Privacy Policy

1. Introduction

Who we are and why this policy matters

At BROKTRADING LTD ("Company", "we", "us", "our"), a private limited liability company incorporated under the laws of the Republic of Cyprus, with registered office at Orfeos Street 18B, 1070 Nicosia, Cyprus, and registration number HE 342927, operating under the trading name THE JAZZ FINTECH, protecting your privacy is our absolute priority, and this privacy policy aims to explain clearly and transparently how we collect, use, store, and protect your personal data when you visit our website, use our products, or access our services.

This policy has been drafted in compliance with the General Data Protection Regulation (GDPR), Cyprus Law 125(I)/2018, and all other applicable data protection regulations.

The Data Controller

The data controller for your personal data is THE JAZZ FINTECH (BROKTRADING LTD). If you have any questions about privacy or wish to exercise your rights, you can contact us at compliance@thejazzfintech.com.

Who this policy applies to

This privacy policy applies to various categories of individuals we interact with: visitors to our website, those who create an account with us, our customers, users of our software, recipients of our marketing communications, and more generally, anyone whose data is processed as part of our activities.

2. The Data We Collect

Categories of personal data

In the course of our business, we collect various types of personal data:

• Identity data includes your name, the username you choose, your date of birth, and, when necessary, identity documents.
• Contact data includes your email address, postal address, and telephone number.
• Account data includes your username, password (always encrypted for your security), and your preferences.
• Technical data includes your IP address, browser and device type, and your time zone.
• Usage data helps us understand how you interact with our services.
• Profile data includes your interests, expressed preferences, and feedback you provide.
• Marketing data consists of your preferences regarding the communications you wish to receive from us.

Data we receive from the Merchant of Record

When you complete a purchase, we receive from the MoR only the information strictly necessary to fulfil your order. This includes confirmation of successful payment, order details (which products you purchased and the type of licence), basic information to deliver your licence (name and email), and transaction reference numbers.

It is important for you to know that we never receive your full payment card details, banking information, or detailed billing data: this information remains exclusively with the MoR.

How we collect your data

Your data reaches us through various channels:

• Direct interactions occur when you register, make a purchase, fill out a form, or contact us.
• Automated technologies such as cookies and tracking pixels collect certain data during your browsing.
• Merchant of Record provides us with information when they process transactions.
• Third parties such as analytics services or public sources.

Special categories of data

We do not intentionally collect sensitive personal data, such as data relating to racial or ethnic origin, religious beliefs, health status, or biometric data.

3. Legal Bases for Processing

The GDPR requires that every processing of personal data be based on a valid legal basis. Here are the bases on which we rely to process your data:

• Performance of a contract (Art. 6(1)(b) GDPR): We use it to create and manage your account, deliver products, activate licences, and provide support.
• Legitimate interests (Art. 6(1)(f)): This occurs when we improve our services, ensure security, prevent fraud, analyse usage of our products, or send marketing communications to existing customers.
• Consent (Art. 6(1)(a)): For sending marketing communications to those who are not yet our customers or for the use of certain cookies.
• Legal obligations (Art. 6(1)(c)): Such as tax and accounting requirements, regulatory compliance, or responses to requests from authorities.

4. How We Use Your Data

To provide our services

We use your data to create and manage your account, to deliver licences and access keys for our products, to provide support when you need it, to communicate important information about your account, and to manage our relationship with you effectively.

To improve our products

The data we collect also helps us analyse how our services are used, improve existing products, develop new features, conduct research, and personalise your experience to better suit your needs.

For marketing activities

When we have your consent or when we can rely on our legitimate interest, we may send you newsletters, inform you about new products and features, offer you targeted advertising, or ask you to participate in surveys. Remember that you can always choose to stop receiving these communications: you will find an unsubscribe link at the bottom of every email we send.

To ensure security

Your data also helps us protect our services, detect and prevent fraudulent activity, verify user identity when necessary, and investigate any suspicious activity.

5. Who We Share Your Data With

Recipients of your data

In certain cases, we may share your data with third parties:

• Service providers (such as those providing hosting, email services, or data analytics) receive the data necessary to perform their functions.
• Merchant of Record to process orders and deliver licences.
• Business partners such as affiliates or resellers.
• Professional advisors (lawyers, accountants).
• Competent authorities when required by law.

International transfers

Your data may be transferred outside the European Economic Area (EEA). In these cases, we always implement appropriate safeguards to protect your data, such as European Commission adequacy decisions, Standard Contractual Clauses, or, in some cases, your explicit consent.

6. How Long We Keep Your Data

We retain your data only for as long as necessary for the purposes for which we collected it:

• Account data: Duration of your account + 7 years following closure
• Transaction records: 7 years (tax and legal requirements)
• Marketing data: Until you withdraw consent
• Technical and usage data: 2 years
• Support communications: 5 years

After these periods, your data is deleted or anonymised.

7. Your Rights Under the GDPR

The GDPR grants you a number of important rights over your personal data:

• Right of access (Art. 15): Obtain confirmation of the processing of your data and receive a copy.
• Right to rectification (Art. 16): Request the correction of inaccurate data.
• Right to erasure (Art. 17): Request the deletion of your data in certain circumstances.
• Right to restriction (Art. 18): Request that the processing of your data be limited.
• Right to data portability (Art. 20): Receive your data in a structured, commonly used format.
• Right to object (Art. 21): Object to processing based on legitimate interest.

How to exercise your rights

To exercise any of these rights, contact us at compliance@thejazzfintech.com. We will respond within one month. For any queries relating to data processed by our MoR (Creem) on our behalf, please contact us and we will coordinate with the MoR accordingly.

8. How We Protect Your Data

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption: Data is encrypted both in transit (using TLS/SSL) and at rest where appropriate.
• Security testing: We conduct regular security assessments and vulnerability testing of our systems.
• PCI-DSS compliance: Our Merchant of Record (Creem) maintains PCI-DSS compliance for handling payment card data, ensuring that your financial information is processed to the highest security standards.
• Breach notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where required, inform you directly.

9. Cookies

Our websites use cookies and similar technologies to enhance your browsing experience, analyse site traffic, and personalise content. For detailed information about the cookies we use, their purposes, and how you can manage your cookie preferences, please refer to our Cookie Policy.

10. Children

Our services are not intended for children under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child under 16, we will take steps to delete that information as soon as possible. If you believe that a child has provided us with personal data, please contact us at compliance@thejazzfintech.com.

11. Links to Third-Party Websites

Our websites may contain links to third-party websites, plugins, or services that are not operated by us. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. We encourage you to review the privacy policy of every site you visit.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated policy on our website and updating the "Last Updated" date at the top of this document. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your data.

13. How to Contact Us

If you have any questions about this Privacy Policy, you can contact us at:

THE JAZZ FINTECH (BROKTRADING LTD)
Address: Orfeos Street 18B, 1070 Nicosia, Cyprus
Email: compliance@thejazzfintech.com
Websites: www.thejazzfintech.com | www.pfarmour.com
Registration Number: HE 342927

Merchant of Record:
Creem (Armitage Labs OÜ)
Website: https://www.creem.io
Support: support@creem.io