Privacy Policy

This Privacy Policy (“Privacy Notice”, “Notice”), together with our cookie policy and other relevant legal notices posted on our website at www.ForexVPS24.com, describes how DigitalForex HK Limited and its affiliates (collectively, “ForexVPS24”, “we”, or “us”) collects, stores, uses and discloses personal data (i.e., personal information) from and about you (“Customer”, “you(r),” or “User”) in connection with our Services, as defined in our posted Terms of Use. (together with all our posted policies and disclosures, the “Terms”). As an initial matter, please note as follows:

• This Notice does not apply to personal data in your User Content (as described in our Terms) such as on websites or other online services you host using our Services; in that context we operate solely as a data processor (i.e., service provider) subject to a Data Processing Agreement under our Terms.
• You must accept our binding Terms in order to use our Services, and are strongly encouraged to read them in addition to this privacy policy.

1. How We Collect Information

We may collect information about individuals by various means, including: (1) directly from Users, both online (e.g., the Services) and offline (e.g., phone); (2) through automated means when Users use our Services; and (3) from third party sources, and from social media platforms that individuals may use to engage with us, for the purposes provided below and to supplement information we already possess.

2. Categories of Information We Collect

Some of the information we collect through or in connection with the Services is known as personal data, which generally means information that identifies an individual, and other information we associate with it. We may collect such information about you directly from you, from third parties, or automatically through your use of our Services. These categories are described in more detail below.

(A) Information you provide

In order to access or use certain portions or functionality of the Services, or otherwise in conducting business with us or seeking to conduct business with us, you may be prompted to provide certain personal data to us in the following ways:

• Persons who subscribe to our Services will be prompted to provide their name, physical address, e-mail address, phone number and necessary billing information. Within a registered Account (defined in the Terms), you may also provide additional profile information, user preferences, notification preferences and other such information.
• You may provide personal data when filling in forms (for example, a ‘Contact us’ form), completing voluntary surveys, or otherwise interacting with us through online or offline communications. Persons who sign up for newsletters or other communications regarding our Services will be prompted to provide their e-mail address.
• Prospective and current suppliers and subscribers, at a trade show or anywhere else we conduct business, when downloading documentation from our Services, by corresponding with us by phone, e-mail or otherwise providing contact details, or engaging in any business transaction with us. In these cases, typically, the personal data you provide may include name, business affiliation and job function, business contact information (physical address, phone number, email address), and any other personal details required for legal/compliance purposes or to resolve any inquiries or complaints. This personal data is required to enter into a contract with you (such as in anticipation of a supply agreement, or to learn about our Services) or to perform a contract with you (such as to provide Services), and failure to provide any information may result in our inability to provide requested Services or products.

(B) Information we collect automatically

When you use our Services, our servers and software tools we use will automatically collects certain browser- or device-related information, including but not limited to: your domain, IP address, device identifier, date/time and duration of your visit, browser type, operating system, page visits, information referred to us from third parties, other technical information about your computer or device, and internet traffic activity.

In some cases this information constitutes personal data under US Privacy Laws, although we do not use this information to try to identify you by name, and we do not associate it with the information you provide voluntarily, as detailed below.

Our Services use cookies and similar technology tools as further described below and in our cookie policy at https://www.ForexVPS24.com/cookie-policy/.

You can click on the “Your Privacy Choices” link in our website footer to opt-out of third party targeting cookies. In addition, we endeavor to process “Global Privacy Control” (GPC) signals from web browsers by automatically opting-out such visitors from third party targeting cookies, although GPC technology is not fully developed and it is not yet supported by all browsers.

In general, we and our third party service providers use cookies and other tracking mechanisms, including those designed for mobile applications, to track information about your use of our Services. In some instances we may combine this information with other personal data we collect from you (and our third party service providers may do so on our behalf). Additional information about such technology and how we use it is provided below

• Cookies. Cookies are alphanumeric identifiers transferred to and stored by your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Services, including for online advertising purposes.
• Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can adjust your browser options to block them in the future. Users of our Services who disable cookies will be able to browse certain areas of the Services, but some features may not function correctly.
• Clear GIFs (a/k/a. web beacons, web bugs or pixel tags). Clear GIFs are tiny unobtrusive graphics that appear invisible on web but trigger a browser call to a third party server that enables us to track User activities on the Services, better manage our content, and monitor Services metrics (such as page views and the performance of advertising campaigns directing traffic to certain website pages). We and our third party service providers may also use this technology in HTML emails to track email read and response rates, and track whether such emails are forwarded.
• Third Party Analytics. We use certain third party performance tools such as Google Analytics to evaluate usage of our Services and help us improve our services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. To learn more about Google’s privacy practices, please review the Google Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
• Third-Party Ad Networks We may use third parties to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to individuals regarding products and services they may be interested in. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal data , about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Services or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

(C) Information from other sources

We may also receive information about you from third party sources, such as fraud and risk scoring from businesses like MaxMind and Kount. We may also obtain information from social media platforms that individuals use to engage with us.

3. How we use your information

We may use your personal data as permitted or required by law for the following purposes:

• To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill transactions, provide you with documentation or communications you requested and for other customer service purposes (e.g., sales, technical or billing support, or responding to queries or complaints);
• To tailor the content and information that we may send or display to you, such as displaying information on your use of our cloud services, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services;
• To administer and manage performance of purchase or sales agreements with our suppliers and customers;
• To operate the Services including to evaluate, maintain, monitor performance, troubleshoot, improve and develop the Services (including by monitoring and analyzing trends, access to, and use of the Services to engage in advertising and marketing activities);
• For marketing and promotional purposes, for example, we may use your email address to send you news and newsletters, special offers, promotions, or to otherwise contact you about products or information we think may interest you;
• To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services and respond to user desires and preferences, and for other research and analytical purposes;
• To administer surveys and questionnaires;
• To protect and ensure the quality, security integrity and safety of the Services, our business operations, and our confidential and proprietary technology and information;
• To prevent, detect, investigate, and address actual or suspected fraud, violation of law or our Terms, claims and other liabilities, or any threat of physical or financial harm to u, our staff or any other individuals or entities; and
• As may be otherwise disclosed at the time of collection.

We also use non-personal or de-identified data, such as that collected automatically or aggregated from our data sources, for research and development activities, analytics purposes, or for marketing and other purposes. Such de-identified data is not subject to this Notice.

4. Notice Regarding Use of Our Community Forum and Internal Messaging

Any personal data provided in portions of a user profile, member directory, or other related Services that you set as public is directed to the public and should be deemed generally available to the public. We do not, cannot, and will not act to maintain the privacy of any personal data that you provide publicly in any such forum or medium.

Likewise, any internal messaging or community forum we make available for Users (such as for discussions regarding the Services) should not be considered secure or confidential and any personal data you directly share in such a forum is not considered private information. You must use caution when sending any personal data through such forums, and not transmit anything you do not want disclosed to the general public.

5. How We Disclose Your Information

We may share your information, including personal information, as follows:

• We may share your personal data with service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include providers of IT infrastructure, payment processing, fraud detection, marketing and analytics services, professional services such as accounting or legal counsel, and other companies that work with us to improve or provide our Services). We only provide such data so they can perform their required functions on our behalf, and our agreements generally obligate them to comply with applicable privacy laws, keep the data safe and secure, and not use the data except for purposes provided. If you have an independent relationship with any such third party service provider, their use of your data may be governed by their independent relationship with you, and we are not responsible for such use;
• We may share your data among our legal affiliates so they can support aspects of our Services or engage more broadly with those who may be interested in other products or services;
• To comply with any laws, regulations or valid governmental or legal demands for such data, including in response to any criminal, civil, or administrative process, discovery request, subpoena, court order, writ, or other demand by authorities, private-party litigants, or other persons or entities that we believe to have the legal authority to obtain such data;
• As necessary to identify, contact, report or bring legal action in regard to violation of our Terms or other user policies such as out Acceptable Use Policy;
• To protect ourselves, our business partners and customers, or the general public. For example, we may, where appropriate or required, disclose personal data to law enforcement in the event that a suspected or confirmed crime;
• In connection with the potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal data held by us about our users may be one of the transferred assets; and
• To the extent permitted by law and as described herein, we may share limited identifying information with advertising and analytics partners, subject to any required consents and respecting any required opt-in or opt-out rights provided by applicable laws.

Where appropriate, we will limit sharing of your personal data in accordance with the choices you have provided us and applicable law.

6. Marketing Communications

Where lawful to do so, and subject to your consent where required, we may communicate with you by e-mail, including to inform you about our products and services. If you wish to opt-out of receiving marketing communications, please use the ‘unsubscribe’ link provided in our emails. If you are a subscriber to our Services, we may send you periodic announcements including the details of our existing and new programs. You may opt out of these announcements by filling out the form at https://www.ForexVPS24.com/unsubscribe/ or by clicking the opt-out link at the bottom of such emails. If you opt out of marketing emails, you may still receive administrative or system emails and other notices specifically related to your Account.

7. How to Access or Modify Your Information.

We offer our Registered Users the ability to access or modify a lot of personal by logging into your Account and going to your profile page. If you need further assistance for such changes, please contact our Customer Service Department as directed at https://my.forexvps24.com/contact.php.

If you reside in certain states or international jurisdictions, you may be entitled to exercise additional rights with respect to your personal data. Please see the next two sections for more information.

8. State-Specific Privacy Rights

(A) State specific Privacy Policies are outlined in the US Privacy Policy

This Section is provided specifically for California, Virginia, Connecticut, Colorado, Delaware, Utah, Iowa, Indiana, Tennessee, Oregon, Montana, and Texas. In addition to the disclosures provided in this Policy, (if you are a resident after January 1, 2024) you can exercise certain additional rights regarding your Personal data:

• You may request a copy of the following: (1) the categories of personal data we collected about you; (2) the categories of sources from which the personal data is collected; (3) the business or commercial purpose for collecting or selling (if applicable) the personal data; (4) the categories of third parties with whom we shared personal data, and the categories of personal data shared; and (5) the specific pieces of your personal data that we have collected, used, disclosed, or sold.
• You may request that we (and our service providers) correct your personal data if it is inaccurate or delete your personal data. Note that deletion requests are subject to certain limitations, for example, we may retain personal data as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for certain other internal business purposes described in this Notice.

If you have an Account with us, you may access and change certain personal data (such as profile and transaction information) directly through your Account after logging in to the Services. Otherwise, to request a copy of personal data we have collected about you, to request a correction of your information, or to request that the your information be deleted, please contact us as provided at https://www.ForexVPS24.com/contact/. You may authorize another person (your “agent”) to submit a request on your behalf the same way. Shortly after you (or your agent) submit a request, we will check our records for matching information and contact you (via email at the email address provided during submission of your request) with instructions on how to verify the request before we fulfill it. We will aim to complete your requests as soon as reasonably practicable and consistent with any applicable laws. Note that you can access and update Account information, or opt out of email marketing, as provided above.

You also have the right at any time to opt out of (i) selling or sharing of your personal data to third parties, and (ii) targeted advertising through third parties. We do not transfer your personal data to third parties in exchange for money but information may be shared with certain third party advertising partners for our targeted advertising purposes, specifically, limited identifying information may be shared with such partners through targeting cookies or other means.

• You can click on the “Your Privacy Choices” link in our website footer to opt-out of third party targeting cookies. As noted above, we also endeavor to process GPC signals from web browsers by automatically opting-out such visitors from third party targeting cookies, although GPC technology is not fully developed and it is not yet supported by all browsers.
• Other than with respect to such targeting cookies, you can contact us at https://www.ForexVPS24.com/contact/ as provided above to exercise your opt-out rights.

Privacy laws may provide you with other opt-out rights which are inapplicable to us. In particular, we do not engage in impactful profiling activities with respect to Users, and we do not collect, use or disclose sensitive personal data (such as government identification number, precise geolocation, financial account credentials, etc.) except for the specific purpose(s) that you provide it.

We may not, and will not, discriminate against any individual for exercising their privacy rights, including those provided by the applicable privacy laws. Please note that we may otherwise continue to share your personal data with our affiliates and service providers, and as otherwise directed by you, for the purposes described in this Notice.

If we deny a privacy request, you may appeal the decision to us at the contact information provided below. To the extent possible, please describe the basis for your appeal and if there is any specific personal data that concern you. We will endeavor to provide a prompt response. If we deny your appeal, you can raise concerns with your state’s Office of the Attorney General.

(B) Residents of California Only

This Section is provided specifically for California residents.

• Financial Incentives. We do not generally provide a loyalty program or other financial incentive in return for the collection or use of personal data. On some occasions we may engage in a limited-time marketing event, promotional offer or discount on fees that includes a registration or other collection of personal data, and we will disclose the benefits and terms of that promotion at the time of collection.
• Privacy rights requests for non-customers.
  • California privacy rights apply to all individuals (not just website visitors or Registered Users), including job applicants, current and former employees, contractors and business partners. Job applicants may provide contact information and resume-related information (e.g., past education and experience) as well as complete relevant background checks. Employees receive internal privacy disclosure relevant to them. Contractors and business partners provide business contact information and payment- related information as necessary to facilitate a prospective or actual business relation. Due to the nature of these relationships, the precise collection and use of personal data can vary.
  • All such individuals who are California residents can request additional information about our privacy practices with respect to their information, as well as make the access, deletion, correction and opt-out requests described above, by contacting us at legal@ForexVPS24.com. Please provide sufficient information that we can identify you, and be aware that we may employ a more extensive authentication process to verify your identity before responding to your request.
• Do Not Track. Do Not Track (DNT) is a privacy preference you can set in most browsers but there is no standard interpretation or practice for responding to DNT signals (see https://allaboutdnt.com/ for more information), and we therefore handle all user information consistent with this Notice. We do endeavor to support browser GPC signals as discussed above.
• Direct Marketing. We do not share personal data such as your contact information with third parties for their own direct marketing purposes.
• California Minors. As stated above, our Services are intended for a general audience and not directed toward children or those who cannot enter into binding Terms with us. In the event a California resident under the age of 18 has posted information to a public-facing forum we offer, the individual may contact us as directed below to request that we remove or anonymize such content to the extent required by California law.

(C) Nevada residents

Please note that we do not sell personal data as defined by Nevada law (Nevada Revised Statutes, Chapter 603A, Section 1.6), but you can submit a request to us as directed below regarding the sale of such information.

9. International Notices

This section is specifically intended for individuals residing outside of the United States (“US”). This includes residents of the European Economic Area (“EEA”) including the European Union (“EU”), the United Kingdom (“UK”), Switzerland and other relevant jurisdictions with respect to privacy and data protection laws applicable to us.

(A) Legitimate Bases for Processing

Where required by law, all processing of personal data is justified by a legally-recognized basis for processing. In the majority of cases, processing will be justified on one or more of the following bases for processing:

• The processing is necessary to perform a contract with you (such as if you subscribe to our Services) or take steps to enter into a contract at your request (such as to fulfill an order), or to provide product information you have requested;
• The processing is necessary for us to comply with a relevant legal obligation, such as keeping accounting records;
• The processing is in our legitimate interests, which are not overridden by your interests and fundamental rights. Our legitimate interests are to use subscriber, website user, supplier and customer data to reasonably and responsibly conduct and develop our business activities without abusing any privacy interests or rights of such individuals; and
• In some instances, we rely on your consent to our processing (at times as a secondary basis for processing in an abundance of caution).

(B) Transfer of Personal Data

If you are in the EEA/EU, the UK, Switzerland or another jurisdiction that has imposed specific legal requirements regarding the lawful transfer of personal data from that jurisdiction to another country (e.g., the US), to the extent that we engage in such a transfer of your personal data (a “Cross-Border Transfer”) we will take steps to ensure that such Cross-Border Transfer satisfies applicable legal requirements. In particular:

• If we transfer personal data to a jurisdiction deemed by relevant regulatory authorities to provide adequate protection for personal data, we will rely on such adequacy decision, as applicable; and
• If we transfer personal data to a jurisdiction that is not recognized under such an adequacy decision, we will take steps to conduct the Cross-Border Transfer using other legally-valid mechanisms, such as by entering into data transfer agreements with standard contractual clauses (“SCCs”) among our affiliates and with relevant service providers, in any necessary supplementary safeguards. We currently rely on SCCs for Cross-Border Transfers to the US, and are monitoring evolving laws and regulatory developments to assess if and when alternative or supplemental measures are available or necessary.

For more information about the mechanism under which your personal data may be subject to Cross-Border Transfers, please contact us at legal@ForexVPS24.com.

(C) Exercising Your Privacy Rights

Residents of certain jurisdictions are entitled to exercise certain rights under privacy laws applicable to their personal data. The rights described below are, for example, applicable to residents of the EEA/EU, Switzerland, UK, Brazil and other jurisdictions with laws similar to GDPR.

• Right to withdraw consent – to the extent we rely on consent for the collection, use or disclosure of your personal data, you have the right to withdraw your consent at any time. For example, if you wish to opt-out of receiving electronic marketing communications, you can change available settings in your Account, use the ‘unsubscribe’ link in our emails, or contact us directly.
• Right of access, rectification, and erasure – you have the right to request access to and obtain a copy of your personal data that we maintain, to request correction of any inaccurate data about you, or request the deletion of your personal data. We will fulfill these rights consistent with legal requirements and guidance as to our obligations. Note that in many respects you can access and correct much of your personal data directly by logging into your Account.
• Data portability – o the extent we rely (as the legal basis for processing) upon your consent, or our processing is necessary to perform a prospective or actual contract with you , and personal data is processed by automatic means, you have the right to receive the personal data which we received in a structured, commonly-used and machine-readable format, that can be transmitted to another party where technically feasible.
• Right to restriction of processing – you have the right to restrict our processing of your personal data where:
  • you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;
  • where the processing is unlawful but you do not want us to erase the personal data;
  • where we no longer need your personal data for the purposes of processing, but you require such personal data for the establishment, exercise or defense of legal claims; or
  • where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
  • Where your personal data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.
• Lodge a complaint – You also have the right to lodge a complaint with the supervisory authority where you reside, work or where alleged infringement occurred, if you consider that the processing of your personal data infringes applicable law.
• Right to object to processing (including profiling) based on legitimate interest grounds – where we are relying upon legitimate interests to process personal data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider requests in this regard on an individual basis.
• Right to object to direct marketing (including profiling) – you have the right to object to our use of your personal data (including profiling) for direct marketing purposes, such as when we use your personal data to invite you to our promotional events

Please contact us as provided at https://www.ForexVPS24.com/contact/ if you wish to exercise any of your rights, or if you have any inquiries or complaints regarding the processing of your personal data.

10. Security Measures

We maintain commercially-reasonable security measures designed to protect the transmission and storage of personal data, and ensure the integrity and security of our network and systems . This can include technical measures like encryption and firewalls, and organizational measures like security policies and procedures. Nevertheless, we cannot guarantee that our security measures will prove effective in all instances, such as due to sophisticated cyber-attacks. We will make any legally required disclosures in the event of any compromise of your personal data, and to the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

11. Retention of Personal Data

We apply a general rule of keeping personal data only for as long as required to fulfill the purposes for which it was collected including (i) to provide you with our products and services, such as to maintain Account records while active and after termination for the purposes described above, and (ii) as reasonably as necessary for legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

With respect to marketing (absent other bases for collection or use), we endeavor to only retain personal data for 18 months after your last request for service or we engage in some other form of contact.

12. External Sites

This Notice applies solely to personal data collected by our Services or in the course of our business activities. The Services may contain links to third party websites or services (including social media platforms). ForexVPS24 does not control nor is responsible for the privacy practices of those third parties and we encourage you to review the privacy policies of these third parties before using their websites or services.

You may see us promoted by other businesses on various websites, web pages, social media and other platforms. Please note that we do not always have complete information about where our brand may be displayed or promoted, and if you believe that we are featured in venues that are inappropriate or offensive, please contact us.

13. Children

The Services are not intended for use by children under the age of 16 or anyone not of legal age to enter into the binding Terms with us, and ForexVPS24 does not knowingly collect, store, share or use the personal data of children under 16 years as a controller. If you are under the age of 16, you may not use the Services or provide any personal data to us. If anyone reports to us that we received personal data concerning any children under the age of 16 we will endeavor to promptly delete all such personal data.

14. Job applicants and other non-Users

Job applicants provide us with personal data as part of an employment application and review process that includes information like the applicant’s name, email, address and the contents of a resume and cover letter. We generally use this information to evaluate the individual for employment with us. Job applicants may provide additional information such as for routine background checks performed by a third party provider of such services. Other individuals we interact with may likewise provide us with contact information or other personal data in connection with our perspective, current or former relationship. We may provide more detailed privacy disclosures and request specific consent to use personal data from any such individuals at the time of collection, and you may exercise privacy rights afforded to you under applicable laws, such as the rights described above.

15. Changes to this Notice

We reserve the right to revise, amend, or modify this Notice and our other policies and agreements at any time and in any manner, subject to applicable laws. You should periodically check for any modifications of this Notice by visiting this webpage and using the ‘refresh’ button on your browser

When visiting this page, note the ‘last modified’ data on this Notice. If the ‘last modified’ date remains unchanged, you may presume that no substantive changes have been made since the last reading of the Notice. A changed ‘last modified’ date indicates that this Notice has been updated or edited, and the modified version supersedes any prior versions.

16. Contact Information

If you have any questions in relation to this Notice or you wish to exercise any of your rights, please contact us as directed at https://my.forexvps24.com/contact.php.