We control the ways of collecting your Personal Information, and determine goals for which We use Personal Information. We are a “data controller” within the meaning of the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”) and other applicable European laws pertaining to data protection.
2. COLLECTION AND USE OF PERSONAL INFORMATION
A. PERSONAL INFORMATION WE COLLECT
We collect the next Personal Information:
We also automatically collect certain computer, device, and browsing information when you access the Website or use of Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:
We may automatically capture, store and otherwise process information about you even if you abandon the completion of an online application or registration form.
The Website is using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are typically stored on your computer’s hard drive.
C. HOW WE USE YOUR PERSONAL INFORMATION
We may use your Personal Information to:
We do not perform behavioral tracking of a customer’s activities on our Website or across different Websites, nor do we allow third-party data collection through our services. If you wish to stop receiving marketing communications from us, please contact us at firstname.lastname@example.org
3. DISCLOSING AND TRANSFERRING PERSONAL INFORMATION
We may disclose your Personal Information to third parties and legal and regulatory authorities, and transfer your Personal Information as described below:
A. DISCLOSURES TO THIRD PARTIES
B. DISCLOSURES TO LEGAL AUTHORITIES
We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:
C. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We store and process your Personal Information in data centers around the world, wherever Company facilities or service providers are located. As such, we may transfer your Personal Information between such data centers. Such transfers are undertaken in accordance with our legal and regulatory obligations and are performed only via protected channels.
D. OTHER CIRCUMSTANCES FOR DISCLOSURE OF PERSONAL INFORMATION
We also can disclose your Personal Information in the following circumstances:
4. EXTERNAL WEBSITES
Occasionally, the Website may provide references or links to other websites (“External websites”). We do not control these External websites third party sites or any of the content contained therein. You agree that we are in no way responsible or liable for External websites referenced or linked from the Company’s Website, including, but not limited to, website content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to, or arising from those sites. External websites have separate and independent privacy policies. We encourage you to review the policies, rules, terms, and regulations of each site that you visit. We seek to protect the integrity of our site and welcome any feedback about External information provided on the Company Website.
5. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
You are able to exercise all the right foreseen by legislation, if this does not contradict the legal requirements in relation to the prevention of money laundering and terrorist financing laws, our record keeping obligations, etc.
You have the following rights:
To exercise these rights, contact us at email@example.com.
Within 40 days of receipt of your written request we will provide you with your Personal Information, including the purposes for which it was used and to whom it was disclosed to in accordance with applicable legislation. We reserve the right to request additional information from you, that may be necessary in order to provide the duly respond to your request in accordance with applicable legislation and you agree with such our right. Also, if you wish to correct, update, and block inaccurate and/or incorrect data, we have a right to request a confirmation of correct data from you, for example, official documents containing such data.
Please note that if we are unable to verify your identity by e-mail messages or at your application to the call center, or in the case of reasonable doubts concerning your identity, we may ask you to provide a proof of identity, including by personal appearance in our office. This is the only way we can avoid disclosing your Personal Information to a person who can perpetrate your identity.
In some cases, we will not be able to change your Personal Information. In particular, such case can include the event when your personal information has already been used during the execution of any agreement or transaction, or is specified in any official document, etc. You have the right of withdrawal of consent to personal data processing. You may also exercise your right to be forgotten and erase your Personal information from our servers. In cases stipulated in Article 17 of GDPR, we will delete your Personal Information we process, except for those Personal Information which we are obliged to store in accordance with the requirements set forth by the applicable legislation.
Please be advised, that in case of realization of your right of withdrawal of consent to personal data processing or right to be forgotten, we may not be able to provide you our products or services, and we have a special right to terminate all our current agreements with you with the application of legal consequences of such termination, and you irrevocably acknowledge such our right.
In order to withdraw the consent to personal data processing and/or exercise your rights to be forgotten please contact us at firstname.lastname@example.org. Furthermore, in this case, for the purposes of safety, we may request you to present your ID document, including directly at our office.
6. SECURITY OF PERSONAL INFORMATION
We use a variety of security measures to ensure the confidentiality of your Personal Information, and to protect your Personal Information from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to: Password protected directories and databases.
Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely.
Limited access to hosting servers using 2FA and traffic encryption
All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorized Company personnel are permitted access to your Personal Information, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.
7. RETENTION OF PERSONAL INFORMATION
DATA PROTECTION OFFICER
To exercise all relevant rights, queries or complaints to any data protection matter between you and us, please in the first instance contact our Data Protection Officer at email@example.com.
AML / KYC
AMT Capital LLC is committed to the highest standards of the Anti-Money Laundering (AML) compliance and Counter-Terrorism Financing (CTF). The aim of the Companies Anti Money Laundering and Terrorist Financing Policy is to actively prevent the risks of these matters. To help the government fight the funding of terrorism and money laundering activities, law requires all financial institutions to obtain, verify, and record information that identifies each person opening an account. We are under the obligation to report suspicious activities of clients relevant to money laundering.
Money laundering – the process of converting funds, received from illegal activities (such as fraud, corruption, terrorism, etc.), into other funds or investments that look legitimate to hide or distort the real source of funds.
The process of money laundering can be divided into three sequential stages:
• Placement. At this stage, funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the company, the launderer may as well make several deposits instead of depositing the whole sum at once, this form of placement is called smurfing.
• Layering. Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered.
• Integration. Funds get back into circulation as legitimate to purchase goods and services.
AMT Capital LLC adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of legalizing illegally gained funds. AML policy means preventing the use of the company’s services by criminals, with the aim of money laundering, terrorist financing or other criminal activity.
To prevent money laundering, AMT Capital LLC neither accepts nor pays cash under any circumstances. The company reserves the right to suspend any client’s operation, which can be regarded as illegal or, may be related to money laundering in the opinion of the staff.
AMT Capital LLC will make sure that it is dealing with a real person or legal entity. AMT Capital LLC also performs all the required measures in accordance with applicable law and regulations, issued by monetary authorities. The AML policy is being fulfilled within AMT Capital LLC FX by the following means:
• know your customer policy and due diligence
• monitoring client’s activity
• record keeping
Know your customer: Because of the company’s commitment to the AML and KYC policies, each client of the company has to finish a verification procedure. Before AMT Capital LLC starts any cooperation with the client, the company ensures that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any customer or counterparty are taken. The company as well applies heightened scrutiny to clients, who are residents of other countries, identified by credible sources as countries, having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who resides in and whose funds are sourced from named countries.
During the process of registration, each client provides personal information, specifically: full name; date of birth; country of origin; and complete residential address. The following documents are required in order to verify the personal information: A client sends the following documents (in case the documents are written in non-Latin characters: to avoid any delays in the verification process, it is necessary to provide a notarized translation of the document in English) because of the requirements of KYC and to confirm the indicated information:
• Current valid passport (showing the first page of the local or international passport, where the photo and the signature are clearly visible); or
• Driving license which bears a photograph; or
• National identity card (showing both front and back pages);
• Documents proving current permanent address (such as utility bills, bank statements, etc.) containing the client’s full name and place of residence. These documents should not be older than 3 months from the date of filing.
In case the applicant company is listed on a recognized or approved stock exchange or when there is independent evidence to show that the applicant is a wholly owned subsidiary or a subsidiary under the control of such a company, no further steps to verify identity will normally be required. In case the company is unquoted and none of the principal directors or shareholders already has an account with AMT Capital LLC, the following documentations must be provided:
• Certificate of Incorporation or any national equivalent;
• Memorandum and Articles of Association and statutory statement or any national equivalent;
• Certificate of good standing or other proof of registered address of the company;
• Resolution of the board of directors to open an account and confer authority on those who will operate it;
• Copies of powers of attorney or other authorities given by the directors in relation to the company;
• Proof of identity of directors in case he/she will deal with AMT Capital LLC on behalf of the Customer (according to the Individual identity verification rules described above);
• Proof of identity of the beneficial owner(s) and/or the person(s) on whose instructions the signatories on the account are empowered to act (according to the Individual identity verification rules described above).
Monitoring of client activity
In addition to gathering information from the clients, AMT Capital LLC continues to monitor the activity of every client to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with the client’s legitimate business or the usual client’s transaction history known from client activity monitoring. AMT Capital LLC has implemented the system of monitoring the named transactions (both automatic and, if needed, manual) to prevent using the company’s services by criminals.
Records must be kept of all transaction data and data obtained for the purpose of identification, as well as of all documents related to money laundering topics (e.g. files on suspicious activity reports, documentation of AML account monitoring, etc.). Those records are kept for a minimum of 7 years after the account is closed.
In cases of an attempt to execute transactions which AMT Capital LLC suspects that are related to money laundering or other criminal activity, it will proceed in accordance with the applicable law and report suspicious activity to regulating authority.
AMT Capital LLC reserves the right to suspend any client’s operation, which can be regarded as illegal or may be related to money laundering in the opinion of the staff. AMT Capital LLC has complete discretion to temporarily block the suspicious client account or terminate an existing client relationship. For more information you can contact us at firstname.lastname@example.org
Foreign exchange trading carries a high degree of risk. In particular, because of the low margins required for currency trading, changes in foreign exchange market can lead to considerable losses. The customer may lose all initial funds and any additional funds deposited to enhance or control the position in the market.