Your privacy is of utmost importance to us, and it is our priority to safeguard and respect the confidentiality of your information, your privacy, and your rights. By entrusting us with your information, we would like to assure you of our commitment to respect your personal data and act in accordance with the privacy and data protection legislation. We have taken all the required technical and organisational steps to protect the confidentiality, security and integrity of your personal information and adhere to applicable statutory data protection requirements, including but not limited to the General Data Protection Regulation (hereinafter referred to as “GDPR”), as illustrated herein.
This Policy sets out how NAGA collects, uses, discloses or processes certain personal information about you, while you are using NAGA’s official website at www.nagamarkets.com ((hereinafter referred to as the “ Website”), the NAGA App (hereafter referred to as the “ App”) and social networks whereby we maintain online presences (hereinafter referred to as the “Social Networks”), including any personal data you may provide through this Website, App and Social Networks when you obtain our services.
It also provides information on how and what personal data we may collect from third parties. Additionally, it provides information on how you can exercise your rights with respect to the processing of your personal data. This Policy applies to the processing activities performed by NAGA Group to the personal data of its clients and potential clients, website and app visitors and users as in order to provide our products and services to you we need to collect your personal information as specified in this Policy.
We would like to point out that our services are not aimed at children under 18 years. We do not knowingly collect information from children under the age of 18. If you have not reached the age limit, do not use the services and do not provide us with your personal information. If you are a parent of a child below the age limit and you learn that your child has provided us with personal information, please contact us on the following information, in order to exercise your rights as explained in more detail below.
Additionally, if you have concerns about how we use your personal data, or requests on how to exercise your legal rights, please use the contact details below:
Entity: NAGA Markets Europe Ltd
Contact Person: Data Protection Officer
Email address: email@example.com
Postal address: Agias Zonis 11, 3027, Limassol, Cyprus
Telephone Number: +357 25041410
For the purposes of this Policy:
The Company reserves the right to amend this document from time to time and we will notify you appropriately and accordingly. We do however encourage you to review this statement periodically to be always informed about how we are processing and protecting your personal data and contact our Data Protection Officer (DPO) at firstname.lastname@example.org if you have any concerns.
If you are a potential client and/or a client and/or a visitor to the website or to the App, the data we process are:
Aggregated data i.e., statistical information. By the word aggregated data, we mean a group of data with which people cannot be identified, for example number of people who visiting our website during the day.
THE FRAMEWORK OF THE CLIENT AGREEMENT (PERFORMANCE OF CONTRACT): We process personal data to provide our services and products, as well as information regarding these services and products, based on our contractual relationship with you. We need, therefore, to use your personal data to perform our services and comply with our contractual obligations to you. In this framework, we need to verify your identity to accept you as our client, and we will need to use those personal details to effectively manage your account with us.
COMPLIANCE WITH LAWS AND REGULATIONS (LEGAL OBLIGATION): numerous laws to which we are subject to, as well as specific statutory requirements (such as anti-money laundering laws, Cyprus Securities and Exchange Commission (CySEC) laws and regulations, financial services laws, corporation laws, privacy laws and taxation laws) dictate that we hold and process personal data. Such obligations and requirements impose on us necessary personal data storage and processing activities. It is mandatory, for example, to store personal data, for record-keeping purposes. In general, complying with applicable laws, court orders, other judicial process, or the requirements of any applicable regulatory authorities may require the processing of personal data by NAGA.
SAFEGUARDING OUR INTERESTS (LEGITIMATE INTERESTS): We process personal data to safeguard the legitimate interests pursued by NAGA. Examples of such processing activities include our initiating legal claims and preparing our defence in litigation procedures and processing personal data for risk management purposes. Further, we may need to use personal information collected from you to investigate issues or to settle disputes with you because it is in our legitimate interests to ensure that issues and disputes get investigated and resolved in a timely and efficient manner. We may also implement procedures based on specific and limited criteria to exchange data regarding suspected abuse of anti-money laundering rules with NAGA Group, with strict limitation on access, security and prohibition of any further use for other purposes.
CASES YOU HAVE CONSENTED TO: We may process your personal data to provide direct marketing about our products or services, whereby your explicit consent is required. Please be informed that, if we rely on your consent as our legal basis for holding and processing your personal information, you have the right to revoke your given consent at any time, by contacting our DPO email@example.com. However, please bear in mind that any processing of personal data that took place prior to the receipt of your revocation, will not be affected.
The below table provides in detail the purposes for the processing of your data and the legal basis for such processing:
|Verify your identity||Performance of a contract /contract|
|Establish your account||Performance of a contract /contract|
|Provide you with our services including products, administrate your account and provide you with technical support||Performance of a contract /contract|
|Respond to your inquiries or requests||Performance of a contract /contract|
|Monitor your trading activity to ensure and/or monitor execution quality.||Performance of a contract /contract|
|Provide you with customer support services||Performance of a contract /contract|
|Deal with your complaints||Legitimate interest|
|Keep you informed about new products and services and tailor this information to your needs and interest unless you decide to not receive such notifications.||Consent|
|Provide you with information about our partners’ promotions or offers which we think you might be interested in||Consent|
|Ask your opinion about our products or services||Consent|
|Monitor and improve our Website/ App and products||Legitimate interest|
|Collect your feedback about our Website/ App and products, including statistics and analytic data||Consent|
|Records keeping||Legitimate interest|
|Profiling including automated decision (evaluate your knowledge and experience in the financial products that we offer, as well as your investment objectives including your risk tolerance and financial situation, is used to form your economic profile and confirm our assessment of the degree to which such financial products are appropriate to you)||Legal obligation|
|Prevent, detect, and investigate illegal activities including Money Laundering and Financing Crimes||Legal obligation|
These datasets may be shared internally in NAGA Group or externally with others, including non-NAGA Group companies. We produce these reports using information about you and other Clients. The information used and shared in this way is never personal data and you will never be identifiable from it. Anonymous statistical data cannot be linked back to you as an individual.
For example, some countries have laws that require us to report spending statistics and how money enters or leaves each country. We’ll provide anonymised statistical information that explains the broad categories of merchants that NAGA clients in that country spend their money with. We’ll also provide information about how NAGA clients top up their accounts and transfer money. However, we won’t provide any client-level information. It will not be possible to identify any individual NAGA client.
The Company may share your personal data for the purposes of processing transactions and providing services relating to your account, as well as to secure our legitimate interests and to comply with our legal obligations in regard to suspected abuse of anti-money laundering rules with any NAGA Group entity. Such sharing of data in NAGA Group includes and is not limited to the data and documents collected by the Company for identification purposes.
Where it is required to disclose your personal data to third parties’ processors, we ensure that the relevant provisions of GDPR are respected. Specifically, will share data only with those processors who has implemented such policies and procedures and have in place specific measures with which they ensure an adequate level of protection as required by the GDPR. We also do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Finally, where such third parties act as our ‘processors’, we also have in place the required contractual agreements for the protection of personal information in process.
The table below explains which suppliers we normally share your personal data with:
|Type of supplier||Why we share your personal data|
|Suppliers who provide us with IT and payment services||To help us provide our services to you|
|Platform providers||To help us provide trading services to you|
|EMI, Bank Institutions, Payment Institutions||To safekeep your assets and/or execute your deposits/withdrawals.|
|Administrative systems (KYC onboarding service providers, translation, due diligence, finance, reporting, risk analysis)||To help us perform checks in order to decide whether to provide our services to you and to maintain our daily operations|
|Internal Auditors||To help us comply with our legal obligations.|
|Analytics providers and search information providers||To help us improve our website or app|
|Customer-service providers, survey providers and developers||To help us to provide our services to you|
|Communications services providers||To help us send you emails, push notifications and text messages|
|Data storage||To store your data|
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
We may store or transfer your personal data outside the European Economic Area (EEA) for business and management purposes, for the performance of our contractual obligation owed by us to you, or for the provision of services that you may request from us. For example, we may disclose your personal data to keep to global legal and regulatory requirements, to provide ongoing support services, to credit reference agencies, fraud prevention agencies, law enforcement authorities and to enable us to provide you with products or services you have requested.
Please be informed that, unless you have provided us with your explicit consent, we will only transfer your data out of European Economic Area where:
Where we may transfer data outside of European Economic Area, we take extra safeguards to ensure the security of such transfers including but not limited to Data loss prevention, file – level encryption, transport encryption, cloud data protection, database encryption etc.
We maintain online presences in Social Networks to interact with you and, among other purposes, to provide information about our products and services.
Furthermore, be noted that these Networks are publicly accessible and, therefore, any personal information, comment, or content you may provide through the Social Networks, may be publicly visible or available. For this reason, we strongly recommend you to be aware of the information you are presented with on these Networks.
While operating our online Social Network accounts, we may have access to information such as statistical data about the use of our Social Accounts, which is provided by the Social Networks. You may refer to the list below for details of the Social Network data that we may access as administrators of these social accounts.
Google My Business
We operate a so-called Google My Business entry. Should you connect with us in this way, we will use the information service offered by Google and the services of Google Ireland Limited, (hereinafter referred to as “Google”), for which you may find more information above. We would like to point out that you use the Google site and its functions on your own responsibility. This applies in particular to the use of the social and interactive functions (e.g. commenting, sharing, rating, direct messaging). When you visit and interact with our Google My Business listing, Google also collects your IP address and other information that is present on your terminal device in the form of so-called cookies. We may also be provided, as the operator of the Google My Business listing, with statistical information about the use of Google services. We, as the provider of our Google My Business entry, do not collect or process any further data from your use of this Google service.
The Company has adopted practice controls and security measures to ensure high level of information security and compliance with the relevant provisions of GDPR. Indeed, our administrative, physical, and technical safeguards that are implemented and maintained, protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, sorted, or otherwise processed. Employees have been trained on how to use and process personal data according to the provisions of the GDPR and the relevant CY legislation and are authorized to access personal data only to the extent necessary to serve the applicable legitimate purposes for which the personal data are processed by the Company and to perform their duties.
Furthermore, we consider the safeguard of the personal data by design and by default. This means that we have implemented the appropriate technical and organisational measures to comply with the principles of the GDPR and to secure the confidentiality of the information we hold about you, such as encryption of data, pseudonymisation of data, backups ensuring the restoration and availability of data and additional evaluation of the effectiveness of the measures in place. Finally, we continually balance the risks for your rights and freedoms through the management risk assessments, while we assess our measures from time to time.
Details of these measures may be available upon request at firstname.lastname@example.org and to the discretion of the DPO.
The Company is assessing your knowledge and experience and is also obliged to assess your financial situation and investment objectives and your risk profile once per calendar year in accordance with relevant laws and regulations. This action is in accordance with Anti-money laundering (AML) Law and related Circulars, guidelines and or Regulations or Directives on this matter. For this processing we use the Appropriateness questionnaire.
The Appropriateness Questionnaire occurs once you register as a client at NAGA where we need to check and ensure that you are suitable for the provision of services and products we offer. This is an evaluation test regarding your knowledge, financial background and experience with financial services and based on the scoring you receive, you will be informed whether you are eligible to receive our services and become our client and the maximum level of leverage you are eligible to. This ensures that our services and products are both suitable for you and in our best of interests.
For this purpose, we may use technology that can evaluate your personal circumstances and other factors to predict risks or outcomes. We do this for the efficient running of our services and to ensure decisions are fair, consistent, and based on the right information. We further use this technology:
Where we make an automated decision about you, you have the right to ask that it is manually reviewed by a person as explained in your Rights (in Section 17) below.
We assure you that NAGA takes all the technical and operational measures to correct inaccuracies and minimize the risk of errors,to prevent any discrimination and to secure your personal data. The scorings above are monitored by the Compliance department of NAGA and should you need any clarification, you may contact us at email@example.com
The Company will record, monitor, and process any telephone conversations and/or electronic communications you have with us such as via phone, email, Social Networks, or electronic message. All such communications are recorded and/or monitored and/or processed by us, including but not limited to any telephone conversations and/or electronic communications that result or may result in transactions or client order services even if those conversations or communications do not result in the conclusion of such transactions. All incoming and outgoing telephone conversations as well as other electronic communications between you and NAGA will be recorded and stored for quality monitoring, training, and regulatory purposes. The content of relevant in person conversations and/or communications with you may be recorded by minutes or notes. Any such records shall be provided to you upon request at the same language as the one used to provide our services to you.
NAGA retains your personal information on secure servers and appropriate procedures and measures are in place to ensure that your personal data is safeguarded as this is of utmost importance to us. We will hold your personal information while we have a business relationship with you and as permitted by relevant laws and regulations. The retention of your personal data is limited for the purposes we collected it for and to comply with any legal, regulatory, accounting, taxation or reporting requirement. To determine the appropriate retention period for personal data, in accordance with the provisions of GDPR, we consider various factors including, but not limited to, the amount, nature, and sensitivity of the personal data, and the potential risk of harm from unauthorised use or disclosure of your personal data.
Moreover, when we consider that personal information is no longer necessary for the purpose for which it was collected, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time. For example, we are subject to certain anti-money laundering and taxation laws which require us to retain the following, for a period of five (5) or (7) years in accordance to the anti-money laundering laws and six (6) years in accordance to the taxation laws:
Upon termination of this period, NAGA will destruct those records since our legal obligation will not apply anymore.
Also, the personal information we hold in the form of a recorded communication, by telephone, electronically, in person or otherwise, will be held in line with local regulatory requirements (i.e., 7 years after our business relationship with you has ended or longer in order to secure our legitimate interests (such as handling a dispute with you). If you have opted out of receiving marketing communications, we will hold your details on our suppression list so that we know you do not want to receive these communications.
Finally, we may keep your personal data for longer because of a potential or ongoing court claim, or for another legal reason.
You must be aware that GDPR is recognising you as a “Data subject” and you have certain rights which you can exercise freely and to your own discretion, as per below:
If you wish to exercise any of the above, you must send an email to the DPO of NAGA at firstname.lastname@example.org and your request will be further handled. Your ability to exercise these rights will depend on several factors. Sometimes, we will not be able to agree to your request (for example, if we have a legitimate reason or a legal obligation for not doing so or the right does not apply to the information we hold about you, or your rights affect the rights and freedoms of others).
Please be informed of the following:
Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Personal Data Protection Commissioner’s Office:
Address: Iasonos 1, 1082 Nicosia, Cyprus
Copyright © 2023 – All rights reserved.
NAGA is a trademark of The NAGA Group AG, a German based FinTech company publicly listed on the Frankfurt Stock Exchange | WKN: A161NR | ISIN: DE000A161NR7.
The website is owned by The NAGA Group AG and operated by NAGA Markets Europe LTD which is authorised and regulated by the Cyprus Securities and Exchange Commission (CySEC) under licence No. 204/13. The registered address of NAGA Markets Europe LTD is 7, Ariadnis Street, Mouttagiaka, 4531, Limassol, Cyprus.
The NAGA Group AG is the holding company of NAGA Markets Europe Ltd, NAGA Technology GmbH, NAGA Global LLC and NAGA Capital Ltd.
RISK WARNING: CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. 86.87% of retail investor accounts lose money when trading CFDs with this provider. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.
Trading with NAGA Trader by following and/or copying or replicating the trades of other traders involves high levels of risks, even when following and/or copying or replicating the top-performing traders. Such risks include the risk that you may be following/copying the trading decisions of possibly inexperienced/unprofessional traders, or traders whose ultimate purpose or intention, or financial status may differ from yours. Before making an investment decision, you should rely on your own assessment of the person making the trading decisions and the terms of all the legal documentation.
Restricted regions: NAGA Markets Europe LTD offers services to residents within the European Economic Area and Switzerland, excluding Belgium. NAGA Markets Europe LTD does not provide investment and ancillary services in the territories of third countries.
Affiliate programs are not permitted in Spain for the investment service commercialisation or client acquisitions by unauthorised third parties.
Los programas de afiliados no están permitidos en España para la comercialización de servicios de inversion y captación de clientes por parte de terceros no autorizados.