Personal Data Agreement

United Exchange Information on Fair Processing and Transfer of Personal Data

Dear User,

About the Protection of Personal Data Act;

United Exchange would like to inform you that we attach great importance to the security of your personal data, and the safekeeping of your data will be our privilege in all services we offer you, both now and in the future.

In line with the provisions of the protection of your personal data by St. Vincent and The Grenadines Maritime Administration subject to EU General Data Protection Regulation 2016/679, all information that renders your identity specific or identifiable, including all special personal data, are deemed Personal Data, and will be processed by United Exchange, as the Data Supervisor, according to the context explained below, and within the limits prescribed by law and codes.

“Processing of Personal Data” means any kind of transaction performed on said data such as obtaining, recording, storing, maintaining, changing, re-arranging, explaining, transferring, receiving, making accessible, classification or prevention of use.

1. Purpose and Legal Grounds for Processing of Employees’ Personal Data

Your personal data may vary depending on the services and commercial activities provided by United Exchange; it will be collected and obtained through automated and non-automated methods by United Exchange business units, website, call center, telephone calls, SMS records, e-mail addresses, social media, mobile applications and similar means in oral, written and electronic media while you are using the products and services offered, and/or within the legal periods, and will continue to be updated and processed.

Your personal data will be processed in order to protect our legitimate interests, and for United Exchange to meet legal and administrative obligations, to establish and perform the agreements that will be concluded with United Exchange, to use in products and services you have/will purchase from United Exchange, to communicate with you about the products and services you have/will purchase from United Exchange, to offer you an effective user service; in addition, to use in marketing activities if you have given permission, for product/service bids, modeling, reporting, scoring, risk monitoring, intelligence, current or new product works and potential user determination, to secure the legal and commercial security of persons who are doing business with United Exchange, coordination at and between units of United Exchange, to ensure and advance cooperation and efficiency, to resolve any legal conflicts that may arise in the future, to answer and meet the demands and questions of our users, to ensure the security of the United Exchange website and other electronic systems, to notify any amendments in the regulations or rules and policies adopted by United Exchange, or to notify you of any other developments related to you, to examine any breaches of contract and laws in order to carry out our activities offered to you, to prevent such breaches and inform the relevant administrative or legal authorities; to protect the life or corporal integrity of persons or others if:

  1. the Data Owner has given clear consent

  2. it is expressly stated in the laws,

  3. someone who cannot express their consent due to physical conditions or whose consent is not legally accepted according to EU General Data Protection Regulation 2016/679,

  4. Provided that it is directly related to the establishment or execution of the contract concluded with United Exchange with your approval and/or signature, your personal data will be processed if the contract requires such process;

  5. e.If it is required for United Exchange to fulfill its legal obligation,

  6. If it is publicized by you personally,

  7. If data processing is required to establish, use or protect a certain right,

  8. In order not to infringe your basic rights and freedoms,
    If such processing is required for the legitimate interests of Demo Exchange;

Within the scope of conditions and purposes of personal data processing as stated in Article 6;

a- the Data Owner has given clear consent,

b- as specified by the Law.

2. Transferring your personal data

Your personal data may be transferred to administrative and official authorities if it's required for such data to be transferred, their parties we outsource from in order to carry out our activities, our program partner institutions, administrations, local/international institutions we cooperate with, institutions we receive service/support/consultation from or local/foreign/international institutions which are project/program partners, third parties we receive support from in areas such as call centers, subcontractors, independent audit, and support institutions and other similar legal entities and third parties we cooperate with in order to ensure the legal and commercial security of these third parties and/or the safety of the electronic and physical medium, and due to legal obligations within the limits prescribed by law.

Provided that we take the necessary security measures, United Exchange may transfer, process or maintain your personal data for storage, archiving, servers supporting information technologies, hosting companies, programs, cloud computing etc. and other electronic media in OECD countries, mainly in EU countries, the USA and the UK.

3. Personal data collection methods

Your personal data will be collected from contracts/information forms and other documents issued with your approval and/or signature, notices you make through electronic approval and/or signatures, by our General Directorate, physical environments, call centers, internet websites, our mobile applications, internet operations, social media and other public media, user interviews, scanning of legal records, market intelligence, Identity Sharing System, SMS channels, digital applications to websites, written/digital applications sent to sales team, via verbal, written, visual, audio or electronic means that are or will be used in the future to contact you, completely or partially through automated systems or as part of data recording systems, and are maintained for the legal periods according to the applicable legislation.

Personal data collected for this legal reason may be processed and transferred for the purposes stated in Article 1 and 2 of this text for personal data processing conditions, and the purposes stated in EU General Data Protection Regulation 2016/679

4. Your Rights according to Article 11 of the Act

You have the right to:

  1. Find out whether your personal data has been processed,

  2. Request information if processed

  3. Learn the purpose of processing and whether the information is used accordingly,

  4. Learn of any 3rd parties the data may have been transferred to in Turkey/abroad,

  5. Request correction if missing/incorrectly processed,

  6. Request that personal data be deleted or destroyed if the reasons requiring the processing of personal data are eliminated,

  7. Request notification of any transactions made with 3rd parties they have been transferred to in accordance with paragraphs (e) and (f) listed above,

  8. Object to any results against you due to analyzing via exclusively automated systems,

  9. Request compensation for any losses arising due to unlawful processing of personal data.

5. Data Supervisors you may apply to according to the Act

You can submit your requests within the scope of your rights as stated in Article 4 by applying to United Exchange’s address listed below in person, by sending a notice through a notary public, or by emailing the email address below from your electronic mail address which you used to register with the United Exchange system.

Any applications submitted to our company must be in English, must include your name, surname, National ID number, your main place of residence or address of your business, your e-mail address and the subject of your request, and the information and documents related to your request must be attached to your application. If your application is in writing, it is also a legal obligation to sign the document.

While your requests will be concluded free of charge as a rule, if the reply to your request incurs a cost, you may be charged according to the tariffs set in PPDA or determined by other authorities.

For written applications:   CubeGlobal Brokers Ltd., Suite 305, Griffith Corporate Centre, P.O. Box 1510, Beachmont Kingston, St. Vincent and The Grenadines.

For applications by email:   [email protected]