requirements for the activity of investment intermediaries, according to the law on accounting, tax legislation and other laws, which oblige the Administrator to process personal data in the field of investment services in the field of capital markets;
The company also processes personal data based on the following lawful grounds:
· the data subject has consented to the processing of his personal data for one or more specific purposes;
· the processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the request of the data subject prior to the conclusion of a contract;
· the processing is necessary for the purposes of the legitimate interests of the controller or a third party, except when the interests or fundamental rights and freedoms of the data subject that require the protection of personal data take precedence over such interests.
Recipients of personal data
We may share your personal data with the following categories of recipients:
· State institutions and bodies with authoritative powers, including, but not limited to, the Financial Supervision Commission, the State Agency for National Security, the National Revenue Agency, the National Insurance Institute, a notary and others;
The company implements appropriate technical and organizational measures to guarantee the rights and freedoms of data subjects in accordance with the principle of "integrity and confidentiality". In particular, the Administrator selects suitable recipients who have taken the necessary guarantees to protect the personal data provided to them and, in view of the existing risks, to ensure the appropriate level of security, including where appropriate:
· pseudonymization and encryption of personal data;
· ability to ensure ongoing confidentiality, integrity, availability and resilience of processing systems and services;
· ability to promptly restore availability and access to personal data in the event of a physical or technical incident;
· a process of regular testing, assessment and evaluation of the effectiveness of technical and organizational measures in order to guarantee the security of the processing.
The administrator does not transfer personal data provided to him by the data subjects to third countries outside the European Union. The transfer of personal data in this case can be carried outafter the Company has previously notified the data subject in writing, as well as the reason for the transfer.
Terms of storage of personal data
(amended by decision dated 30.06.2022) "Axiom Invest" Ltd. stores your personal data on paper and electronic media in accordance with the principle of "storage limitation". In particular, for the purposes described above, the Company will store:
· The personal data of customers are stored for a period of 5 (five) years from the termination of the relevant contract according to the general statute of limitations;
· Personal data of data subjects given on the basis of consent is stored for a period of 1 (one) from its receipt by the Administrator. In this case, the Company takes the necessary measures to notify the data subjects of this circumstance, providing them with the opportunity to give their consent again for a period of 1 (one) year;
Personal data contained in accounting documents are stored for the following periods:
- accounting registers and financial statements, including documents for tax control, audit and subsequent financial inspections - 10 (ten) years, starting from January 1 (first) of the accounting period following the accounting period to which they refer;
- all other carriers of accounting information - 3 (three) years, starting from January 1 (first) of the accounting period following the accounting period to which they refer.
Rights of data subjects and how to exercise them
(amended by decision dated 30.06.2022) Every client, after submitting a written application, has the right to access the personal data collected for him by "Axiom Invest" Ltd. In cases where, when the client exercises this right of access, personal data may also be disclosed to a third party, "Axiom Invest" Ltd. is obliged to provide the relevant client with access to the part of them that pertains only to him. When exercising their right of access, every customer of "Axiom Invest" Ltd. has the right at any time to request:
confirmation of whether data relating to him are being processed, information on the purposes of such processing, on the categories of data and on the recipients or categories of recipients to whom the data is disclosed;
a message to the client in an understandable form containing his personal data that is being processed, as well as any available information about their source;
information about the logic of any automated processing of personal data.
(amended by decision dated 30.06.2022) Every client has the right at any time to request from "Axiom Invest" Ltd. to:
delete, correct or block his personal data, the processing of which does not meet the requirements of the regulatory framework;
notify the third parties to whom his personal data has been disclosed of any deletion, correction or blocking carried out in accordance with the previous point, except in cases where this is impossible or involves excessive efforts.
(amended by decision dated 30.06.2022) At any time while "Axiom Invest" Ltd. stores or processes personal data, the client has the right to:
(amended by decision dated 30.06.2022) requested a copy of his personal data from "Axiom Invest" Ltd., as well as the right to access his personal data at any time;
(amended by decision dated 30.06.2022) request from "Axiom Invest" Ltd. his personal data in a form convenient for transfer to another personal data administrator, or request to do so without being hindered by him;
(amended by decision dated 30.06.2022) requested that "Axiom Invest" Ltd. correct, without unnecessary delay, inaccurate personal data, as well as data that are no longer up-to-date;
(amended by decision dated 30.06.2022) The client has the right to request from "Axiom Invest" Ltd. that the personal data be deleted without undue delay in the presence of any of the following grounds
the personal data are no longer necessary for the purposes for which they were collected;
when he has withdrawn his consent and data processing is based only on him;
(amended by decision dated 30.06.2022) when he has objected to the processing and "Axiom Invest" Ltd. has no legal basis to continue processing and/or storing the data;
when the processing is unlawful;
(amended by decision dated 30.06.2022) when personal data must be deleted in order to comply with a legal obligation under EU law or the law of a member state that applies to "Axiom Invest" Ltd. as a personal data administrator;
when personal data were collected in connection with the provision of information society services.
(amended by decision dated 30.06.2022) "Axiom Invest" Ltd. may refuse to delete the personal data of a client for any of the following reasons:
in exercising the right to freedom of expression and the right to information;
(amended by decision dated 30.06.2022) for compliance with a legal obligation by "Axiom Invest" Ltd.or for the performance of a task of public interest,
for reasons of public interest in the field of public health;
for the purposes of archiving in the public interest, for scientific or historical research or for statistical purposes, to the extent that deletion is likely to make it impossible or serious toore the achievement of the objectives of this processing; or for the establishment, exercise or defense of legal claims.
(amended by decision dated 30.06.2022) The client can request from "Axiom Invest" Ltd. to limit the processing of personal data, in which case the data will only be stored, but not processed. The refusal to limit will be expressly only in writing, as "Axiom Invest" Ltd. is obliged to justify the refusal with a legitimate reason;
the customer has the right to withdraw his consent to the processing of personal data at any time with a separate request addressed to the administrator;
the customer can object to certain types of processing, such as direct marketing (unsolicited advertising messages);
the customer has the right to object to automated processing, including profiling;
right not to be subject to a decision based solely on automated processing, including profiling;
(amended by decision dated 30.06.2022) If Axiom Invest Ltd. needs to use personal data for a new purpose, Axiom Invest Ltd. will provide a new data protection opinion and when and where necessary, it will require prior consent for the new processing.
(amended by decision dated 30.06.2022) If the customer wishes to exercise any of the rights listed above, he should notify the company in writing. In this case, it is possible that "Axiom Invest" Ltd. is not able to provide him with information about the services and/or products he requested, as well as it is not possible to provide him with the services and products themselves, therefore "Axiom Invest" Ltd. will not be liable to the customer in this regard.
Data subjects whose data are processed by the Administrator on the basis of their consent have:
· Right of access to the personal data, including to receive a copy of them. This right can be exercised by submitting a request for access to information or completing a form on site at the Company's office;
· Right to correct inaccurate or incomplete personal data by sending a request by email or filling out a form on site at the Administrator's office;
· Right to erasure (right to "be forgotten") of your personal data by sending an application or filling in the necessary form on the spot;
· Right to restrict processing, which can be exercised by sending an application or on paper at the Company's office;
· Right to data portability, which can be exercised by sending an application or on-site at the Company's office and filling in the necessary form;
· Right to object, which can be exercised by sending an application or by filling in the relevant paper form on site.
Responses to requests to exercise rights are received on site at the Company's office after the applicant has provided an identity card for reference. The company is in the process of building a system that will provide an opportunity to send a response electronically by encrypting the traffic.
Giving consent and withdrawing consent
We may request consent from data subjects in order to process personal data for one or more of the purposes specified by us. Consent must be a freely expressed, specific, informed and unambiguous indication of the will of the data subject.
Consent can be withdrawn at any time in the manner in which it was given. Consent can be withdrawn by sending a form or in person at the Company's office.
Right of appeal to the supervisory authority
In accordance with the General Data Protection Regulation and the Personal Data Protection Act, data subjects have the right to file a complaint with the Commission for Personal Data Protection at the address: Sofia, Prof. Tsvetan Lazarov" No. 2, or via the website: www.cpdp.bg.
Updating or deleting customer data
(amended by decision dated 30.06.2022) The client must inform "Axiom Invest" Ltd. in a timely manner that his personal data has been changed by providing his current data.
(amended by decision dated 30.06.2022) The client must inform "Axiom Invest" Ltd. if he wishes the company to delete his personal data by sending an email to compliance@axiominvest.eu
(amended by decision dated 30.06.2022) "Axiom Invest" Ltd. will change or delete the client's personal data according to his instructions, except to the extent, order and manner in which the company is obliged to preserve them due to regulatory or legal requirements, for to provide the client with the requested services, or due to the fact that it has provided them to the client in the past and now must store certain information within a legally defined period.
Personal data security measures
The client's non-public information and personal data are stored in a secure and strictly confidential manner - they are accessed and used only by the employees who service the client's account and by employees with control functions.
(amended by decision dated 30.06.2022) "Axiom Invest" Ltd. uses advanced security software in order to ensureof a safe and secure environment for trading, as well as for the protection of non-public personal, financial and commercial information of customers.
(amended by decision of 30.06.2022) "Axiom Invest" Ltd. encrypts all the personal data of its customers in order to be able to protect this data to the maximum extent.
All paper documents containing personal data are stored in locked cabinets in the Company's offices, and only authorized persons have access to them. The Administrator's premises have installed alarm systems that help limit unauthorized access to data.
Access to the Company's information systems is carried out through unique user accounts and passwords for each employee. Staff members undergo training immediately upon hire and fully comply with confidentiality rules, with no sharing of personal data with unauthorized persons.
Cancellation procedure
(amended by decision dated 30.06.2022) The policy of "Axiom Invest" Ltd. is not to disclose non-public information about the client to third parties, except in cases defined by law.
(amended by decision of 30.06.2022) The client is not obliged to provide any part of his non-public information or personal data that may be requested by "Axiom Invest" Ltd..
(amended by decision dated 30.06.2022) The client's refusal to provide the information or personal data requested by "Axiom Invest" Ltd. may lead to the impossibility of "Axiom Invest" Ltd.to open or maintain the client's account for trading in financial instruments or to provide him with financial services.
Changes to the Privacy Policy and protection of personal data
(amended by decision dated 30.06.2022) All changes to this Policy will be promptly published on the website of "Axiom Invest" Ltd. and will serve as a notification to customers.
Consent
(amended by decision dated 30.06.2022) By agreeing to accept this Policy, the client gives permission to "Axiom Invest" Ltd. to process his personal data only for the stated purposes.
(amended by decision dated 30.06.2022) Consent is necessary for Axiom Invest Ltd. to process both types of (ordinary and special) personal data, but it must be explicit.
(amended by decision dated 30.06.2022) In cases where "Axiom Invest" Ltd. requests consent for special (sensitive) personal data, it will always be justified why and how this information will be used.
(amended by decision of 30.06.2022) The client can withdraw his consent at any time by written request to "Axiom Invest" Ltd..
Applicable law
This Policy is governed by and interpreted in accordance with the legislation of the Republic of Bulgaria and disputes related to this Policy are resolved between the parties, and in the event of an impossibility - subject to resolution by the courts of the Republic of Bulgaria.
This Policy was adopted by a decision of the Managers from 31.01.2022. and amended by decision of 30.06.2022. and 17.04.2024.
