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Privacy Policy

DBG Markets · Last updated November 2023

We value your privacy and are committed to safeguarding your personal data. This Policy outlines what we collect, how we use it, and the measures we take to keep it secure. By using our services, you acknowledge how we handle your personal data in accordance with this Policy.

This Policy may be updated from time to time. Material changes will be reflected on our website. Questions? Contact our Data Protection Officer at compliance@dbgm.com.

Section A

Records or Personal Data That May Be Retained

Category	Records
Operations	Brochures and company information, client registry, contracts, general correspondence, work-in-progress, marketing material, policies and procedures
Financial Records	Accounting records, annual statements, asset register, banking records, contracts, financial transactions, insurance information, management accounts, tax records
Information Technology	IT policies and procedures
Special Information	Offences / alleged offences; criminal proceedings, outcomes & sentences
Possible Recipients	Banks and financial institutions, ombudsman, regulatory and government bodies, third party verification agencies and credit bureaus

Data Subjects	Personal Information Processed
Natural Persons (Clients, Agents, Contractors)	Name, address, date of birth, ID number, tax info, nationality, gender, email, telephone
Service Providers	Name, registration number, VAT number, address, bank details
Employees (Current, former, temporary)	Name, address, qualifications, identity numbers, bank details, tax info, nationality, email, contact numbers
Juristic Persons	Contact names, legal entity name, registration number, address, founding documents, tax info, authorised signatories and beneficial owners

Section B

Incomplete or Inaccurate Information

If you provide incomplete or inaccurate information, we may be unable to fulfil your service requests. Please ensure all information is accurate and up to date. To update your contact details, email support@dbgm.com.

Section C

Safeguarding Your Personal Data

We implement appropriate technical and organisational measures to protect your information. Employees handling personal data are trained on confidentiality. Privacy violations are treated seriously and may result in dismissal.

Acceptable usage of personal information
Access control to personal information
Computer and network security (firewalls, virus protection)
Governance and regulatory compliance
Internal breach reporting processes
Investigation and response to security incidents
Logical and physical access control
Monitoring of access and usage
Physical security measures
Retention and disposal procedures
Secure communications
Security in outsourced activities via contracts
Ongoing staff training

Section D

Processing of Personal Information

All processing is carried out with the data subject's consent in compliance with applicable data protection law. Employees and contractors must follow these guidelines:

Personal information must only be used for lawful purposes.
Processing must be adequate, relevant, and not excessive in scope.
Information may only be collected with the data subject's consent. The burden of proof lies with the employee or contractor.
Only information necessary for a specific purpose may be collected.
Information must not be retained longer than necessary, unless required by law or contractual agreement.
Records must be updated when the data subject provides new or updated information.

Section E

Transfers of Your Personal Data

We may transfer your personal information to other DBG Group companies and processors outside Anguilla, including entities in Singapore, Australia, and South Africa. All transfers are conducted lawfully with appropriate security arrangements in place.

Section F

Data Retention

We retain personal data only for as long as necessary to provide our services and meet legal, accounting, or regulatory requirements. Regulators may require us to retain basic client information for up to six years after the client relationship ends.

To request deletion of your personal data, email support.al@dbgm.com. Data no longer needed is securely destroyed.

Section G

Right to Access Personal Information

You may request a record or description of your personal information held by us, including the identity of any third parties who have accessed it. Submit your request using the form below.

Application to Request Access to Personal Information

A. Particulars of Requesting Person

Full Names and Surname

Identity Number

Postal Address

Telephone

Fax

Capacity (if acting on behalf of another)

B. Person on Whose Behalf (complete only if applicable)

Full Names and Surname

Identity Number

C. Record Requested

Description of record or portion requested

D. Reference Number / Heading

Reference (if applicable)

E. Further Particulars

Additional details

Signature of Requester

Signed at _____________ on day ____ of _____________ year _____

Request received from

Acting on behalf of (if applicable)

Signature of Information Officer

Section H

Forbidden Uses of Personal Information

Employees and contractors may not use company access to personal data for personal gain, including soliciting for commercial ventures, religious causes, or non-job-related purposes.

Misuse of personal data will result in disciplinary action, which may include dismissal. The Company may access any device used for business purposes if a policy contravention is suspected.