Privacy Policy

This privacy policy (“Privacy Policy”) applies to all personal information processing activities conducted by Optimum LLC (“Optimum” or “the Firm”).

Optimum is a data controller with regard to the personal data that we process in the course of conducting our business (including the products and services that we provide).

Both personal and non-personal information collected is safeguarded according to the privacy and data protection standards adopted worldwide.

This Privacy Policy outlines how we collect and use personal data in the course of conducting our business, including providing services to, conducting business with counterparties that relates to the counterparty’s employees, officers or other associated individuals. “Personal data” is any information relating to an identified or identifiable living person.

We may update this Privacy Policy according to privacy law changes. When we do, we will communicate any material changes to you and make the updated Privacy Policy available.

If we amend our Privacy Policy, we will post these changes here so that you are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to use your information in a manner different from that stated at the time it was collected, we will notify you by email.

1. Optimum privacy processes

Optimum collects, oversees, stores, discloses, and otherwise uses (“process”) various categories of personal data at the inception, and for the duration, of your relationship with us. We will limit the collection and use of your personal data to that which is necessary for conducting one or more legitimate purposes, as outlined in this notice. Personal data typically includes: 

•  Basic personal information, including name, address, and date of birth.
• Contact information, including email address and telephone number.
• Financial information, including occupation, bank account numbers, bank statements, financial assets, liabilities and trading information.
• Contract notes.

Records of our discussions, including records of phone and video calls on messaging apps, such as Telegram.

We do not normally process special categories of personal data. Any processing of special categories of personal data will only take place once we’ve obtained your explicit consent or are otherwise lawfully permitted to do so. Special categories of personal data include:

•  Information about racial or ethnic origin.
• Religious or philosophical beliefs.
• Trade union membership.
• Physical or psychological health details or medical conditions; and
• Biometric information, relating to the physical, physiological or behavioral characteristics of a person.

Where permitted by law, Optimum may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with law relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions.

2. Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies are used as beacons, tags, and scripts to collect and track information and to improve and analyze our platform.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, you may not be able to use parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

3. How does Optimum obtain data?

Your data is made up of all the personal data we collect and hold about you.

It includes:

• Data you share with us
• Data that we received from third parties
• Data that we gather from publicly available sources, such as company websites and online search engines

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4. How does Optimum use your data?

We use this information for carefully considered purposes which also benefit our customers, and which include but are not restricted to the following:

• To provide and facilitate our services and products
• To share information with you
• To occasionally send company news, updates, promotions, offers and information relating to products and services provided by Optimum or of other parties that may be of interest to you
• To provide support for our services and products
• To create a “lookalike audience” or “matched audience” of (prospective) customers for targeted advertising on social media platforms
• To analyze website usage, analyze use of this website, analyze and measure ad impressions, and to protect the interests, rights, safety, or property of Optimum or others and to monitor compliance with and enforce the terms of any agreement with Optimum.
• To monitor to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, and hold those responsible for that activity

5. Rectification, Erasure, Restriction & Complaint

If you believe any of the data we hold about you is inaccurate, you have the right to request that we limit the use of that data and to rectify the inaccurate personal data.

You have a right to request the deletion or removal of your personal data, and subject to the relevant law or regulation, we have to comply with that request in the following circumstances:

• We no longer need to use your personal data for the purposes for which it was originally collected.
• We requested your consent to use your personal data and you wish you withdraw that consent; or
• We are not using your information in a lawful manner.

You may request us to restrict the use of your personal data if you believe that:

• Any of the data we hold about you is inaccurate
• We no longer need to use your data for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or
• We are not using your data in a lawful manner

If you wish to make a complaint regarding the way in which we have used your personal data, you can contact our Compliance department, who will investigate this matter. While we hope that we can address any concerns you may have, you can also contact the relevant organization on this matter.

Please note that in certain circumstances, if you do not agree to the way we use your data, we may no longer be able to provide certain products and/or services to you.

Should you wish to exercise any of these rights, have any questions about how we use your personal data, or would like to make a complaint, please contact us at trading@optimum.markets.

6. Portability

Where we have requested your consent to use your personal data or you have provided us with data for the purpose of entering into a contract with us, you have a right to receive the personal data you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible.

We’re not responsible for any such third party’s use of your personal data, which will be governed by their agreement with you and any privacy statement they provide to you.

7. Objection

In certain circumstances, you have a right to object to the processing of your personal data, and to request us to the limit use, unless we can evidence compelling and legitimate grounds for the use, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims.

8. Withdrawal of consent

Where we rely on your consent to process your personal data, you have a right to withdraw that consent at any time. We will always make it clear where we require your consent to conduct specific uses of your personal data. Please note that there may be legal, regulatory or other reasons why we would need to keep using your personal data, and Optimum will inform you of those reasons if applicable.

9. Sharing data with third parties

Optimum may share your personal data in the following ways : 

• To other entities within the entity.
• To professional advisers such as accountants, auditors and law firms.
• Where we are required by law, and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world.
• To selected third party providers providing services to us, such as anti-money laundering screening, onboarding due diligence or transaction monitoring services; and/or
• To select third party contractors or service providers that may process your Personal Data for us, such as marketing agencies, event co-sponsors, etc.
• Where it is permitted by law, it is necessary for our legitimate interest, or those of a third party, and is not inconsistent with the purposes listed above.

 10. Retention of information

In the course of our relationship with you, we will create and store records of your personal data on a variety of media (physical or electronic) and formats. We maintain these records in order to conduct our business effectively and to comply with legal and regulatory reasons. Retention periods for these records are determined based on the type of records and the applicable legal or regulatory requirements.

Optimum will keep your data for up to three years, following the termination of all agreements between Optimum and the counterparty, unless one of the following reasons apply:

• We are required to retain the data for a longer period of time in order to comply with a legal or regulatory obligation.
• We are unable, or it's impractical, for technical or operational reasons, to delete the data. This exception generally applies to circumstances where the data has been written to offline storages such as back-up tapes. In such circumstances, it is impractical to delete relevant sections within these tapes, and to rewrite these tapes with the remaining data intact.