Privacy Policy

Privacy Policy

Effective Date: September 26, 2024

At J. Knobel Investor Services Limited, your privacy is a top priority. This Privacy Policy outlines how we collect, use, and protect your personal data when you visit our website, use our services, or otherwise interact with us. We are committed to safeguarding your personal information and ensuring transparency in how we handle your data.

By using our website or services, you agree to the terms of this Privacy Policy.

  1. Who We Are
  2. Knobel Investor Services Limited is a tied agent of Mega Equity Securities and Financial Services Public Limited, an investment firm regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 011/03. We provide investment advice and related services to clients and operate in compliance with the General Data Protection Regulation (GDPR).
  3. Information We Collect

We collect and process the following types of personal data:

2.1 Personal Information

  • Identification details: Full name, email address, phone number, postal address.
  • Financial information: Information related to your financial situation, such as investment experience, risk tolerance, and income levels, typically collected as part of our suitability assessment process.
  • Account details: Client ID, account numbers, and other information relevant to your brokerage account.
  • Communication data: Information contained in communications with us (emails, phone calls, online chats).

2.2 Usage Information

  • Website usage data: When you visit our website, we collect information about how you interact with the site, such as your IP address, browser type, device information, and pages visited. We use cookies to collect this data (see Section 7 for our Cookies Policy).

2.3 Sensitive Data

In the course of providing investment advice and services, we may collect sensitive personal data, such as financial information or information relating to your investment preferences and risk tolerance. We will only collect this information with your explicit consent and ensure that it is handled with the highest level of care.

  1. How We Use Your Information

We process your personal data to provide you with the best possible service and to comply with our regulatory obligations. Specifically, we use your data for:

3.1 Service Provision

  • Providing investment advice, risk assessment, and brokerage services.
  • Completing suitability assessments to ensure that the advice we offer is appropriate to your financial situation.
  • Handling transactions and executing orders through our principal firm, Mega Equity Securities and Financial Services Public Limited.

3.2 Compliance with Legal Obligations

  • Meeting regulatory requirements under MiFID II and CySEC rules.
  • Carrying out Know Your Client (KYC) and anti-money laundering checks.
  • Maintaining accurate records for auditing and compliance purposes.

3.3 Communication

  • Responding to your inquiries or requests.
  • Notifying you about updates to our services or important regulatory information.
  • Providing you with your suitability report or other investment-related documents.

3.4 Improving Our Services

  • Analyzing website usage and customer feedback to enhance our service offerings.
  • Conducting internal audits and performance assessments to ensure high-quality service delivery.
  1. Legal Basis for Processing Your Data

We rely on the following legal grounds to process your personal data:

  • Contractual obligations: We process your data to fulfill our obligations under the agreements we enter with you, such as providing investment advice and transmitting your orders to our principal firm.
  • Legal and regulatory compliance: We are required by CySEC and MiFID II regulations to collect and process certain information for compliance, including KYC checks and suitability assessments.
  • Legitimate interests: We may process your personal data to pursue our legitimate business interests, such as improving our services and ensuring the security of our systems.
  • Consent: In cases where we collect sensitive data or where required by law, we will seek your explicit consent before processing such information.
  1. Sharing Your Information

We will only share your personal data with third parties in limited circumstances and in compliance with GDPR:

5.1 Principal Firm (Executing Broker)

As a tied agent, we transmit your information to Mega Equity Securities and Financial Services Public Limited for the purpose of completing account setup, executing orders, and complying with regulatory obligations.

5.2 Service Providers

We work with trusted third-party service providers who assist us with IT services, data storage, and compliance operations. These providers are bound by confidentiality agreements and only process your data in accordance with our instructions.

5.3 Legal and Regulatory Authorities

We may be required to disclose your personal information to CySEC, tax authorities, or other regulatory bodies in order to comply with legal and regulatory obligations.

5.4 Business Transfers

In the event of a merger, acquisition, or other business reorganization, your data may be shared with the relevant entities involved in the transaction, subject to strict confidentiality obligations.

  1. Data Security and Retention

6.1 Data Security

We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it from unauthorized access, loss, or misuse. These include:

  • Encryption of sensitive data.
  • Secure storage systems and firewalls.
  • Access controls to limit data access to authorized personnel only.

6.2 Data Retention

We retain your personal data only for as long as is necessary for the purposes outlined in this Privacy Policy or as required by law. Typically, we retain:

  • Client records: For a minimum of 5 years after the termination of our business relationship, as required by MiFID II.
  • Compliance records: For the duration required by regulatory authorities (e.g., KYC and AML data).
  1. Cookies Policy

We use cookies to enhance your experience on our website and to gather usage data. Cookies are small text files placed on your device by the websites you visit. You can control your cookie preferences through your browser settings, but disabling cookies may limit your use of certain website features.

Types of Cookies We Use

  • Essential Cookies: These cookies are necessary for the proper functioning of our website. They allow you to navigate the site and use features like form submissions and secure areas.
  • Performance Cookies: We use cookies to track website performance and improve user experience, such as caching pages for faster loading times.
  • Functionality Cookies: These cookies store your preferences and allow us to offer personalized features, such as form data or remembering login information.
  • Analytical Cookies: These cookies help us analyze user interactions with our site to optimize the user experience and marketing strategies.

How We Use Collected Data

Data collected through cookies is used to:

  • Ensure site functionality and security.
  • Enhance the performance of our website.
  • Track form submissions and other user interactions for improving our services.
  • Facilitate communication with users as part of our client onboarding and marketing processes.

Your Data Privacy

We do not sell your data or share it with third-party advertisers. Data collected via cookies is only used for the purposes outlined above. Where third-party integrations are used (e.g., for email or form submissions), these are securely managed under your own control.

You can control or disable cookies through your browser settings. However, disabling essential cookies may affect the website’s functionality.

Your Data Rights

Under the GDPR, you have several rights with regard to your personal data:

  • Right to Access: You can request a copy of the personal data we hold about you.
  • Right to Rectification: You can request that we correct any inaccurate or incomplete data.
  • Right to Erasure: You can request that we delete your personal data, subject to regulatory retention requirements.
  • Right to Restriction: You can request that we limit the processing of your personal data in certain circumstances.
  • Right to Data Portability: You can request that we transfer your personal data to another service provider in a structured, commonly used format.
  • Right to Object: You can object to the processing of your personal data where we rely on legitimate interests.

If you wish to exercise any of these rights, please contact us at privacy@jknobel.com.

  1. International Data Transfers

Your personal data may be transferred to and processed in countries outside of the European Economic Area (EEA). When transferring data outside the EEA, we ensure that appropriate safeguards are in place to protect your data, such as standard contractual clauses approved by the European Commission.

  1. Complaints and Contact Information

If you have any concerns or questions about how we handle your personal data, or if you wish to make a complaint, you can contact our Data Protection Officer (DPO) at:

Email: dpo@jknobel.com
Phone: +357 22 258 790

If you are not satisfied with our response, you have the right to lodge a complaint with the Cyprus Data Protection Commissioner.

  1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make significant changes, we will notify you via our website or email. Please review this policy periodically to stay informed about how we protect your data.

Last Updated: October 4, 2024