CIF License no. 303/16  
Regulated by the Cyprus Securities & Exchange Commission  
PRIVACY POLICY  
Contents  
1. Introduction ................................................................................................................................ 3  
2. Scope of the Privacy Policy ......................................................................................................... 3  
3. Our Commitment to You............................................................................................................. 3  
4. Data Protection Officer............................................................................................................... 3  
5. Your Consent to Collection and Use of Personal Information.................................................... 4  
6. Why We Process and Use Your Information............................................................................... 5  
7. Disclosure of your Personal Data................................................................................................ 5  
8. Safeguard Measures ................................................................................................................... 6  
9. Duration of keeping Your Information........................................................................................ 6  
10.Your Legal rights ........................................................................................................................ 7  
11. Cookies...................................................................................................................................... 8  
12. Geographical processing of Personal data ............................................................................... 8  
13. Questions .................................................................................................................................. 8  
14. Update of this Policy................................................................................................................. 9  
2
Rynat Trading Ltd is registered as a Cyprus Investment Firm (CIF) with the registration number HE344135 and licensed by the Cyprus Securities  
and Exchange Commission (CySEC) under license number 303/16. Our registered address is 88, Agias Fylaxeos, Zavos City Center, First Floor,  
Office 101, Limassol 3025, Cyprus.  
1. Introduction  
Rynat Trading LTD is a Cyprus Investment Firm (CIF) and is authorized and regulated by the Cyprus  
Securities and Exchange Commission (CySEC) under License number 303/16.  
Rynat Trading LTD (hereinafter called the “Company”) is governed by the provisions of the  
Markets of Financial Instruments Directive II (MiFID II) of the European Union and its  
implementation and transposition into Cyprus national law, Law 87(I)/2017 as amended and/or  
replaced).  
The Company is registered with the Office of the Commissioner for Personal Data Protection of  
the Republic of Cyprus for the purposes of personal data processing. Therefore, your personal  
data is kept and handled in accordance with the Processing of Personal Data (Protection of the  
Individual) Law of 2001, its amendment (Law No. 37(I)/2003) and the Processing of Personal Data  
(Protection of Individual) Amending Law 2012 (Law. No. 105(I)/2012 and the Regulation of  
Electronic Communication Data Protection Act 1998 and General Data Protection Regulation (EU  
2016/679) (“GDPR”), as amended from time to time. The Company is the data controller  
responsible for your personal data.  
2. Scope of the Privacy Policy  
Through this privacy policy, your data may be called either “personal data” or “personal  
information”. We may also sometimes collectively refer to handling, collecting, protecting and  
storing your personal data or any such action as “processing” such personal data.  
For the purposes of this statement, personal data shall mean any information relating to you  
which identifies or may identify you and which includes, for example, your name, address and  
identification number.  
To fully understand the changes and terms that will govern your use of our “Services,” you will  
need to read the full Privacy Policy and Cookie Policy  
3. Our Commitment to You  
We understand the importance of maintaining the confidentiality and privacy of Your  
Information. By entrusting us with Your Information, we would like to assure you of our  
commitment to keep such information private. We have taken measurable steps to protect the  
confidentiality, security and integrity of Your Information.  
4. Data Protection Officer  
The Company has appointed a Data Protection Officer (“DPO”). Should you have any questions  
about this privacy policy, including any requests to exercise your legal rights, please send us an  
email at: dpo@rynattrading.com  
3
Rynat Trading Ltd is registered as a Cyprus Investment Firm (CIF) with the registration number HE344135 and licensed by the Cyprus Securities  
and Exchange Commission (CySEC) under license number 303/16. Our registered address is 88, Agias Fylaxeos, Zavos City Center, First Floor,  
Office 101, Limassol 3025, Cyprus.  
5. Your Consent to Collection and Use of Personal Information  
The Company collects information directly from you, through any correspondence made with us  
by phone, e-mail or otherwise; including information which you enter when you register to use  
our website, mobile app, subscribe to our service or any other activities carried out on our  
website or any connected applications Please note that when you access our Website we collect  
non-identifiable information in the following ways:  
•
Contact Data – we collect, which may include, but are not limited to, your first name, last  
name, nationality, date of birth, telephone number (landline and mobile), fax number,  
email address and postal address  
•
Personal and Professional Information - we collect, which may include, but are not limited  
to, your marital status, education, occupation, information regarding your financial  
situation such as source of wealth and gross annual income, tax identification number.  
•
•
Cookies (including third party Cookies) – Please see our Cookies Policy  
Financial data – to use the Company’s services, we may require to collect certain  
information, such as, bank details, trading activity, transaction history, account balance  
information.  
The Company will need to obtain the following documents for verification purposes of clients’  
trading accounts; proof of identification, proof of address and proof of transfer.  
The Company has the right to request additional documents and information to carry out its due  
diligence where it deems fit. We only collect personal data that is adequate and relevant for the  
purposes of our business and for a reasonable period of time as required by law. We never ask  
for more information that is required by law.  
If you have given us your specific consent for processing (other than for the reasons set out  
above) then the lawfulness of such processing is based on that consent. You also consent when  
the Company is transferring your personal information outside the European Economic Area  
(“EEA”) where this is necessary for the Company to fulfil its contractual obligations to you (see  
section 12 below). You have the right to revoke consent at any time. However, any processing of  
personal data prior to the receipt of your revocation will not be affected.  
4
Rynat Trading Ltd is registered as a Cyprus Investment Firm (CIF) with the registration number HE344135 and licensed by the Cyprus Securities  
and Exchange Commission (CySEC) under license number 303/16. Our registered address is 88, Agias Fylaxeos, Zavos City Center, First Floor,  
Office 101, Limassol 3025, Cyprus.  
6. Why We Process and Use Your Information  
We are committed to protecting your privacy and handling your data in a transparent manner,  
and as such we collect, use, disclose, store and process your personal data for the performance  
of our services as required by law.  
Furthermore, we are obligated to collect such personal data not only for the commencement and  
execution of a business relationship with you but also for the performance of our contractual,  
regulatory, statutory and legal obligations  
Based on the requirements of our regulated authorities in our efforts to maintain our Know-Your-  
Client procedures, we will require to verify clients’ trading accounts, so to ensure our clients meet  
appropriateness and suitability requirements, process transactions, send information about  
transactions/services and keep you updated with products, services and news  
We further collect data to operate, provide, improve, understand, customise and support our  
services in relation to your account.  
Marketing Purposes – we may collect your personal information through our App(s), one of our  
social medial channels, public databases; joint marketing partners; from people with whom you  
are connected on social media platforms, as well as from other third parties. Use of this personal  
information, allows us to deliver information by email, SMS, push notification, email, in-app  
notification or contact you by telephone or by any other means to provide you with information  
about our products, services, training and offers we think would be of interest to you. We always  
give you the right to opt out/unsubscribe to receiving such communications from us at any time.  
7. Disclosure of your Personal Data  
When providing our services or conducting our business operations, if necessary, we may disclose  
or share your personal data. Such sharing of data is in accordance with the Company’s internal  
security policies and applicable data privacy laws. We do not sell the personal data we collect  
from you, or we do not distribute/transfer any personal data to any unauthorized or non-  
affiliated third parties.  
All the Company’s external services providers and suppliers enter into contractual agreements  
with us, by which they legally agree to confidentiality and data protection to the data protection  
law and General Data Protection Regulation (EU 2016/679) (“GDPR”). Recipients with whom we  
may disclose or share your personal information, may include the following:  
5
Rynat Trading Ltd is registered as a Cyprus Investment Firm (CIF) with the registration number HE344135 and licensed by the Cyprus Securities  
and Exchange Commission (CySEC) under license number 303/16. Our registered address is 88, Agias Fylaxeos, Zavos City Center, First Floor,  
Office 101, Limassol 3025, Cyprus.  
a) Within the Company – such as various departments within the Company, where all  
employees and contractors are required to follow our data privacy and security policies  
when handling personal data.  
b) Supervisory and other regulatory and public authorities, notary offices, tax authorities,  
criminal prosecution authorities as much as a statutory obligation exists  
c) Third Party service providers – such as, and which are not limited to, financial institutions,  
banks and payments processing providers, external and internal auditors, financial and  
business advisors, fraud prevention agencies, Debt collectors subject to bankruptcy or  
insolvency claims, External authorised processors for processing client data, software  
system and platform support, cloud hosting services, data analytics, direct  
marketing/advertising services  
8. Safeguard Measures  
The Company takes reasonable precautions to protect Personal Information from loss, theft,  
misuse, unauthorized access or disclosure, alteration, or destruction.  
The Company employ physical, electronic, and procedural safeguards to protect Personal  
Information and it does not store Personal Information for longer than necessary to provide the  
Service or as permitted by law.  
In accordance with the recommendations of Payment Card Industry Security Standards Council,  
customer card details are protected using Transport Layer encryption — TLS 1.2 and application  
layer with algorithm AES and key length 256 bit. The Company does not store or collect any  
Credit Card data. All credit card information is stored on the payment provider side.  
The Company’s datacenter(s) contain both internal and external servers. Access to the  
Company’s internal server is restricted to pre-approved persons, servers and locations; our  
external servers can be accessed via the Internet. Your Information is stored and encrypted on  
secure servers and our servers can only ever be accessed by authorized personnel.  
While we will use all reasonable efforts to safeguard Your Information, you acknowledge that the  
use of the internet is not entirely secure and for this reason we cannot guarantee the security or  
integrity of any personal data transferred from you, or to you via the internet.  
9. Duration of keeping Your Information  
We will not keep Your Information for any longer than is required for legal and/or business  
purposes. In many cases, information must be kept for considerable periods of time, subject to a  
maximum of seven (7) years. Retention periods will be determined considering the type of  
information that is collected and the purpose for which it is collected, bearing in mind the  
6
Rynat Trading Ltd is registered as a Cyprus Investment Firm (CIF) with the registration number HE344135 and licensed by the Cyprus Securities  
and Exchange Commission (CySEC) under license number 303/16. Our registered address is 88, Agias Fylaxeos, Zavos City Center, First Floor,  
Office 101, Limassol 3025, Cyprus.  
requirements applicable to the situation and the need to destroy outdated, unused information  
at the earliest reasonable time.  
10.Your Legal rights  
You have the following rights under data protection laws in terms of personal data we hold about  
you:  
a) Receive a Copy of your personal data – you have the right to have access to your personal  
data, where your personal data is stored, how we collected your data and for what  
purposes. Your request to obtain your personal data must be sent to us in writing via a  
durable medium, where we will process your request in accordance with the applicable  
law(s).  
b) Request rectification/correction of the personal data we hold about you – you can at any  
time have the right to correct any inaccurate or incomplete data we hold about you. If  
this applies to you, please reach to our Customer Support team.  
c) Request erasure of your personal information – you have the right to request deletion of  
your personal data (“right to be forgotten”). Please bear in mind that, as we are a CySEC  
licensed investment firm, we are under certain legal obligation to hold your data for a  
maximum of seven (7) years.  
d) Object to processing of your personal data – you have the right to object to the processing  
of your personal data. Please bear in mind that, as a CySEC licensed investment firm,  
should you object to processing certain data, then we may not be able to provide you our  
services.  
e) Right to data portability – you have the right to request for your personal data to be  
transferred to a third party, your request to transfer your personal data must be sent to  
us in writing via a durable medium, where we will process your request in accordance  
with the applicable law(s).  
f) Data being processed for direct marketing purposes – you have the right to object for  
your personal data to be used for direct marketing (this includes profiling), where you can  
unsubscribe to our direct marketing campaigns.  
Please note that for all the above mentioned, we may need to request specific information from  
you to help us confirm your identity. This is a security measure to ensure that personal data is  
7
Rynat Trading Ltd is registered as a Cyprus Investment Firm (CIF) with the registration number HE344135 and licensed by the Cyprus Securities  
and Exchange Commission (CySEC) under license number 303/16. Our registered address is 88, Agias Fylaxeos, Zavos City Center, First Floor,  
Office 101, Limassol 3025, Cyprus.  
not disclosed to any unauthorized third party. In certain circumstances relevant legal  
requirements may prevent us from providing your personal information.  
11. Cookies  
We use cookies to help us find which services you are interested in and remember details about  
your application. We don't store sensitive information like your name or address in our cookies,  
just an anonymous reference to them so that we're able to find them. We also occasionally set  
Cookies to help you navigate around the site, enhance your experience, or give you important  
information regarding interests.  
When you access our Website, we collect information that your browser sends whenever you  
visit the Website or an online service (“Cookies”). Such Cookies may include, but is not limited  
to, your computer’s Internet Protocol address, browser type, the web page you were visiting  
before you came to the Site and information you search for on the Site. In addition, if you access  
the Website via a mobile device, we may collect a PushID, subject to your consent as indicated  
by you in the mobile application, and a Mobile IP.  
You can choose to disable or block these cookies in your browser but without some of them our  
site will not be able to give you the best experience possible. For more detailed information  
please see our Cookies Policy.  
12. Geographical processing of Personal data  
All your personal data is processed within the European Economic Area (“EEA”). In some cases,  
when we provide our services to you, your personal data may be transferred to and processed  
within countries outside the EEA, such jurisdictions may not offer the same level of data  
protection as in the EEA. Through accepting provisions of our services to you, you acknowledge  
and consent to such transfer.  
13. Questions  
If you have any questions regarding this policy, wish to access or change your information or have  
a complaint, or if you have any questions about security on our Website, you may email us at  
dpo@rynattrading.com  
If you are not content with our response and have concerns or believe we are not processing  
your personal data in accordance with the law, you have the right to escalate your complaint to  
the data protection regulator in your jurisdiction. The Office of the Commissioner for Personal  
Data Protection is at 1 Iasonos str.,1082 Nicosia. Further information is available on the Office of  
the Commissioner for Personal Data Protection's website http://www.dataprotection.gov.cy/.  
8
Rynat Trading Ltd is registered as a Cyprus Investment Firm (CIF) with the registration number HE344135 and licensed by the Cyprus Securities  
and Exchange Commission (CySEC) under license number 303/16. Our registered address is 88, Agias Fylaxeos, Zavos City Center, First Floor,  
Office 101, Limassol 3025, Cyprus.  
14. Update of this Policy.  
This Policy is subject to change without notice. For this reason, you are advised to look for up-  
dates from time to time.  
9
Rynat Trading Ltd is registered as a Cyprus Investment Firm (CIF) with the registration number HE344135 and licensed by the Cyprus Securities  
and Exchange Commission (CySEC) under license number 303/16. Our registered address is 88, Agias Fylaxeos, Zavos City Center, First Floor,  
Office 101, Limassol 3025, Cyprus.