1. Introduction
1.1. Netrios Ltd. (“Netrios” or “the Company”) is incorporated in the British Virgin Islands (“BVI”) with Company Number 2086602. Netrios is a licensed entity under the Securities and Investments Business Act (“SIBA”) 2010 under:
- Category 1: Dealing in Investments
- Sub-Category B: Dealing as Principal.
1.2. As a Regulated Company, Netrios is required to maintain a Record Privacy Policy (“the Policy”) in accordance with the Data Protection Act 2021. The present Policy sets out the general applicable record-keeping requirements.
2. Scope
2.1. This Privacy Notice (“Notice”) aims to give you information on how we collect and process your Personal Data through or in conjunction with your use of this website and our services.
2.2. This Notice stipulates details and conditions of collecting and processing your personal details and provides you with information in accordance with the transparency principle and requirements under the applicable data protection laws.
2.3. This Notice delineates the methods by which we acquire and handle your Personal Data via the digital interfaces and software programs associated with this Privacy Notification.
2.4. The https://netrios.com/ (the “Site”) is not intended for children and we do not knowingly collect data relating to children (below 18 years of age).
2.5. By using our website, you consent to the data practices described in this Notice and all extensions and addendums to this Notice.
3. Data Collection
3.1. In accordance with the information we gather pertaining to our users:
Personal Data means any information that identifies you as an individual or that relates to an identifiable individual. Whenever it is not possible or feasible for us to make use of anonymous and/or anonymized data (in a manner that does not identify any users of the Site or customers of our services), we are nevertheless committed to protecting your privacy and the security of your Personal Data at all times.
3.2. Data obtained from you: We may collect from you, through interaction with you or through your interaction with us or our services different kinds of Personal Data about you which we have grouped together as follows:
i. Automatic Collection Through Tracking Technologies: Information about the devices used to access Netrios’ websites is automatically collected. This includes: IP address; device identifier; web browser details; browsing details through cookies and other tracking technologies.
ii. Third-party Data Sources: Netrios may obtain Personal Data from third-party sources, which may include demographic information, professional information, etc. This data may be acquired from publicly available online sources.
iii. Data Merging and Analytics: When necessary and in compliance with applicable laws, Netrios may merge this data with existing information for purposes such as benchmarking and market data analytics.
4. Data Usage
4.1. At Netrios, we prioritize the protection and respectful handling of your Personal Data. This section outlines how we utilize the information we collect from you through our website and services.
4.2. Purposes of Personal Data Usage. We may collect and use Personal Data for the following purposes:
i. Improving services and website functionality: Your feedback and usage patterns help us enhance our services and optimize website performance.
ii. Distributing newsletters and alerts: With your consent, we send newsletters and alerts to keep you informed about updates and relevant information.
iii. Analyzing website performance: We may analyze user behavior and website interactions to improve user experience and functionality.
iv. Complying with legal obligations: we may process Personal Data to comply with regulations such as FATCA and CRS. This ensures adherence to anti-money laundering laws and international tax compliance standards, allowing us to fulfil our legal duties and maintain regulatory standards effectively.
v. Executing Netrios agreements: Personal Data may be used to execute agreements between Netrios and its users or partners.
4.3. Necessity of Personal Data. The collection and processing of Personal Data are justified by the following reasons:
i. Essential for website operation and client services: Certain Personal Data is essential for providing you with access to our platform and delivering our services effectively.
ii. Used for providing market data products: We may use your data to provide you with market data services or similar offerings.
iii. Analyzed for personalized content and services: In instances where analysis of your Personal Data is conducted, such action assists us in tailoring our content and services to better align with your preferences and needs.
iv. Retained for future communication purposes: We may retain your data to communicate with you regarding your account, updates and relevant information.
4.4. Use of Cookies and Tracking Technologies. We utilize cookies and tracking technologies for the following purposes:
i. Website management and analytics: Cookies help us manage website operations and analyze user behavior to improve our services.
ii. Monitoring user interactions: We may use cookies to monitor how users interact with our website and services to enhance user experience.
iii. Tracking links opened or interacted with in communications: Cookies may be used to track links opened or interacted with in communications sent to you.
5. Legal Basis for Processing Personal Data
5.1. This Section outlines the legal framework that governs the processing of Personal Data by the Company:
i. Legitimate Interest: We may process your Personal Data based on our legitimate interest in promoting and safeguarding Netrios. This includes fostering and managing relationships, recruitment activities and delivering our services effectively.
ii. Consent: With your explicit consent, we may utilize your data for various purposes, such as creating user profiles, sending newsletters or alerts, and for business-related enhancements to your website experience.
iii. Performance of Contract: Processing of your data may occur to fulfill our contractual obligations to provide you with our services. This ensures the performance and delivery of agreed-upon terms between you and Netrios.
iv. Legal Compliance: In certain instances, we may process your data to comply with legal requirements, including fulfilling our legal obligations.
5.2. Direct Marketing: In compliance with relevant laws and regulations and through a legitimate interest or with your consent, Netrios may periodically notify you about similar products or services. This includes but is not limited to, new services and promotions, bonuses and offers. This notification may be conveyed through (i) electronic email (or SMS), or (ii) social media, or (iii) live phone calls, or (iv) push notification (desktop and/or app).
5.3. When relying on legitimate interest, Netrios will give you the opportunity to oppose such direct marketing when registering on our Site.
5.4. When relying on consent, the consent may be granted by you when registering on our Site.
6. Disclosure of Personal Data
6.1. At Netrios, we prioritize the protection and confidentiality of your Personal Data. It is imperative for us to transparently communicate how your information may be disclosed and transferred, especially on an international scale. Below, we delineate the protocols and safeguards in place:
i. Recipient Identification: Netrios reserves the right to transfer Personal Data globally to subsidiaries, affiliates and third-party service providers. Such transfers are conducted with the utmost care and adherence to data protection standards.
ii. International Data Transfer Protocols: Safeguards are implemented to ensure the security and integrity of your data, particularly during international transfers. These measures encompass encryption, pseudonymization and contractual agreements with recipients to uphold data protection standards.
iii. Consent and Legal Obligations: Your Personal Data will not be shared with third parties without explicit consent, except where mandated by law. Netrios complies with legal requirements and only discloses information when necessary for legal proceedings, law enforcement purposes, or governmental requests.
iv. Legal Compliance: Netrios may disclose Personal Data if required by law, law enforcement agencies, or government officials. Additionally, information may be shared to prevent harm, illegal activities, enforce contracts, or support corporate functions in accordance with applicable laws and regulations.
v. Recipient Notification: In cases where data rectification, deletion, or processing limitation is requested by individuals, Netrios will notify relevant third-party recipients to ensure compliance with such requests.
vi. Business Transition: In the event of re-organization, merger, or sale, Personal Data may be disclosed or transferred as part of the business transition process. Netrios will take appropriate measures to safeguard the confidentiality and integrity of your information throughout such transitions.
6.2. By availing our services or accessing our platform, you acknowledge and consent to the disclosure and transfer of your Personal Data as outlined in this Section.
7. Third-Party Sites
7.1. Netrios may provide links to external websites or information as a service. Clicking these links redirects users away from Netrios’ site.
7.2. It is important to note that Netrios neither endorses nor sponsors any third parties or their sites.
7.3. Users are solely responsible for their use of these external links, which is subject to the terms and privacy notices of the respective third-party websites.
8. Retention
8.1. . We will retain your Personal Data only as long as necessary to fulfil the purposes for which it was collected, including meeting any legal, accounting, or reporting obligations. This practice is in line with our Record Retention Policy, which adheres to regulatory standards.
8.2. The criteria we use to determine what is ‘necessary’ depends on the nature of the particular Personal Data in question. Our normal practice is to determine whether there is/are any law(s) (for example license requirement, tax or corporate laws, etc.) permitting or even obliging us to keep certain Personal Data for a period of time (in which case we will keep the Personal Data for the maximum period indicated by any such law) and if not, whether there are any laws and/or contractual provisions that may be invoked against us by you and/or third parties and if so, what the prescriptive periods for such actions are. In the latter case, we will keep any relevant Personal Data that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you and/or third parties.
8.3. Where your Personal Data is no longer required by us, we will either securely delete or anonymize the Personal Data in question.
9. Data Security
9.1. We have implemented security measures to safeguard your Personal Data from accidental loss, unauthorized access, alteration or disclosure. To comply with the law, we employ industry-standard encryption techniques to encrypt data during transit and at rest, ensuring confidentiality and integrity at all times.
9.2. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a need to know business requirement. They will only process your Personal Data on our instructions or subject to a lawful ground, as well as their duty of confidentiality.
9.3. Netrios cannot provide absolute assurance of safeguarding against unauthorized access or breaches. In the event of a data breach, Netrios will conduct a thorough risk assessment and notify impacted individuals in accordance with applicable local laws.
10. Your Rights regarding Personal Data
10.1. You have the right to request confirmation of how we process your personal data. Upon request, we will provide access to the following information:
a) The personal data we hold about you.
b) The purposes for processing your data.
c) The recipients of your data.
d) The retention period, if applicable.
e) Any data transfers and related safeguards.
f) Your rights concerning your data.
g) The process for filing a complaint.
h) The source of your data.
i) Whether automated decision-making or profiling has been used.
10.2. You have the right to request deletion of your data under the following circumstances:
a) The data is no longer needed for its original purpose.
b) You withdraw consent, and no other legal basis for processing exists.
c) You successfully object to processing.
d) The data has been unlawfully processed.
e) We are legally required to erase it.
10.3. You may also request to restrict the processing of your data, meaning it can be stored but not further processed, under specific conditions:
a) If data accuracy is contested.
b) If processing is unlawful and you oppose erasure.
c) If data is no longer needed for its original purpose but is required for legal claims.
d) If you object to processing and we are verifying whether our legitimate grounds override your objection.
10.4. Data will only be processed during a restriction with your consent, for legal claims, to protect another’s rights, or for important public interests.
10.5. You may request your data in a machine-readable format or have it transferred to another controller, if feasible and without infringing others’ rights. This applies if processing is based on consent or a contract and is automated.
10.6. You also have the right to object to processing based on legitimate interests or public tasks, and to any processing for direct marketing, including related profiling.
10.7. If processing is based on your consent, you may withdraw consent at any time. We will determine if another legal basis exists to continue processing your data and inform you accordingly.
10.8. Finally, you may lodge a complaint with the relevant supervisory authority, though we encourage you to first attempt resolution with us.
11. Cookies
11.1. Netrios Site uses cookies, for further information on what cookies are, which cookies we use, how and why we use cookies and how you can control which cookies are dropped, please read our Cookies Notice.
12. Amendments to Netrios’ Privacy Notice
12.1. Through utilization of the Site, you acknowledge and consent to the acquisition, utilization, and retention of your Personal Data by the company, as delineated within this Privacy Notice and other pertinent sections of the platform.
12.2. We retain the prerogative to modify this Privacy Notice periodically. Notification of such alterations shall be disseminated by means of updating this Privacy Notice.
12.3. In instances where substantial modifications are made, granting us additional privileges concerning the utilization of Personal Data previously obtained from you, we shall seek your consent either through electronic communication to your designated email address or by publishing details regarding said alterations on our platform.
13. Contact Details
13.1. For inquiries pertaining to the retention period of the data you provide to us or for any other questions related to data privacy, please direct your correspondence to our customer support at [email protected]