PRIVACY POLICY
1. POLICY STATEMENT
International Capital Markets Brokers Limited (hereinafter the "Company", "we", "our", "us") intends to
fully comply with all requirements on the protection of natural persons with regards to the processing of
personal data and on the free movement of such data, in so far as they affect its activities.
2. INTRODUCTION
International Capital Markets Brokers Limited needs to collect and use the personal data about its
employees, visitors, potential active and terminated clients and other individuals who are accessing or
using the Company’s website(s) and mobile applications and come into contact with the Company.
In collecting and using personal data, the Company is committed to protecting an individual’s right to
privacy with regard to the processing of personal data, therefore this Privacy Policy Notice (hereinafter the
“Privacy Notice”) is hereby adopted in compliance with the Regulation and with the Law to support this
commitment.
The Privacy Notice ensures that International Capital Markets Brokers Limited:
• Complies with internal and external Laws and Regulations
• Protects the rights of individuals related to the Company;
• Is transparent about how the Company collects, use, storage, access, discloses, transfers and
destructs individual’s data;
• Protects the Company from the risks of a data breach.
The Company respects and values your data privacy rights and makes sure that all personal data collected
from you are processed in adherence to the general principles of data protection as set out in the Marshall Islands
Laws and Regulations.
In accordance these principles, the personal data shall be:
• processed lawfully, fairly and in a transparent manner;
• collected for specified, explicit and legitimate purposes and not further processed in a manner that is
incompatible with those purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are
processed;
• accurate and, where necessary, kept up to date;
• kept in a form which permits identification of data subjects for no longer than is necessary for the
purposes for which the personal data are processed;
• processed in a manner that ensures appropriate security of the personal data, including protection
against unauthorised or unlawful processing and against accidental loss, destruction or damage.
The Policy applies to all personal data that the Company holds relating to identifiable individuals.
International Capital Markets Brokers Limited
Trust Company Complex
Ajeltake Road, Ajeltake Island
Majuro MH96960, Marshall Islands
info@icmbrokers.com | www.icmbrokers.com
3. PROCESSING OF PERSONAL DATA
3.1 Collection
The lawfulness of collection and processing of personal data by the Company is based on:
• the data subject has given consent to the processing of his or her personal data for one or more
specific purposes;
• the necessity to comply with its legal obligations;
• for the performance of a contract to which is a party or in order to take steps at the request of a
prospect client prior to entering into a contract;
• for the Company's legitimate interests.
3.1.1 COLLECTION OF PERSONAL DATA OF CLIENTS AND OTHER INDIVIDUALS
In order to receive more information, register for a demo account, open a trading account with the
Company or for any other business relationship, you are requested to complete the Application Form. By
completing the Application Form and providing your personal information, you enable the Company to
evaluate the application and comply with the relevant laws and regulations governing the provision of
financial services. The same information will be used by the Company to contact you regarding the offered
services.
The Company collects sufficient evidences and information of potential clients and other individuals for
their identity verification process, subject to its legal obligations.
These evidences and information include:
• Personal information you provide to the Company on applications and other forms, such as your name,
surname, address, telephone number, email address and fax number if exist,
• Date of Birth,
• Gender,
• Certified and translated copy of passport or ID,
• Original or certified and translated copy of bank statement or Utility Bill,
• Tax information,
• CV,
• Bank Reference,
• Information on profession or occupation,
• Name of employer, if exist,
• Information about his/her economic profile (size of wealth, source of wealth, income source),
• IP address;
• Details about Bank account, e-wallets and credit card;
International Capital Markets Brokers Limited
Trust Company Complex
Ajeltake Road, Ajeltake Island
Majuro MH96960, Marshall Islands
info@icmbrokers.com | www.icmbrokers.com
• Tax information
Any other information that the Company might request from time to time in order to comply fully with its
regulatory obligations.
The Company may collect additional personal data for its clients under its legal obligation, update the
personal data that processes and collect other additional personal data under any new legal requirement
the Company is subject, as well as, personal data information not obtained from the data subject.
In case a potential client has not become a client of the Company, the Company shall destroy his/her
Personal data the soonest.
3.2 USE
The Company applies security measures for the protection of the personal data in use. The Security
measures include technical and organisational procedures.
The Company restrict access to personal information to employees who need to know the specific
information in order to operate, develop or improve our services. These individuals are bound by
confidentiality and will be subject to penalties if they fail to meet these obligations.
The personal data that the client provides are highly protected and can be accessed by the client using
his/her selected password. This personal data is safely stored in the Company’s servers that only
authorized personnel have access to it through access rights.
The Company encrypts all personal data to prevent unauthorized parties from viewing or access such
information.
3.2.1 USE OF PERSONAL DATA OF CLIENTS AND OTHER INDIVIDUALS
Personal data collected shall be used by the Company for the client’s identity verification process subject to
its legal obligations and to decide for the establishment or not and the continuation of a business
relationship with the client.
The personal data collected by other individuals is in use by the Company for a specific purpose, such for
example the use of personal data for providing more information following a request for a business
relationship.
The Company may use your personal information for one or more of the following purposes:
• to confirm/verify your identity;
• to assess your appropriateness/suitability to the products and services we provide;
• to process your transactions;
• to manage the account the client holds with the Company;
• to provide you with transaction and post transaction related services;
• to inform you of products and/or services that may be of interest to you;
• to keep you updated on the issues that are relevant to your business relationship with us;
• to analyse statistical data to enable us to provide you with better products and/or services;
• to enhance the security controls of the Company’s networks and systems;