Privacy Policy

1. General

SR Global is committed to compliance with applicable data protection laws, including the UAE Federal Decree Law No. 45 of 2021 Concerning the Protection of Personal Data, its associated Executive Regulations, and international data protection guidelines (the "Law"). This policy, together with our terms of use and any other referenced documents, outlines how we handle your personal data. By accessing www.srglobalfx.com, you consent to the practices described in this policy.

We prioritize the confidentiality of your information, and our employees are trained to handle personal data with care. Any breaches of this policy will result in disciplinary actions, including dismissal if necessary. A data protection officer is designated to ensure our ongoing compliance with this policy and applicable laws.

2. Information We Collect

We collect the following types of personal data:

Information You Provide to Us:

You may provide personal information through forms on our website, by phone, email, or other communication methods. This includes:

• Name, address, date of birth, email, phone number, and financial information (tax, payment details, etc.).
• Documents such as photographic ID for regulatory purposes (e.g., AML/KYC compliance).
• Additional information may be collected voluntarily, such as through surveys or promotional offers, to improve services.

Information We Automatically Collect:

When you visit our website, we may automatically collect:

• Technical information (IP address, browser type, time zone, operating system).
• Data about your interactions with our website (URL clickstream, page interaction data, response times, etc.).
• Telephone communications with our staff, including the date, time, and key account information.

Information from Third Parties:

• We may receive additional information from third-party providers, such as business partners, advertising networks, analytics providers, and credit reference agencies, primarily for AML/KYC compliance and risk management.

3. Cookies

We use cookies to improve your experience and our services. Please refer to our Cookie Policy for detailed information on how cookies work and how we use them.

4. How We Use Your Information

We use your information in the following ways:

Information You Provide:

• To fulfill contractual obligations and provide the services you request.
• To communicate information about similar services and products.
• To provide targeted advertising and measure its effectiveness.

Information We Automatically Collect:

• For internal operations, including troubleshooting, data analysis, testing, and research.
• To enhance our website’s performance and security.
• To ensure our website content is displayed in an optimized format.

Information from Third Parties:

• For compliance with regulatory requirements, such as AML/KYC.
• To assess credit risk and ensure our contractual agreements are fulfilled.

5. Disclosure of Your Information

We may share your personal information with:

• Other companies within the SR Global group.
• Service providers who assist us with administrative, financial, insurance, or marketing services.
• Introducing brokers, credit reference agencies, and regulators, where necessary for compliance and fraud protection.
• Authorized third parties, as instructed by you or required by law. In the event of a merger, acquisition, or asset sale, your data may be shared with prospective buyers or sellers.

6. Data Security

We employ robust security measures, including encryption and multi-layered firewalls, to protect your personal information. While we strive to protect your data, no online transmission is completely secure. By using our site, you accept the inherent risks associated with transmitting personal data online.

All stored data is encrypted and protected on secure servers. We advise you to safeguard your password and avoid sharing it with others.

7. International Data Transfers

Your data may be transferred to, and stored in, locations outside of your country of residence. By submitting your personal data, you agree to this transfer, which will always be carried out in compliance with applicable data protection laws.

8. Your Rights

You have the right to:

• Access the personal data we hold about you.
• Request corrections to any inaccurate information.
• Opt out of receiving marketing communications.
• Withdraw consent where it has been previously given.

To exercise these rights, please contact us at support@srglobalfx.com.

9. Retention of Data

We retain personal data only as long as necessary for the purposes outlined in this policy or to comply with legal obligations. Afterward, your personal data will be securely deleted or anonymized.

10. Changes to This Policy

We reserve the right to amend this privacy policy at any time. Any changes will be posted on this page, and significant changes may also be notified to you via email.

11. Complaints

If you have any concerns about our use of your data, you can contact our Compliance Department at support@srglobalfx.com. We are committed to addressing your concerns promptly and thoroughly.

12. Data Minimization and Purpose Limitation

We only collect the personal data that is necessary for the purposes outlined in this policy. We ensure that the personal data we process is relevant and limited to what is required for the provision of services, compliance with legal obligations, or legitimate business interests.

13. Lawful Basis for Processing

We process your personal data under various lawful bases, including:

• Consent: Where you have provided consent for specific processing activities.
• Contractual necessity: Where processing is required to fulfill a contract we have with you.
• Legal obligation: Where processing is necessary for compliance with a legal obligation.
• Legitimate interests: Where processing is in our legitimate business interests, and these are not overridden by your rights.

14. Data Subject Rights

In addition to the rights outlined previously, under applicable data protection laws, you have the following rights:

• Right to Data Portability: You may request to receive your personal data in a structured, commonly used, and machine-readable format, or request us to transfer it to another data controller.
• Right to Restrict Processing: You can request that we restrict the processing of your personal data under certain conditions (e.g., if you contest the accuracy of your data).
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or based on our legitimate interests.
• Right to Erasure ("Right to be Forgotten"): You can request the deletion of your personal data under certain circumstances (e.g., if the data is no longer necessary for the purposes for which it was collected).

15. Automated Decision-Making and Profiling

We do not make decisions based solely on automated processing, including profiling, which could have legal or similarly significant effects on you. If in the future we engage in such activities, we will inform you and provide you with rights concerning these activities.

16. Cross-Border Data Transfers

When transferring personal data outside of the UAE, or any other jurisdiction, we ensure that appropriate safeguards are in place, such as the use of standard contractual clauses or reliance on adequacy decisions from relevant authorities. You will be informed if your data is transferred internationally and how it is protected.

17. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant data protection authorities and affected individuals without undue delay. We have implemented procedures for identifying, assessing, and reporting data breaches.

18. Third-Party Data Processors

We only engage third-party service providers who agree to protect your personal data in compliance with applicable legal standards. These third parties are prohibited from using your personal information for purposes other than those specified in our agreement with them.

19. Children’s Privacy

Our services are not directed to individuals under the age of 18, and we do not knowingly collect personal data from minors. If we learn that we have inadvertently collected data from a child under 18, we will take steps to delete such information promptly.

20. Data Retention Periods

We retain personal data for as long as necessary for the purposes stated in this policy, including fulfilling contractual obligations, complying with legal requirements, and pursuing legitimate business interests. Retention periods vary depending on the type of data and the applicable legal or regulatory requirements.

21. Legal Compliance

We comply with all applicable laws and regulations governing privacy and data protection, including financial regulations that mandate the retention of certain types of data for specific periods (e.g., AML and KYC compliance). We also cooperate with government authorities and regulators when required by law, including responding to legal requests for information.

22. Dispute Resolution and Governing Law

Any disputes arising from this privacy policy will be resolved through negotiation, and if unresolved, will be subject to the exclusive jurisdiction of the courts in [your jurisdiction]. This policy is governed by the laws of [your jurisdiction].