Last revised: October 7, 2020
We, at New Capital, respect your privacy and your privacy is extremely important to us. We are required by regulations to collect, use and store your Personal Information in certain ways. We do not tolerate spam and will never sell, rent, lease or give away your information to any third party (unless required by law). Nor will send you an unsolicited email.
We will not collect any personal information (eg. name, email address) without your explicit permission. When we ask you to provide information by which you can be identified when using our Services, you can be assured that the information provided will only be used in accordance with this privacy statement.
We collect two types of information from our Users:
We may collect the following types of information from you:
To establish an account and access our Services, we will ask you to provide us with some important information about yourself. Please note that the Personal Information we collect is required in order for us to contractually provide the Services, as well as for us to meet our regulatory requirements (such as Anti-Money Laundering and Know-Your-Customer regulations), and to safeguard our legitimate interests. In the event that you choose not to provide such information, we may not be able to provide our Services. As we add new features and Services, you may be asked to provide additional information. Any information you provide to us that is not required is voluntary.
We may collect the following types of information from you:
To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us to address user support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site.
From time to time, we may obtain information about you from third party sources as required or permitted by applicable law. These sources may include:
The following chart summarizes what kind of information we collect from you:
|Information category||Site Visitors||Users of Source Force/ Exchange|
|Cookies and other tracking technologies|
|Log files (include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages)|
|Copy of a government-issued ID / passport|
|Details regarding the government-issued ID / passport (number, issuing country and issuance/expiration date)|
|Country of residence / address|
|Date of birth|
|Details regarding your business activity, income and source of funds|
|The purpose for opening the account and related information|
|Details regarding whether or not the User is a Politically Exposed Person (PEP)|
|Transaction information (information about the transactions you make on our Services, such your name, the amount, and/or timestamp)|
|Correspondence: Survey responses, information provided to our support team or user research team|
Kindly note that without providing the above information, and unless that information, at our sole discretion, is determined to be satisfactory for our specific requirements, the User will not be able to register and use our Services.
In addition, we also may collect information regarding the behavior of the users on our Services, which includes keystrokes, captioning and recording of User behavior, mouse movements and other activities.
In addition, we may collect the User's publicly-available social network information in cases when the User chooses to link their other social network accounts with that of New Capital.
In the event that a User registers for the Services or otherwise grants us with certain access permission to his/her existing third-party social network account, the third-party social network(s) operating such account(s) may provide us with certain information about the User, as is stored in and/or made available by the User through his/her account and in accordance with the permission granted to us by the User. For example, such information may consist of, as applicable and/or made available by the User, the User's name, public profile picture URL address, account ID, email address, date of birth, gender, occupation or work information, education and other information which the User has made public.
Our primary purpose in collecting Personal Information is to meet regulatory requirements, for loss prevention and anti-fraud purposes. We also wish to provide you with a secure, smooth, efficient, and customized experience. We generally use Personal Information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes.
We collect information in order to:
We will not use your Personal Information for purposes other than those purposes that we have disclosed to you without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your Personal Information with third parties. You may opt out of having your Personal Information shared with third parties, or allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected this information or subsequently obtained your authorization. If you choose to so limit the use of your Personal Information, certain features or our Services may not be available to you.
We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.
We take care to allow your Personal Information to be accessed only by those who require such access to perform their tasks and duties, and to only share this information with third parties who have a legitimate purpose for accessing it. New Capital will never sell or rent your Personal Information to third parties without your explicit consent. We will only share your information in the following circumstances:
When using our Services, your data is processed and stored in the EU and other countries. We and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process that information. We provide adequate protection for the transfer of personal data to countries outside of the European Economic Area (EEA) that are not recognized as providing adequate data protection. This protection is achieved through a series of intercompany agreements based on the Standard Contractual Clauses authorized under EU law (the content of the standard contractual clauses is available here).
We understand how important your privacy is, which is why New Capital maintains (and contractually requires third parties it shares your information with to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the Personal Information you entrust to us.
We may store and process all or part of your Personal and transactional Information. We protect your Personal Information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to Personal Information only for those employees who require this information to fulfill their job responsibilities.
However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own Personal Information. When registering with our Services, it is important to take all necessary precautionary measures by using 2FA or other methods of digital identity authorization. You should immediately notify us if you become aware of any unauthorized access to or use of your account.
If you have registered with an account through our Services, New Capital will retain your Personal Information during the period that your account is active. Furthermore, New Capital will retain your Personal Information for an additional period as deemed necessary to enable New Capital to meet its legal obligations under applicable laws or regulations, such as the KYC and AML regulations, as well as to meet New Capital's contractual obligations.
In addition, New Capital may retain Personal Information for longer periods, provided that retaining such information is strictly necessary for New Capital’s legitimate interests, such as fraud prevention and record keeping, enforcing its policies, resolving or exercising claims regarding potential disputes, and where New Capital is guided to do so by the applicable regulatory authority.
To use the Service, you must be over the age of eighteen (18). New Capital does not knowingly collect Personal Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we may verify that minors under the age of eighteen (18) are not using the Services. If you are under the age of eighteen (18) you should immediately contact us for special permission to use our Services. Such permission will only be granted at our sole discretion, and with the stipulation that it does not contravene any applicable laws or regulations. Otherwise, in the event that it comes to our knowledge that a person under the age of eighteen (18) is using the Services, we will prohibit and block such a User from accessing the Services and will take appropriate measures to prevent that User from making use of our Services. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent this unauthorized access to our Services.
When you access or use the Services, we may use (and authorize third parties to use) industry-wide technologies such as cookies or similar technologies, including web beacons, pixel tags, scripts, tags and other technologies that store certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your Service experience much more convenient and effortless.
Your rights to Personal Information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.
You may contact us at any time at gdpr at new dot capital, and request:
E-mail address: gdpr at new dot capital
Address: Lvovo str. 13C-5, LT-09313 Vilnius, Lithuania
We will make an effort to reply within a reasonable time frame. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can contact the applicable data protection authority: