Network Investments Limited respects each individual's right to privacy. We value our relationship with you, and we take pride in maintaining loyalty and respect with each individual client by providing you with security. The provisions of this notice apply to former clients as well as our current clients. We kindly ask that you read the following information.
1. GENERAL PROVISIONS
1.1 The present Privacy Policy is an integral part of the public documents package, pursuant to which the Network Investments Limited officially represented by its Affiliated Partners (hereinafter referred to as the Company), provides various services (including services of financial and informational nature, etc.) to its Clients.
1.2. By choosing the Company's services, the Client fully agrees to all the terms and conditions of the public documents. The same applies to the interactions between the Client and the Company, during which trading and investment operations are performed, various informational materials are used, payments and transfers are arranged, etc. Should the Client disagree with any condition of the public documents package, she/he should cease all interaction with the Company. In case the Client deems the conditions of the present Privacy Policy unacceptable for any reason whatsoever, she/he shall cease all interaction with the Company, including terminating all financial operations carried out with Company mediation.
1.3. The present Privacy Policy declares one of the most important principles that the Company follows when providing the services to its Clients. The Company respects the right of every individual and legal unit for privacy irrespective of their being or not being the Clients of the Company, as well as those who only intend to interact with the Company. The conditions of the present Privacy Policy apply equally to former, present and future Clients of the Company. One of the most important priorities of the Company is the relationship between the Company and its Clients. The Company maintains loyalty and respect for every Client individually, and grants every Client perfect security and confidentiality.
1.4. In the present Privacy Policy the following basic terms and definitions are used:
1.4.1 Privacy (confidential information) is a legal right of an individual or a legal unit for non-disclosure of private or personal information (data) or of information which is commercially classified. In the relation between the Company and the Client, privacy means the commitment of the Company to safeguard and ensure non-disclosure of Client information gained by the Company, while rendering services to the Client.
1.4.2 Personal (private) information of the Client - information which characterizes, identifies or verifies the Client or discloses certain details of his/her personality, financial conditions, and preferences. A more detailed definition of this term can be found in the text of the present Privacy Policy. Privacy Policyis a complex measures, procedures and actions that ensures collection of full, accurate and authentic information concerning the Client, and the safeguarding of this information, as well as the exchange of this information with governmental (regulatory) bodies in accordance with the existing legislation, and the conditions of the present Privacy Policy.
2. PERSONAL INFORMATION
2.1. When the Client applies for or maintains a live or demo account with the Company, the Company collects personal information about the Client for business purposes, such as evaluating the Client's financial needs, processing the Client's requests and deals, informing the Client about products and services that may be of interest to him/her, and providing effective and quality service to the Client. Such information can be of the following types:
2.1.1. Registration information - information provided by the Client on application forms and other documents (including electronic documents). This includes: first name, last name, patronymic name, contact information (postal address, telephone number, e-mail, etc.), date of birth, occupation, assets and incomes.
2.1.2. Transaction Information - information about deals between the Client and the Company, or between the Client and the Affiliated Partners of the Company, as well as information about communications (unilateral or bilateral) between the Client and the Company. Examples include Client account balances, trading (investing) activity, Client inquiries and the Company responses, including texts of the mails or log-files in used messaging systems. In the present Privacy Policy, the term "Affiliated Partners of the Company" refers to the organizations owned or run by the Company, as well as organizations that own part of Company property.
2.1.3. Verification Information - information necessary to verify Client identity such as a passport or driver's license (or articles of association in case the Client is a legal unit). Examples also include information received by the Company from public records, such as loan offices, information agencies and address bureaus or from other entities not affiliated with the Company. The Anti-Money Laundering Policy requires the Company to collect information and take the necessary action to prevent transformation and legalization (laundering) of money gained from illegal activity. In certain cases the Company has the right to require a document disclosing the sources of money.
2.1.4. Information about subscriptions - information such as signals, alerts, news category and price subscriptions.
2.2. The Company does not collect nor store credit /debit card details of any customer in its database.
2.3. The above is not inclusive. The Company reserves the right to require other information from the Client in the case that it is necessary for complying to the regulations of existing legislation.
3. ABOUT "COOKIES"
3.1. Cookies are small files containing information that a Web server (site) uses to track its visitors. The Company may set and access cookies on Client computers, to assess which advertisements and promotions draw users to the Company Web site. The Company (or any of its divisions) may use cookies to evaluate Client interest in Company products and services, and to track Client activities on its Web server (site). The information collected by the Company and shared with its Affiliated Partners is anonymous and not personally identifiable.
4. SECURITY TECHNOLOGIES
4.1. The Company uses Secure Socket Layer (SSL) encryption technology in order to protect certain information submitted by its Clients. This technology protects the Client from having his/her information intercepted by anyone other than the Company while it is being transmitted. The Company works hard to ensure that its Web servers (sites) are secure and that they meet industry standards. The Company also uses other safeguards such as firewalls, authentication systems (e.g., passwords and personal identification numbers) and access control mechanisms to control unauthorized access to systems and data.
4.2. The Company reserves the right to choose technologies and methods of data protection at its own discretion, and to cooperate in this field with contractors which appear to be reliable to the Company.
4.3. In accordance with the recommendations of Payment Card Industry Security Standards Council, customer card details are protected using Transport Layer encryption — TLS 1.2 and application layer with algorithm AES and key length 256 bit.
5. SHARING INFORMATION WITH THE COMPANY'S AFFILIATED PARTNERS
5.1. The Company may share Client personal information described above with its affiliates for business purposes, such as servicing the Client's accounts and informing him/her about new products and services, as permitted by applicable law.
5.2. The affiliate partners can access Client private information upon to the Company request and mandatory approval by the individual Client. Every access to personal information of Clients by the affiliate partner is recorded in a log, which is available for viewing by the Client. This log contain: time, the name of a partner and the type of information sought.
6. SHARING INFORMATION WITH THIRD PARTIES
6.1. The Company does not disclose the Client's personal information to third parties, except as described in this Privacy Policy. Third-party disclosures may include sharing such information with Non-Affiliated Partners of the Company that perform technical support services for Client accounts or facilitate Client deals with the Company, including those that provide professional, legal, or accounting advice to the Company. Non-affiliated Partners that assist the Company in providing services to the Clients are required to maintain the confidentiality of such information to the extent that they receive it, and to use this personal information only in the course of providing such services, and only for the purposes that the Company dictates.
6.2. The Company may also disclose the Client's personal information to third parties to fulfill Client instructions or pursuant to the Client's express consent. Company also informs its Clients that it shall never sell, place at interim disposal on a remuneration basis, distribute or disseminate the Client's Personal information under any circumstances.
7. REGULATORY DISCLOSURE
7.1. Under limited circumstances, the Company may disclose the Client's personal information to third parties as permitted by, or to comply with, applicable laws and regulations. The Company may disclose personal information to cooperate with regulatory authorities and law enforcement agencies in complying with subpoenas or other official requests, and as necessary to protect Company rights or property.
7.2. Except as described in the present Privacy Policy, the Company will not use the Client's personal information for any other purpose unless the Company describes how such information will be used at the time the Client discloses it, or if the Company obtains the Client's express permission.
The Company has the right to use the Client's Personal information in cases other than described in the present Privacy Policy if clearly stated at the time the information is disclosed by the Client or when the Company receives the Client's express permission.
8. OPT OUT
8.1. The Client may refuse to supply any of the Personal information that the Company may request. However, failure to do so may result in the Company being unable to open or maintain an account or to provide other services to the Client.
While the Company makes every effort to ensure that services, provided to its Clients are based on accurate, complete and up-to-date information about them, the Client can help considerably in this respect by promptly notifying the Company when there are changes to his/her personal information.
8.2. If the Client does not wish to have his/her Personal information disclosed to third parties as described in the present Privacy Policy, s/he should contact the Company via specific contact form.
9. AMENDMENTS
9.1. The Company reserves the right to make amendments to the present Privacy Policy. In particular, this may take place in cases that are not described directly or indirectly in the current edition of the Privacy Policy, or if a rule or law passes that requires such an amendment or addition.
9.2. Amendatory procedure:
9.2.1 Should amendments and/or additions be made, the Company shall inform the Clients of this fact by posting relevant notice on the Company's official Web site and sending a relevant message via the internal mail system.
9.2.2 Posting the relevant notice on the Company Website and sending messages via internal mail are considered to be adequate Client Privacy Policy of the amendments, whether the Client reads and understands a corresponding text or ignores it.
9.2.3 The amended document becomes effective after 5 (five) full astronomical days (120 hours) following publication of the notice on the Company Web site, before this time the notice has only an informative nature.
9.2.4 The amended document immediately applies to any accounts registered after its publication (irrespective of other accounts registered earlier, which its holder may possess). The amended document applies to trading accounts that were registered previous to the date the document in question went into effect.
9.2.5 In the case that a rule of law is introduced, which requires a corresponding amendment and/or addition to the present Privacy Policy, then the rule of law shall be applied immediately after the effective date of the relevant statutory act, whether the required amendment is made or not. Regulations of the present Privacy Policy that contradict the newly introduced rule or law become void once the corresponding amendments to the aforementioned document go into effect.
10. ACCEPTANCE OF NOTICE CONDITIONS BY THE CLIENT
10.1. Being the Client of the Company, and actively using its services (including brokerage services and information services), software and/or hardware allowing to carry out professional activities in the financial markets, I accept the Privacy Policy described in this Notice.
10.2. I agree with all the provisions (clauses, sections) of all documents publicly declared by the Company during the period of use of any services of the Company, and in case of disagreement, I will immediately cease to use the Company's services.
Anti-Money Laundering Policy
Money laundering is the act of converting money or other monetary instruments gained from illegal activity into money or investments that appear to be legitimate, so that its illegal source cannot be traced. Domestic and international laws that apply to companies, whose customers can deposit and withdraw funds from their accounts.
ZAR strictly follows the provisions of the anti money laundering and counter terrorism financing policy and demands that its employees fully observe these standards. The Company therefore takes all necessary measures to detect and counter money laundering and terrorism financing. The internal rules are observed in accordance with the relevant international requirements.
ZAR anti-money laundering procedures
Implemented Procedures
The objective of Anti-Money laundering procedures that ZAR implements is to ensure that customers engaging in certain activities are identified to a reasonable standard, while minimizing the compliance burden and impact on legitimate customers. ZAR is committed to assisting governments combat the threat of money laundering and financing terrorist activities around the world. For that purpose ZAR has set up a highly sophisticated electronic system. This system documents and verifies client identification records, and tracks and maintains detailed records of all transactions.
ZAR carefully tracks suspicious and significant transaction activities, and reports such activities "providing timely and comprehensive information" to law enforcement bodies. To uphold the integrity of reporting systems and to safeguard businesses, the legislative framework provides legal protection to providers of such information.
In order to minimize the risk of money laundering and financing terrorist activities, ZAR neither accepts cash deposits nor disburses cash under any circumstances. ZAR reserves the right to refuse to process a transfer at any stage, where it believes the transfer to be connected in any way to money laundering or criminal activity. It is forbidden for ZAR to inform customers that they have been reported for suspicious activity.
Clients' identification and verification
For the purpose of complying with Anti-Money laundering laws, ZAR requires two different documents to verify the identity of the customer. The first document we require is a legal government-issued, identifying document with the picture of the customer on it. It may be a government-issued passport, driver's license (for countries where the driver's license is a primary identification document) or local ID card (no company access cards). The second document we require is a bill with the customer's own name and actual address on it issued 3 months ago at the earliest. It may be a utility bill, a bank statement, an affidavit, or any other document with the customer’s name and address from an internationally recognized organization.
To change the phone number related to the Client Profile, Clients are required to provide a document confirming ownership of a new phone number (agreement with a mobile phone service provider) and a photo of the ID held beside the Client’s face. The Client’s personal data shall be the same in both documents.
Clients are required to submit uptodate identification and contact information in a timely manner, as soon as changes occur.
Documents in non-western letters must be translated into English by an official translator; the translation must be stamped and signed by the translator and sent together with the original document with a clear picture of the customer on it.
Payment Policy: Deposits and Withdrawals
Please be aware that chargebacks to Skrill payment system and bank cards are prohibited. To make a withdrawal from a trading account to one of these systems, a correspondent demand must be sent via Client’s Cabinet. Money will be loaded into the wallet within 3 business days. If money has been lost when trading, it cannot be reimbursed by means of a chargeback.
ZAR Investments Limited requires all deposits, where the name of the originating customer is present, to come from the name matching the name of the customer in our records. Third party payments are not accepted.
As for withdrawals, money may be withdrawn from the same account and by the same way it was received. For withdrawals where the name of the recipient is present, the name must exactly match the name of the customer in our records. If the deposit was made by wire transfer, funds may be withdrawn only by wire transfer to the same bank and to the same account from which it originated. If the deposit was made by means of electronic currency transfer, funds may be withdrawn only by the means of electronic currency transfer through the same system and to the same account from which it originated.
The Company accepts deposits in the following currencies: USD, EUR, CHF, AED, RUB, IIR, ZAR. To comply with the AML procedures, funds withdrawals have to be made solely in the same currency that was used to make a deposit.