Privacy Policy

1. Who oversees your personal data, and how can you reach out to them?

ROYAL FLOW - FZCO., with registered office UG-01, Building A1, IFZA Business Park DDP, Dubai Silicon Oasis, Dubai, United Arab Emirates, and identified by Business ID: 35886, is the entity overseeing your personal data (referred to hereafter as ”we”, ”our”, ”our Company”, or ”Controller”).

For inquiries or to assert your rights concerning the handling of your personal data, you may reach out to ROYAL FLOW - FZCO via mail at UG-01, Building A1, IFZA Business Park DDP, Dubai Silicon Oasis, Dubai, United Arab Emirates, or through help@upcomers.com.

2. What data do we gather about you, and through what means is it acquired?

This section outlines the types of personal data we collect and how they are acquired. Detailed inforfmation on the purposes of processing can be found in Section 3. All data that can directly or indirectly identify you or is related to you is considered personal data.

We primarily obtain data directly from you in connection with our services, including:

Information provided by you:

• During registration, order placements, event participation, or communication through customer support or social networks.
• Includes identification and contact details, payment information, communication records, and business-related identifiers if applicable.

Automatically collected data when using our services:

• Device data (IP address, device type, operating system, browser, connection provider).
• Website usage data (date, time, duration of visit, country of visit, browsing history).
• Service usage data (login/logout details, account settings, fictitious capital value, account currency, business strategy).

Data from third parties:

• Provided by trading platform providers chosen for our services and social network operators if you link your accounts.
• Includes information on simulated transactions (financial instrument type, opening/closing times, investment amount, profit/loss) and social network data (user name, profile picture, associated email address).

Refer to the privacy policies of trading platform providers and social network operators for details on how they process your personal data for their purposes.

3. What is the utilization of your personal data by us?

We utilize personal data for the following purposes:

Registration and User Account:

• To facilitate service usage, registration on the website and account creation are required, involving the processing of your identification and contact data, along with user account settings.
• Legal basis: Processing is necessary for contract performance, and provision of these personal data is mandatory for user account registration.

Provision of Services and Contractual Rights and Obligations:

• Processing is conducted to deliver services, provide access, tools, and support, and execute trades, requiring the processing of identification and contact data, payment data (for paid services), service usage data, and simulated trade data.
• Legal basis: Processing is necessary for contract performance or based on legitimate interest, with post-service processing for a limited period to exercise and protect our rights.

Marketing Communication:

• Marketing communications related to our services, products, or events may be sent to current or past customers. Commercial communications are sent based on legitimate interest or with consent, and each email includes an opt-out option.
• Personal data: Identification and contact data.
• Legal basis: Legitimate interest for customer communication; consent-based processing for marketing purposes.

Customer Support and Communication:

• Processing of personal data for customer support services, including identification data, contact data, and, if relevant, data from social networks.
• Legal basis: Legitimate interest in maintaining customer satisfaction and supporting service use.

Improving Services:

• Personal data is processed to develop, test, and enhance services, focusing on improving security.
• Legal basis: Legitimate interest in enhancing services.

Analytics:

• Customer behavior analysis is conducted to understand website and service usage. Personal data includes identification, contact, payment, device, website usage, service usage, and simulated trade data.
• Legal basis: Legitimate interest in understanding customer behavior and preferences.

4. How are personal data stored, and what security measures are in place?

We handle your personal data within an encrypted database across computers and other devices. To safeguard against unauthorized access, alteration, disclosure, or destruction of the collected and processed data, we implement rigorous organizational and technical security measures.

5. What is the timeframe throughout which we undertake the processing of your data?

We handle personal information as needed to achieve the mentioned goals and for the time required to meet those objectives or as directly specified by law. After that, the personal data either get removed or made anonymous. We manage personal data based on the following timeframes:

• For the purpose of fulfilling contracts and handling rights and duties related to the contract, including addressing complaints, settling damage claims, or dealing with legal matters, personal data get processed for the necessary duration but not exceeding 10 years after the last contract ends.
• If we send business messages without your clear approval, we process personal data for a maximum of 5 years after our last contract or until you object or opt out of business communications.
• To improve our services, we usually handle personal data for a maximum of 6 months.
• To meet legal obligations, like tax rules, we process personal data for the period outlined by relevant laws (for example, following tax regulations for 10 years after getting the necessary documents for your order).
• If you give consent, we process personal data for the duration specified in the consent agreement.

6. Data distribution and transfers to third countries

We may share or transfer your data to individuals who assist us in delivering our services, specifically including:

• The trading platform provider, facilitating your engagement in simulated trades.
• Various third parties supporting our website and service operations, encompassing entities within our corporate group, hosting and cloud service providers, payment system operators, financial institutions, customer support service providers, IT companies, system administrators, marketing and communication agencies, consultants, and postal service providers.

Furthermore, data transfers may occur with your consent or when legally mandated, such as by law or a binding judicial decision. Each recipient of personal data is contractually bound to uphold legal standards for safeguarding your information and process the data strictly according to our instructions.

Certain third parties act as independent controllers, collecting personal data for their own purposes. In such cases, their specific data processing rules will apply.

7. Your rights

To make use of your rights listed below, like deleting your personal info or withdrawing your agreement, drop us an email at help@upcomers.com or reach out using the details in Section 1 of this Privacy Policy. You don't need any specific wording, just give us enough info so we can help (like who you are, the right you want to use, what action you want, details of the data you want deleted, etc.).

Regarding your personal data, you have these rights:

Access to Personal Data:

• Ask us anytime if we're using your personal data. If we are, we'll give you more details. You can also get a free copy of your data, but additional copies might have a small fee.

Correction of Personal Data:

• If we have something wrong about your personal data, let us know, and we'll fix it quickly. If you're registered on the website, you can also correct your data in your user account.

Deletion of Personal Data (”Right to Be Forgotten”):(You can ask us to delete your personal data in these cases)

• They're not needed for why we collected them.
• You withdrew your agreement, and there's no other legal reason for processing (applies when we process data with your agreement).
• You object, and there's no overriding reason or if it's for marketing, and you don't want it.
• Your data is processed unlawfully.
• But, we can't delete data if we need it for freedom of expression and info rights, legal duties, public tasks, legal claims, or other reasons in the law.

Restriction of Data Processing:

• In certain situations, you can limit our processing of your data.

Data Portability and Getting Data in a Readable Format:

• If we use your data automatically with your agreement or to fulfill a contract, you can get the data in a format you can read, and we can send it to another data controller.

Objecting to Processing:

• If we process your data because it's in our interest, you can object. We won't process your data unless we have good reasons that outweigh your rights.

Withdrawing Agreement:

• If we process based on your agreement, you can withdraw it anytime. It won't affect previous lawful processing.

Not Being Subject to Automated Decisions:

• Except when needed for a contract, allowed by law, or with your clear agreement, you can avoid decisions based solely on automated processing (like profiling) that significantly affect you.

8. Final provisions

We might update this policy on our own, but only when needed, and we'll inform you of any changes. You can always check the latest version in your Client Section.

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