Moonie Trade's Privacy & Cookie Statement

Moonie Trade respects and protects your privacy. You can visit this website anonymously. Moonie Trade is not interested in names or other information revealing the identity of the visitors to this site. Information about you or your computer will only be registered with Moonie Trade for technical reasons, or in connection with a customer. This is done with a cookie or other means.

Privacy Statement

Moonie Trade take the privacy and security of your personal data very seriously, our privacy statement explains the information we collect from you, why we collect this data, how we ensure that it is kept safe and it explains your rights in relation to your personal data. You should read this statement carefully to ensure that you understand how we handle your personal data.

Who are we?

We are Moonie Trade, a financial entity registered within United Kingdom that is the data controller as defined in the General Data Protection Regulation or GDPR. Should you wish to contact us with general questions these can be sent to clients@mooniegroup.net

The registered office for Moonie Trade is Moonie Trade United, Suite 4 Commercial Mews, 93-97, Main Street, Larne, County Antrim, BT40 1HJ, U.K

What do we mean by personal data?

Personal data, is any information relating to you or can be used to identify you.

As a client of Moonie Trade you provide us with some of your personal data, this includes your name, telephone number, email address. It can also include Internet Protocol or IP addresses which in some circumstances can be used to identify you.

In the event that a corporate or professional party intend on becoming a client, we will also collect personal data which relates to the interested individuals of the company for example, directors, UBO, authorised representatives etc.

What do we mean by processing?

Processing is a concept from law. It is very broad concept which covers actions taken in respect to your personal data such as: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

Whenever Moonie Trade carries out any processing of personal data, we do so in line with the relevant privacy regulation.

How do we collect your data?

Below you will find ways in which we collect your personal data:

When you provide information by email, via the website, phone, in writing, or other means. This includes for example the information you provide during the registration, signing up for further information, entering a promotion or survey.;
When you visit our websites, we will automatically collect information including the IP address. We also collect information about your visit, this includes the full click path and mouse movement, pages you visited, searches which were made and other page interaction information.;
It is possible that we will receive information about you from credit rating agencies, this collection is carried out in line with the Client Agreement.;
For Corporate clients we will also collect information which is publicly available in relation to the UBOs of the company.;
If you visit us in person, for security we collect images of visitors using CCTV.;

Why do we process your personal data

Moonie Trade collect personal data for the following reasons:

To comply with the legal and regulatory obligations;
Marketing activities; and
Execution of contractual obligations.

Moonie Trade as an investment firm has a number of regulatory obligations which require the processing of client data; customer identification is one of the main reasons we collect and process personal data. Further to this there are additional legal and regulatory obligations we must comply with, co-operation with courts and authorised law enforcement agencies and to prevent and detect crime. Next to this, when people contact Moonie Trade to ask for additional information or to become a client of Moonie Trade, Moonie Trade needs to be able to contact that client or potential client or you request us to send you our periodical newsletters. Moonie Trade also have contractual obligations which mean that they need to process the data of their clients to fulfil these obligations.

When Moonie Trade process the personal data of its clients, it does so by using the minimal amount of data possible to ensure that aim is met.

What do we use personal data for?

Moonie Trade may for example do the following with your personal data:

Client acceptance

It is required by law for us to verify the identity of our clients, and without this information Moonie Trade could not provide its services to you. With your personal data we can for example,

Contact you.
Perform the relevant checks to ensure that you are eligible to become a client of Moonie Trade.
Review and check your request to become our client or to change your profile.
Keep your details in our administration and update them when there are changes.
Manage your profile(s) including you individual risk profile; which are based on internal client acceptance policies.

Reduce risks

We share the responsibility for the safety and stability of the financial sector. We also have a responsibility to you and all our clients. We will therefore use your personal data to reduce risks.

You might notice for example:

If the risk on your account breaches the allowed limits we will contact you to allow you to bring this back into the allowed limits.

You might not notice much of the below but it is also done to protect you:

We keep your IP address when you visit our site. This can be used in the event that there is a dispute as to who accessed your account or for the security of the company for example preventative measures against DDoS attacks.
Ensure good levels of security and invest in resources that protect both you and ourselves against all kind of crimes.
Internal quality checks, to determine possible issues, risks and testing to ensure that legislation has been properly implemented.
Carry out the relevant regulatory reporting.
Ensure that we remain a healthy company (risk management).

Legal obligations

There are a variety of legal obligations which Moonie Trade as an investment firm must follow.

Identification of clients: we check who you are and ensure that we have enough knowledge to allow us to offer our services.
Provide your personal data to specific organisations which are authorised to request this information, for example the tax authorities, financial supervisors, or when we are legally obliged to share this information for example during a criminal investigation.
We also have a number of obligations under anti money laundering legislation.

Marketing activities

At Moonie Trade we like to keep you informed. For example, with emails, newsletters, offers or updates to our Mobile App.

We can for example collect your searches within the website of Moonie Trade to ensure that our FAQ are up to date with the information clients need. This information is anonymised, so no one is able to ascertain which client is asking the question.
We use anonymised data to ensure that our marketing campaigns are effective.

If you would prefer not to receive some of this information, please feel free to contact the Service desk or unsubscribe via the button within the marketing email.

Improve and innovate

We may also use personal data for analytical research, this allows us to find better solutions and ensure that we continue to be innovative.

When we are carrying out these research activities, we use the minimal data required and do this in a way where your information is either pseudonymised or anonymised.

Google analytics

In order to ensure that the website of Moonie Trade is easy to use for clients, and to assess the success of campaigns Moonie Trade make use of Google Analytics. Moonie Trade have signed an agreement for the use of this service and ensures that the data is anonymised as much as possible, this includes masking part of the IP address.

Who do we have personal data from?

We can have (some) personal data of anyone who has contact with Moonie Trade. If you request additional information we will store the information which is provided during that request.

We are required by law to have personal information surrounding all of our clients. This information is gathered during the registration and requested when necessary. In some cases it may be necessary for us to make use of third parties to either verify or collect information.

What personal data is collected?

Data about you

This includes your name, address, telephone number and email address. In the event you are a corporate client we will also collect information surrounding your company or foundation. If you open a minor account or a joint account, the information surrounding the secondary account holders will also be collected. We will also ask for copies of your ID and personal numbers such as your tax identification number or relevant identifiers.

Transaction history

In addition to personal data which Moonie Trade have in relation to clients, we also keep a historic log concerning transaction and order history.

Contact history

We keep record of the times when you have contacted Moonie Trade, this includes telephone recordings, emails or other ways you have communicated with us.

Website visits and app use

In the event that you visit the website of Moonie Trade, we will also collect the IP address which is used. Should your IP address be used, for example via Google Analytics this will be done in an anonymised way.

External data sources

There are times where Moonie Trade will use external data provides, such as checking with the relevant chamber of commerce or in the event a credit check is required.

In the event that Moonie Trade carry out credit checks (BKR) they apply the strictest confidentiality on this information. Any individual who has access to this information does so only in the performance of their duty and the relevant data protection regulation is fully complied with. In the event you have questions of when BKR checks are carried out please contact the service desk of Moonie Trade.

Sensitive personal data

Sensitive personal data include things such as tax identification number, criminal history, biometric data, political beliefs, sexuality or ethnic origin, etc. If processing sensitive personal data is necessary, there are stricter rules applied to this.

At Moonie Trade we never use sensitive data related to health, religious beliefs, political or philosophical beliefs, sexual orientation or ethnic origin.

We have a legal obligation to identify our clients, therefore we require the tax identification number to do this.

Who do we share your personal information with?

In principle we do not share your information with others. It is possible that we may share personal data within the Group which Moonie Trade is a part of. All members of the Group which Moonie Trade is a part of have the same strict Privacy Policy. The police, judiciary, regulators and the tax authority can also request information from us on the grounds of law. However, we follow procedures which ensure that any sharing of information is both legitimate and proportionate.

Service providers

In the event we use a service provider to assist Moonie Trade, we will aim to inform you about the use of a third party and limit the sharing of personal information strictly to what is required for that specific assignment.

In the event that you make use of the Morgan Stanley Liquidity Funds, it is possible that we will need to provide them with information about who you are. In the event that this information will be provided to Morgan Stanley with the relevant safeguards in place.

With other companies on your own request

There are times when we will only share your personal data with other companies when you specifically ask. When this is done, we will specify this in the agreement to share the information.

Government and regulatory bodies

As an investment firm regulated within the United Kingdom, there are times when we receive requests for information surrounding our clients. We are obliged under law to provide the regulators with this information. Additionally, we have legal obligations which require us to share information with governmental bodies and competent legal authorities. The data protection regulations which cover Moonie Trade are also applicable to these bodies.

Moonie Trade, in its capacity of Qualified Intermediary, may exchange information directly with the Internal Revenue Service for purpose of establishing your status as a non-US Person and, if applicable, obtaining a reduced rate of withholding.

Moonie Trade will in specific circumstances also share information with relevant tax authorities.

How long do we store your personal data?

When you become a client of Moonie Trade we will keep your personal data for the duration of our relationship, we have a legitimate business need to do so. Upon the end of the relationship we are required to keep this personal data for five years. We need to keep this to ensure that we can comply with legal obligations such as fighting financial crime or to settle any disputes or mount a legal defence.

How do we protect your personal data?

Security

We spend a lot of time and resources to ensure our systems and your personal data have the relevant security measures in place. In the case that there is a breach of our systems we will report this to the relevant authorities and ensure that our clients are aware.

We have appropriate technical and organisational measures in place to protect your personal data against unauthorised access including accidental loss, destruction or disclosure of your data. We place restrictions on the access of personal data, so only those employees who need to access your data can. To ensure that any new processing is justified and compliant with the law we complete data protection impact assessments and carry out monitoring of any external data processors.

Confidentiality

Our employees have all signed a confidentiality agreement and agreed to an internal code of conduct and follow the Oath of promise in the financial sector. Further to this, only authorised personnel may view and process your personal data.

Supervision

We are supervised by the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) to ensure we comply with the Personal Data Protection Act.
Moonie Trade operates under behavioural supervision of The United Kingdom Authority for Financial Markets (AFM) and the prudential supervision of the British Central Bank.

Is your personal data used in automated decision making?

There are times for example when you change profile from a Basic to an Active or Trader or Day Trader that we will automatically screen your account against the information from the Bureau Krediet Registratie. Should there be an issue in providing the services of Debit Money, the Service Desk will contact you to inform you that you are unable to make use of the services Debit Money and how to proceed in this case.

Your rights

Right of access:

you have the right to access any personal data which Moonie Trade hold about you. We can provide a copy of this information, to request this you can contact the relevant Service Desk of Moonie Trade who can provide this information after completing security.
Right to rectification:

if you find your data to be incorrect or outdated, you should contact the relevant service desk of Moonie Trade to request for this data to be updated.
Complaints:

If you have complaints about the processing of your personal data, please get in touch either with the relevant service desk of Moonie Trade or by contacting the Data Protection Officer via clients@mooniegroup.net
Autoriteit Persoonsgegevens:

Under GDPR you have the right to complain about our processing of your personal data to the autoriteit Persoonsgegevens.

Under GDPR you have some other rights which may be possible in specific circumstances:

Right to Erasure:

in certain circumstances it is possible for us to delete some of or all the personal data we hold for you.
Right to restriction of processing:

You can ask for Moonie Trade to restrict the way your personal data is processed.
Right to data portability:

It is possible to request for your data to be provided to you for to be sent to a third party.
Right to object:

You have the right to object to the processing of your personal data when this processing is done on the basis of legitimate interest.
Right to stop marketing:

it is possible to stop using your personal data for direct-marketing purposes. This can be done via the unsubscribe button in the marketing emails or by contacting the relevant Service Desk. Please be aware that for some communication we are required to inform you and for these it will not be possible to unsubscribe while you are a client, this includes changes to the client agreement for example.

Furthermore, in the event that consent was required for the processing of your personal data, you have the right to withdraw your consent as given regarding your data at any time.

The above requests will be considered by Moonie Trade and responded to within a reasonable period. Please be aware that some of these requests might not be granted, for instance in cases where these would result in Moonie Trade failing to meet a legal requirement or the ability to exercise or defend a legal claim.

Our view on privacy

At Moonie Trade, our clients trust is fundamental to our relationship. We therefore strive to ensure that our clients have faith in the way we deal with their personal data. We take great care in ensuring that your data is safe and only processed when authorised to do so.

When we process your personal data, we always make sure that it is essential for us to do this. When possible, we will anonymise your personal data or when this is not possible, we will only use the data which is strictly necessary. For processing your personal data, we will also ensure that the concept of ‘privacy by design’ is at the heart of our development.

Our privacy policy is updated regularly, as law and regulations are continuously subjected to change, we will review the policy to ensure that it is kept up to date.

Questions about privacy

In the event you have some additional questions in relation to privacy or your personal data you can contact the service desk of Moonie Trade where they will answer all questions.

In the event that you wish to complain about the way we have handled your personal data please contact the data protection officer via clients@mooniegroup.net. Please note when contacting the data protection officer this communication will be answered in English. The DPO will then look into your complaint and work towards a resolution.

If you still feel that your personal data has not been handled appropriately according to the law, you can contact Autoriteit Persoonsgegevens and file a complaint with them.

What Moonie Trade uses your personal information for?

Moonie Trade only records personal information that you have provided upon request when you become a client of Moonie Trade and only after your explicit permission. Without these statements Moonie Trade cannot and must not exercise its business activities. Moonie Trade and Moonie Trades group companies will use your information to provide you services that keep you informed about (new) products and services from Moonie Trade and group companies for anonymous statistical analysis, and comply with legal obligations.

All telephone conversations between the customer and Moonie Trade are recorded. These recordings are stored and can be used for:

delivery of documents, such as by difference of interpretation or regarding the content of the telephone conversation;
(fraud) detection and investigation;
evaluation of service quality;
training, coaching, and evaluation purposes.

Liability

Moonie Trade considers it important that the processing of your (personal) information is conducted in a manner that is consistent with the existing safeguards to protect your personal information. Moonie Trade complies with the rules of the Data Protection Act and the Act on Financial Supervision in all its activities. Your (personal) information will not be disclosed to third parties outside Moonie Trade and Moonie Trade's group companies without your express consent, unless legal obligations require of Moonie Trade.

Third-party websites

Moonie Trade and group companies are not responsible for the measures of other websites using terms, even when they are associated with Moonie Trade's and the Group's websites with hyperlinks or otherwise.

Exercise of rights

You have the right to see your information and when necessary the ability improve or correct this information. For this, contact Moonie Trade through this website.

We'll keep you updated about (new) products and services from Moonie Trade and group companies via e-mail. If you do not want this, it can be specified via clients@mooniegroup.net

Changes

Moonie Trade reserves the right to make changes to this statement. It is therefore advisable to consult this privacy statement regularly when you visit this website.

Do you think that there is something wrong with this statement or are you unhappy with another aspect of our service? Please make sure to contact us. Your complaint will be handled by Moonie Trade's compliance officer. If you are unhappy with Moonie Trades assessment, please contact our customer support