Last Modified: 20th May 2018
This Privacy Policy is effective from 20th May 2018.
Fibonacci Marketing is concerned with protecting the privacy of any personal information that you may choose to provide to us (“Personal Information”). Fibonacci Marketing will attempt to ensure that its use of your Personal Information is compliant with the General Data Protection Regulation, (“GDPR”), (Regulation (EU) 2016/679). Accordingly, Fibonacci Marketing issues this policy to inform you of our use of your Personal Information.
1. Introduction
1.1 This Privacy Policy sets out the way in which Fibonacci Marketing (“we” or “us”), a company, registered with the registrar of companies in Malta (with registered office at: SB Business Centre, Triq Dun Karm, Birkirkara, Malta, is Operating www.fibonacci-marketing.com collects and processes Personal Information, as well as the steps we take to protect such information.
1.2 By utilising our Services, you acknowledge that you have read, and agree to, the terms of this Privacy Policy and that you consent to the use by Fibonacci Marketing of your Personal Information for the purposes set out in paragraph 3 of this Privacy Policy. If you do not wish to provide your Personal Information on the basis set out in this Privacy Policy, you should not enter the relevant information on the Website or provide your Personal Information to us otherwise. However, if you do not provide your Personal Information, you may not be able to use all of the Services.
1.3 Capitalised terms not defined in this Privacy Policy shall be as defined in the Terms & Conditions. This Privacy Policy is incorporated into, and forms part of, the Terms & Conditions.
1.4 Definitions:
“You” means the data subject who is using the services of Fibonacci Marketing.
“Personal Data” means information that specifically identifies an individual or that is linked to information that identifies a specific individual.
“Visitor” means an individual other than a user, who uses the public area, but has no access to the restricted areas of the Site or Service
1.5 Principles:
This policy is based on the following data protection principles:
• The processing of personal data shall take place in a lawful, fair and transparent way;
• The collecting of personal data shall only be performed for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
• The collecting of personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed;
• The personal data shall be accurate and where necessary, kept up to date;
• Every reasonable step shall be taken to ensure that personal data that are inaccurate having regard to the purposes for which they are processed, are erased or rectified without delay;
• Personal data shall be kept in a form which permits identification of the data subject for no longer than it is necessary for the purpose for which the personal data are processed;
• All personal data shall be kept confidential and stored in a manner that ensures appropriate security;
• Personal data shall not be shared with third parties except when necessary in order for them to provide services upon agreement;
• Data subjects shall have the right to request access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right of data portability.
2. The Information we collect:
2.1 As part of providing you with the Services, we collect your Personal Information on registering an account. “Personal Information” means any information from which you can be personally identified, including your name, surname, email address, home address, telephone number, mobile number and date of birth.
2.2 As part of providing you with the Services, we also collect information about the transactions you undertake, including details of payment cards used.
3. How we will use your Personal Information
3.1 We will process your Personal Information in accordance with the GDPR and to provide you with the Services. We will process your Personal Information to enable us to:
3.1.1 Set-up, administer and manage your Account and records (including processing deposits and withdrawals);
3.1.2 Provide and personalise the Services (provide examples);
3.1.3 Receive and respond to your communications and requests;
3.1.4 Notify you about updates to the Software and/or the Services;
3.1.5 Ensure that we are able to fulfil our regulatory obligations regarding your Account, including by verifying the accuracy of any information you give us;
3.1.6 Comply with our obligations under Applicable Laws
3.1.7 Investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with the Services (including, where appropriate, dealing with requests from authorised entities/Authorities for the sharing of information);
3.1.8 Carry out market research campaigns;
3.1.9 Preparing statistics relating to the use of the Services by you and other customers;
3.1.10 Provide you with information about, and support for, the Services, including changes to the Services, technical updates and changes to the Terms & Conditions (including this Privacy Policy);
3.1.11 Provided that you “opt-in” and don’t “opt-out” from this option, keep you informed on offers and promotions in relation to our products and services;
3.1.12 Support any other purpose necessary for performance of our contractual obligations or specifically stated at the time at which you provided your Personal Information. These are the “Purposes” for which we may collect your Personal Information.
3.2 If at any time you wish us to stop processing your Personal Information for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. You may contact us by .
3.3 To ensure a good quality of service we may monitor any communication you have with us whether in writing or by electronic mail (“recordings”). Any recordings remain the property of Fibonacci Marketing and will be used only for the purposes listed above.
3.4 In the event that the purposes for processing change, then we will notify you as soon as practicable and seek any additional consent that may be required.
4. Disclosing your Personal Information
4.1 Except as described in this Policy, we will not intentionally disclose the Personal Data that we collect or store on the Service to third parties without your prior explicit consent. We may disclose information to third parties in the following circumstances:
4.2 Any company within our Group (including to its employees and sub-contractors) which assists us in providing the Services or which otherwise has a need to know such information;
4.3 Any third party which assists us in providing the Services, including (but not limited to) payment processors, videographers, photographers, media providers.
4.4 Any third party which can assist us in verifying the accuracy of your Personal Information, including financial institutions and credit reference agencies (a record of the search may be retained by such third party).
4.5 Any third party which assists us in monitoring use of the Services, including the detection and prevention of fraud and collusion.
4.6 Any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us.
4.7 Any law enforcement body which may have any reasonable requirement to access your Personal Information;
4.8 Any regulatory body or authorised entity which may have any reasonable requirement to access your Personal Information; and
4.9 Any potential purchaser of Fibonacci Marketing or any investors in it or in any company within our Group (including in the event of insolvency).
4.10 If at any time you wish us to stop processing your Personal Information for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. You may contact us on info@fibonacci-marketing.com
5. Data Subject Rights
5.1 We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. Your principal rights under the GDPR are:
a. the right for information;
b. the right to access;
c. the right to rectification;
d. the right to erasure;
e. the right to restrict processing;
f. the right to object to processing;
g. the right to data portability;
h. the right to complain to a supervisory authority; and
i. the right to withdraw consent.
5.2 If you wish to access or amend any other Personal Data we hold about you, or to request that we delete any information about you, you may contact us by emailing info@fibonacci-marketing.com. We will acknowledge your request within seventy-two (72) hours and handle it promptly. Fibonacci Marketing will respond to these requests within a month, with a possibility to extend this period for particularly complex requests in accordance with Applicable Law. We will retain your information for as long as your account is active, as needed to provide you services, or to comply with our legal obligations, resolve disputes and enforce our agreements.
5.3 You may update, correct, or delete your Account information and preferences at any time by contacting info@fibonacci-marketing.com. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
5.4 You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some or all of the features and functionality of the Service.
5.5 At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.
5.6 In accordance with Applicable Law, we reserve the right to withhold personal data if disclosing it would adversely affect the rights and freedoms of others. Moreover, we reserve the right to charge a fee for complying with such requests if they are deemed manifestly unfounded or excessive. Fibonacci Marketing may charge a reasonable administrative-cost fee if further copies are requested.
6. Contacting us
6.1 For full details about Fibonacci Marketing Group members and where they operate please contact us on info@fibonacci-marketing.com.
6.2 If at any time you believe that we have not adhered to this Privacy Policy, please contact us on info@fibonacci-marketing.com and we will seek to promptly determine and correct the problem.
7. Advertising and use of Cookies
7.1 We may collect anonymous information about your use of the Website using “cookies”, pixel tags and similar functionality. A “cookie” is a small file of text which is downloaded onto your computer when you access the Website and it allows us to recognise when you come back to the Website. We use cookies for the operation of the Website, including (for example) to allow you to remain logged in as move between different parts of the Website. We also use cookies for our own analytical purposes so that we can identify where customers have encountered technical problems on the Website, and therefore help us improve our customers’ experience.
7.2 If you object to cookies or want to delete any cookies that are already stored on your computer, you should follow the instructions for deleting existing cookies and disabling future cookies on your web browser or equivalent software. Further information is available at www.aboutcookies.org. Please note that by deleting or disabling cookies you may not be able to access certain areas or features of the Website.
7.3 As part of the Website’s operation, and for our own statistical analysis of site traffic, our Website automatically logs internet IP addresses. We do not log any e-mail address of visitors to the Website. Our advertising system logs IP addresses to supply more accurate advertising features, such as language-specific banners.
7.4 While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.
8. Minors and Children’s Privacy
8.1 Protecting the privacy of minors is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at info@fibonacci-marketing.com and request that we delete your child’s Personal Data from our systems.
9. Security
9.1 We take appropriate security measures to protect against loss, misuse and unauthorized access, alteration, disclosure, or destruction of your information. Fibonacci Marketing has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing personal information, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.
9.2 No method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organisational safeguards. If you believe your Personal Data has been compromised, please contact us on info@fibonacci-marketing.com.
9.3 If we learn of a security systems breach, we will inform you of the occurrence of the breach in accordance with applicable law.
10. Privacy Settings
10.1 Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users with whom you may choose to share your information. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons. We have taken the neccassary steps to protect as much as possible your Personal Information in transit by utilising HTTPS on our Website and TLS 1.2 (a strong protocol), ECDHE_RSA with P-256 (a strong key exchange), and AES_128_GCM (a strong cipher).
11. Data Retention
11.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
11.2 We only retain the Personal Data collected from you for as long as your account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows: tracking and external data will be retained for a minimum period of six months following the termination of your agreement with Fibonacci Marketing, and for a maximum period of 12 months following the termination of your agreement with Fibonacci Marketing.
11.3 In some cases where it is not possible for us to specify in advance the periods for which your personal data will be retained, we will determine the period of retention based on the following criteria:
The period of retention of financial data will be determined based on any outstanding payments owed to Fibonacci Marketing after your agreement with Fibonacci Marketing has been terminated.
11.4 We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
12. International Transfers
12.1 The information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA) as we use website hosts which may be based outside of the EEA, or use servers based outside of the EEA. It may also be processed by staff operating outside the EEA who work for one our suppliers. A transfer of your personal data may happen if any of our servers are located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA. If we transfer or store your personal data outside the EEA in this way, we will take steps with the aim of ensuring that your privacy rights continue to be protected, as outlined in this privacy policy and in accordance with the GDPR and other applicable laws.
13. Data Protection Officer
13.1 Fibonacci Marketing has appointed a Data Protection Officer (“DPO”) who is responsible for matters relating to privacy and data protection. Fibonacci Marketing’s DPO can be reached by: Zvetlana@fibonacci-marketing.com
14. Changes to this Privacy Policy
14.1 Please note that this Privacy Policy may change from time to time. If we change this Privacy Policy in ways that affect how we use your Personal Information, we will advise you of the choices you may have as a result of those changes. We will also post a notice that this Privacy Policy has changed.