• Գլխավոր

Լուծումներ

 

  • Մեր Մասին
  • Այլ
  • Analytics
hy
  • en
  • ru
r98-frame-1233-16981784148461.png

Privacy Policy

“INCORE Invest” Mobile Trading Application Privacy Policy

 

This Privacy policy describes how this trade application collects, uses, processes, and discloses your information, including personal information, relating to your access to and use of INCORE Invest. If you do not agree with this Privacy policy, you should immediately refrain from using our website and/or services.

We may collect and process your individually identifiable information, namely information that identifies a person or can, with reasonable efforts, identify a person (hereinafter “Personal data”) in order to provide proper services for you.

  1. Changes

We reserve the right to update, change or replace any part of this Privacy policy by posting updates and/or amendments. The changes will become effective when posted on this application. Your use of the application following these changes means you accept the revised Policy. In the event you disagree with any amendment and/or alteration and/or update you shall immediately terminate the use of our website and/or services.

 

  1. Contact details for communication on personal data protection issues

If you have any questions relating to this Privacy policy or processing of your Personal data, you may contact us by using the communication channels:

Address: 0002, Republic of Armenia, Yerevan, Buzand Str. 91, territory 72

Email: info@incore.am

Phone: +374 12 900 200

 

  1. The purposes and legal justification of personal data processing

We collect and process your Personal data only for legitimate purposes in accordance with the rules of data protection and processing according to RA legislation, international rules and obligations undertaken by RA.

We shall also comply with local and international anti-money laundering (hereinafter "AML”) and counter-terrorist financing (CTF) obligations, as well as to implement know your customer (hereinafter "KYC”) requirements. We will only process your Personal data for lawful purposes defined in this Privacy Policy

While processing your Personal data we will comply with Personal data protection applicable laws and regulatory enactments, as well as with data processing principles, which means that your Personal data will be:

  • Used lawfully, fairly and in a transparent way
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  • Relevant to the purposes we have informed you about and limited only to those purposes
  • Accurate and kept up to date
  • Maintained only for as long as necessary for the purposes we have informed you about
  • Kept securely and protected against unauthorized or unlawful processing and against loss or destruction using appropriate technical and organizational measures.

 

3.1 The commencement and provision of services for the fulfillment of obligations under the services agreement:

Below you can find the details and additional information why, for what sub-purposes and/or what data for certain sub-purpose (where explained) we will process.

We will process your Personal data to:

  • identify you as a prospective client and/or client’s – legal entity’s director/legal representative/
  • management board/supervisory board member/ authorized person or employee, and implement relevant “Know your customer” procedures
  • to understand your financial circumstances
  • identify ultimate beneficial owner or controlling person of the account
  • collect information regarding client’s main business partner
  • verify your mobile number and e-mail address
  • conclude an agreement (General Terms and Conditions for the Provision of services) for services with you/your represented legal entity․

Within the client onboarding process, in addition to Personal data processing for the purposes of client identification and contact details verification, in compliance with the requirements of AML and KYC, we will use document authenticity verification services provided by external vendor, including validation of KYC documentation, business documentation required for legal entity onboarding, verification of beneficial ownership and information checking in national registers of Member States as required by the Applicable legislation. We will use vendor’s overnight screening services for potential sanctions and politically exposed person (PEP) matches, negative information in adverse media.

If you are indicated as the beneficial owner or a controlling person of a legal client, we shall process the following your Personal data: name, surname, date of birth, residency/nationality, identification documents/residence permits data, nature and description of the beneficial ownership, source of funds and wealth (where required) and other data required by the Applicable legislation․

As part of transaction processing, we will process your identification data and your payment account data, payment transaction data, payment recipient’s Personal data (name, surname, account number and the recipient bank detail), IP-address, other data required by the Applicable legislation:

  • handle necessary procedures according to anti-money laundering and terrorist financing regulations
  • make relevant risk assessments
  • monitor transactions
  • ensure proper risk and organizational management
  • keep contact and necessary communication with you
  • process client’s requests and complaints, where relevant.

 

3.2 AML/CTF and transaction monitoring

As part of this, we would need to comply with AML/CTF legal framework, establish your/your represented legal entities client risk classification, monitor transactions, carry out risk score and AML/CTF risk exposure assessment.

For the implementation of our legitimate interest within the AML/CTF framework we may verify information relating to you against credible publicly available information sources; ensure monitoring of your transaction and provide information to the supervisory authorities and investigative authorities in the cases provided by legal enactments, ensure the maintenance of relevant registers, e.g., risk register, beneficial owners register.

 

3.3 The sources of obtaining your personal data

We can get your personal data in one of the following ways:

 

  • from you, visiting our website, applications and/or subscribing to our services
  • from you, providing your Personal data for identification and KYC purposes via our website
  • and/or applications
  • from you, in the process of entering into a mutual agreement with us
  • from you, if you submit any requests, complaints, e-mails, or call us
  • from you, when you are using our products/services
  • from third-party registers as required by Applicable legislation or according to our legitimate interests
  • from State institutions and registers, e.g., the Bank of England, the HM Treasury, The HM Revenue & Customs, the Companies House, law enforcement institutions, other registers and public authorities
  • from bailiffs in accordance with the requirements of debt property information and suspension of assets if relevant court decision was made
  • where applicable, from video surveillance records.

 

3.4 Why do you have to give us your personal data?

Above all, we are collecting your information to fulfill the commitments under the General Terms and Conditions for the Provision of services entered with you, to fulfill the legal obligations that are binding on us, and to pursue our legitimate interests. In these cases, it is necessary for us to obtain certain information for the purposes involved, so that failure to provide such information may endanger the commencement of or provision of services to you. If the data are not required, but their submission could help to improve our services provided to you, we will indicate that the provision of data is voluntary.

 

3.5 The Receipients/Possible Receipients of your personal data

Your Personal data could be accessed as needed by and shared with:

  • our employees or directly authorized persons who are required to process this Personal data to perform their duties
  • Personal data processors
  • Third parties, carefully assessing whether such Persona data transfer has an appropriate legal basis

Personal data processors:

Your Personal data will be transmitted to third parties that we use to provide our services; these parties have been rigorously assessed and offer a guarantee of compliance with the legislation on the processing of Personal data. These parties have been designated as data processors and carry out their activities according to the written agreement, the instructions given by us and under our control.

We may work with the following categories of Personal data processors:

Personal data processors may change from time to time, so we may also make relevant changes to this Privacy policy.

Third parties:

We may also be required to share your Personal data with various financial institutions, payment services providers and/or law enforcement bodies and officials, supervisory authorities/ regulatory bodies and financial crime investigation service to comply with Applicable legislation, prevent fraud or enforce an agreement we have with you;

We may also share your personal data to comply with applicable laws and regulations, to respond to a legal requests of law enforcement bodies and officials, supervisory authorities/ regulatory bodies, or to other third parties if it is provided by applicable law, and/or if it is relevant for the protection of our and our employees legitimate interests, property or safety, or legitimate interests of third parties or data subject.

 

3.6 Terms of Personal Data Retention/Storage

Your Personal data is stored for as long as their storage is required for appropriate purposes for the processing of Personal data, as well as in accordance with the Applicable legislation.

Data may be stored in an electronic form and/or in paper format, provided always that your Personal data will be stored securely and protected against unauthorized or unlawful processing and against loss or destruction, using appropriate technical and organizational measures.

When assessing the length of the storage of Personal data, we take into account existing regulatory requirements, aspects of contractual performance, your instructions (e.g., in the case of consent), and our legitimate interests. If your Personal data is no longer needed for the purposes specified, we will delete them or destroy them.

 

Use of Cookies, Log Files, and Tracking

We may use cookies, log files, and other tracking technologies to collect information about your interactions with our website and services. These technologies help us analyze trends, administer the site, track users' movements, and gather demographic information.

Cookies can be disabled or cleared through your browser settings. However, disabling cookies may affect the functionality of certain parts of our website.

 

Opt-Out of Data Collection/Usage

You can opt-out of certain data collection and usage by:

  • Adjusting your browser settings to disable cookies.
  • Contacting us directly to inquire about and manage your data preferences.

Please note that some essential functions may be affected by opting out of certain data collection.

If you have any questions or concerns about opting out of data collection and usage, please contact us at: Support@incore.am

 

Withdrawal of consent

If the processing of your Personal data is based on your consent, you have the right to withdraw it at any time and we will no longer process your Personal data on the basis of your consent. However, please be informed that the withdrawal of consent cannot affect the processing of Personal data which is necessary for the fulfillment of the requirements of regulatory enactments, or which is based on a contract, our legitimate interests, or other legal bases for the lawful processing of Personal data provided for in regulatory enactments.

 

COMPLAINTS REGARDING YOUR PERSONAL DATA PROCESSING

If you have any questions or concerns regarding our processing of your Personal data, we encourage you to contact us first.