Privacy Policy

  • Privacy Policy


    As GreenTrader, owned by Royal Group Company, we prioritize protecting your privacy and respecting your rights when interacting with our services. This Privacy and Data Usage Policy explains the terms and conditions that govern our commitment to your privacy.


    Safeguarding your personal information and protecting the rights of our valued service users are our priorities. This Privacy Policy outlines the categories of personal data we collect, the methods of collection, how we use and safeguard your data, how we process your personal information, and why we process this data. This policy aims to inform you by providing insights into our data practices and your rights concerning this data.


    We reserve the right to regularly modify our privacy policy, and it is crucial for you to be informed about these updates. We consider any changes made to this policy significant, and we have a responsibility to inform all of our service users, especially our respected investors, about such revisions. The processing of personal data of individuals associated with GreenTrader, such as employees or third-party service providers, takes place within the framework of our business principles and policies and existing contractual relationships.


    The terms "we," "us," "company," or "GreenTrader" in the aforementioned privacy agreement refer to companies, including Royal Group Company. Royal Group Company is a subsidiary located at PEKA DAPCEVICA BT. 50 PODGORICA.


    Similarly, the terms "you," "your," or "yourself" in this privacy policy refer to potential investors and individuals whose personal data is processed.


    Whenever you need assistance or clarification, do not hesitate to reach out to us through any of our communication channels. By using our website or services, you acknowledge that you understand and accept the terms of this statement, and you acknowledge that you are aware of how your personal data shared with us is processed and protected before becoming a customer.


    This policy aims to indicate that when you create an account at GreenTrader, use your account, including updates, during collaboration, and after the termination of your customer relationship, you understand how your data is managed, processed, shared, and stored.


    About Us


    This privacy policy covers the data processing activities of organizations belonging to the Royal Group Company consortium, including the GreenTrader subsidiary. The organization responsible for supervising data processing activities is located at PEKA DAPCEVICA BT. 50 PODGORICA.



    - Collection and Storage of Personal Data


    Within our operational framework, we collect feedback from current and potential customers. The personal data we collect may include:


    - Names, surnames, and contact information

    - Date of birth and gender information

    - Financial assets and liabilities, account balances, transaction details, tax information, and financial statements

    - Earnings and wealth information, employment details, and occupation

    - Position information

    - Trading experience data, risk tolerance, and risk profile

    - IP addresses, device characteristics, and information related to trading history

    - Details related to bank accounts, e-wallets, and credit cards

    - Activities conducted on the GreenTrader platform or applications, traffic data, location information, web logs, and additional contact information



    We use cookies to collect and store information related to your interactions with the GreenTrader platform. These small text files are stored on your device's hard drive when you access our website. When you access the GreenTrader platform, these cookies help reload necessary data to our web server and enhance your experience by accommodating your personal preferences.


    We record your transaction activities in the following manner:


    - Products traded on GreenTrader

    - Historical data of your investments

    - Preferences for specific products or services

    - For corporate investors, additional personal information such as company addresses, shareholders, executives, officials, and other information required to comply with legal and regulatory requirements

    - We may obtain this data from market research, surveys, special offers, third-party marketing lists, general sources, social media platforms, affiliates, brokers, intelligence databases, and other third parties.


    It's important to note that you have the option to refrain from providing certain information, but such an option carries the risk of not being able to provide the requested product or service.


    Recipients of Personal Data


    As part of our services, we may share information with the following:


    - Companies within Royal Group Company, including GreenTrader, as well as third-party application providers, communication systems, and e-commerce platforms used by Royal Group Company

    - Service providers that provide administrative, IT, analysis, online marketing optimization, financial, regulatory, compliance, insurance, research, and other related services

    - Individuals providing promotional services to brokers and organizations with whom we have mutual relationships

    - Payment service providers and banks for your transactions

    - Auditors, consultants, or contractors who perform audits or regulatory compliance checks for our operations

    - Legal organizations that respond to authorized courts, regulatory bodies, government agencies, and regulatory requests and agreements

    - Links to third-party websites may be present on our website or applications that redirect to external websites. These external sites are not covered by this privacy statement or the established procedures. We recommend reviewing the privacy policies of these third-party organizations to better understand their privacy practices.


    Authorization and Consent


    We use your personal information for the purpose of our company. These processes are based on legal grounds such as fulfilling contractual responsibilities to investors, complying with legal and regulatory requirements, and protecting our legitimate interests. When using investors' personal information, we ensure that their consent aligns with the ways specified in this privacy policy. GreenTrader has the right to withdraw this consent at any time by contacting the company through the provided contact information.


    Management of Personal Data


    As Royal Group Company, we are committed to protecting the transmission, storage, or other processing of personal information. We implement and maintain technical and organizational measures to protect against accidental loss, alteration, unauthorized access, disclosure, and destruction of the personal data given to us. These measures aim to maintain the necessary level of security for your data.


    This privacy statement and the relevant laws appoint a "Data Protection Officer" to ensure the management of personal information. This individual ensures compliance with privacy standards. Externally, this information is considered confidential, and individuals who receive or process personal information commit to respecting individuals' privacy rights and complying with current data protection laws.


    The data protection measures we implement include:


    - Personnel accessing personal information are trained in security measures and adhere to security protocols such as two-factor authentication and password requirements when accessing our systems.

    - Encryption technologies are used for data transfer in online transactions.

    - Security measures such as firewalls, intrusion detection systems, and virus scanning tools are used to prevent unauthorized access and virus infection.

    - Physical and electronic access control tools such as access cards, surveillance cameras, and security personnel are used to protect against unauthorized access.

    Retention Period of Personal Information


    Personal data is kept together in secure computer storage facilities and paper-based files. When personal data becomes no longer necessary to identify investor identity, we either securely dispose of this data or delete the records. Sometimes records need to be retained for a specific period, such as to comply with regulatory behavior rules, monitor transactions and investments, address complaints, and demonstrate compliance with anti-money laundering laws. We retain these records for the duration of your business relationship and for five years after the end of the business relationship or longer if required by regulators.


    Please note that your personal data may be transferred and stored outside the European Economic Area (EEA). We take all reasonable steps to ensure that your data is processed securely by our personnel or suppliers or affiliates outside the EEA and carry out such transfers in compliance with our Privacy Policy. If you would like a copy of the regulations that govern this transfer, please contact us using the contact information provided below.


    Investor Rights


    Subject to conditions, investors have the following rights:


    - Requesting access to personal data (usually referred to as a "Data Subject Access Request")

    - Requesting correction of personal data

    - Requesting deletion of personal data; however, we retain the right to store data in certain legal or communication-related circumstances

    - Objecting to the processing of personal data, especially when you believe it may affect fundamental rights and freedoms and when it is based on our legitimate interests

    - Requesting restriction of processing of personal data in specific scenarios

    - Requesting the transfer of personal data to you or a third party in a structured, commonly used, machine-readable format in cases of automated processing based on your consent (e.g., for direct marketing purposes)

    - Withdrawing your consent based on automated decision-making

    - Investor Complaints and Requests


    We strive to respond to all requests within one month. If a request is complex or voluminous, the response time may exceed one month. In such cases, we will inform you within one month from the date of receiving the request. If a request is clearly unfounded, excessive, or repetitive, or if further copies of the same data are requested, we may charge a reasonable fee or refuse to comply with the request.


    For any questions, complaints, or requests related to your personal data, please feel free to contact us using the provided contact information.