Privacy Policy

Online Privacy Policy

Black Tower Investments Ltd. and it's subsidiary company Urban Forex (the “Company”) respects the privacy concerns of the Users of its website, www.urbanforex.com and the services provided therein (the “Site”) and the Users of any of it's affiliated applications. The Company thus provides this privacy statement to explain what information is gathered during a visit to the Site or use of any of the affiliated applications and how such information may be used.

Please also review the Terms of Use at https://www.urbanforex.com/pages/terms which also govern use of this Site.

Use of Information: As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Site. However, certain non-personal information is recorded by the standard operation of the Company’s internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.

The Site’s various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give us contact information such as your name, mailing and/or e-mail address, demographic information such as your age and gender, and personal preference information such as your preferred software and interests. Information submitted at the time of submission will be used by the Company only as necessary for our legitimate business interests, including without limitation the improvement of our products, services and the contents of the Site. The Company may also share such information with our business and promotional partners to further those interests. Personally identifiable information is never sold or leased to any third parties. With your permission, we may use your contact information to send you information about our company and products. You may always opt-out of receiving future mailings as provided below. The Company does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.

Unless specified otherwise, all Data requested by The Company or Application owned by The Company, is mandatory and failure to provide this Data may make it impossible to provide services requested by user. In cases where The Company or Application owned by The Company, specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact The Company at [email protected]

The Company may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other users of the Site, or anyone else that could be harmed by such activities.

Children Age 13 and Under: The Company recognizes the special obligation to protect personally identifiable information obtained from children age 13 and under. AS SUCH, IF YOU ARE 13 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY. If the Company discovers that a child age 13 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.

The Company nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:

  1. Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
  2. Know the sites your kids are visiting and which sites are appropriate.
  3. Look for Website privacy policies. Know how your child’s information is treated.
  4. Check out the FTC’s site for more tips on protecting children's privacy online

Use of Cookies: Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using our Site easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Site, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the Site may not function properly or may be considerably slower.

Company uses the following cookies on the Site:

Cookie Name Purpose
_kjb_session Kajabi session cookie Tracks your active admin session so you don't need to re-login
kjba Kajabi affiliate token Tracks which affiliate has referred an offer purchase
_abv Admin bar hidden Tracks whether the user wishes their admin previewing bar to be hidden

Any use of Cookies – or of other tracking tools – by The Company or by the owners of third-party services used by The Company for any application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in this Cookie Policy.

Malware/Spyware/Viruses: Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.

Links to External Sites: The Company is not responsible for the content or practices of third party websites that may be linked to the Site. The Company is also not responsible for any information that you might share with such linked websites. You should refer to each website’s respective privacy policy and practices prior to disclosing any information.

Bulletin Boards and Chat Areas: Guests of the Site are solely responsible for the content of messages they post on the Company’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features. Choice/Opt-Out: The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Company which you no longer wish to receive. If you are unsuccessful in completing the instructions specified in any such communication, please e-mail us at [email protected], including a copy of the undesired email attached to the request, and state you wish to be removed from the mailing list.

Contact Information for Complaints or Concerns: If you have any complaints or concerns about the Company or about this privacy statement, please contact:

Via email: [email protected]

or

Via regular mail: Black Tower Investments Ltd. 82/F Int'l Commerce Centre, 1 Austin Road West, Hong Kong

Information provided by you via general e-mail inquiries to the Company such as your e-mail address is used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.

Security: Security for all personally identifiable information is extremely important to us. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, The Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to the Company, you accept that you do so at your own risk.

Place: The Data is processed at The Company's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the The Company to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with The Company at [email protected].

Retention Time: Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
Personal Data collected for purposes related to the performance of a contract between The Company and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of The Company’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by The Company within the relevant sections of this document or by contacting The Company.
The Company may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, The Company may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users: Users may exercise certain rights regarding their Data processed by The Company. In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

Access their Data. Users have the right to learn if Data is being processed by The Company, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, The Company will not process their Data for any purpose other than storing it.

Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from The Company.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing: Where Personal Data is processed for a public interest, in the exercise of an official authority vested in The Company or for the purposes of the legitimate interests pursued by The Company, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether The Company is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights: Any requests to exercise User rights can be directed to The Company through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by The Company as early as possible and always within one month.

Additional information about Data collection and processing Legal action: The User's Personal Data may be used for legal purposes by The Company in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that The Company may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data: In addition to the information contained in this privacy policy, The Company and it's affiliated applications may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance: For operation and maintenance purposes, The Company, it's affiliated applications and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy: More details concerning the collection or processing of Personal Data may be requested from The Company at any time. Please see the contact information in this document.

How “Do Not Track” requests are handled: This Application does not support “Do Not Track” requests.

Your Acceptance of These Terms: By using the Site, you accept the policies and restrictions set forth in this Online Privacy Policy. If you do not agree to this policy, please do not use the Site. This Online Privacy Policy may be revised from time to time by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Online Privacy Policy to which you are bound. 
Should the changes affect processing activities performed on the basis of the User’s consent, The Company shall collect new consent from the User, where required.

Last Updated: May 21, 2018

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