Complaints

If you as a client or a prospective client of UniFin ApS (UNIFIN) have raised a question or an issue with UNIFIN for instance with your account manager or another employee of UNIFIN without receiving a satisfactory answer you may file a complaint with UNIFIN.

Please contact us in writing by using the following address:

Attn: Complaints UniFin ApS

Ny Carlsberg Vej 82, 1799 København, Denmark

Or send information via e-mail to: [email protected]

Compliance & AML Statement

The UniFin ApS (UNIFIN) is committed to adhering to the highest standards of compliance with rules, regulations and ethical standards.

UniFin ApS is licensed by the Danish Financial Supervisory Authority and as such is subject to both Danish and EU regulations governing financial institutions. Furthermore, all branches and subsidiaries conducting financial services are properly registered and authorized by local authorities.

The group compliance functions operate under a Group Compliance and AML Charter and Policy, which sets out the vision and mission of the compliance functions and furthermore describes the reporting structure and obligations.

All questions regarding compliance should be directed to: [email protected]

Statement regarding Anti-Money Laundering, Counter Terrorist Financing and Know-Your-Customer measures within UniFin ApS (UNIFIN).

Anti-Money Laundering (AML), Counter Terrorist Financing (CTF) and Know-Your-Customer (KYC) measures are focus areas within UNIFIN Group. Below you will find a summary of our policy in regard to these areas.

The Board of Directors has adopted a Policy and Charter on prevention of money laundering and terrorist financing. It requires UNIFIN’s head office, branches and subsidiaries worldwide to have effective programs in place to comply with applicable laws, regulations and ethical standards.

The Head of Group Compliance & AML, together with a dedicated team, oversees these policies, practices and procedures. Furthermore, AML Officers within the different business units are obliged to report to the Group Anti-Money Laundering Officer as well as to national Financial Intelligence Units (FIU).

We have implemented procedures and routines regarding Know-Your-Customer and Customer Due Diligence, e.g. identifying customers and beneficial owners and verifying their identity on the basis of documents, data or information obtained from reliable and independent sources. Furthermore, UNIFIN pays special attention to: understanding the ownership and control structure of our customers; jbtaining information on the purpose and intended nature of the business relationship, and monitoring the business relationship.

We have established processes enabling us to identify persons and legal entities identified by government agencies to be involved in terrorist financing, money laundering, etc. (e.g. EU’s, HMT’s and OFAC’s sanction lists).

We have established processes enabling us to identify persons who qualify to be a PEP or related to a PEP.

We have developed procedures that assist in the monitoring of transactions for the purpose of identifying possible suspicious activity.

We have established employee training programs to educate and assist employees in the ways of preventing that UNIFIN is used to execute transactions related to money laundering and terrorist financing.

UNIFIN does not allow anonymous accounts.
We co-operate with law enforcement and regulatory agencies in accordance with national regulation.

Disclaimer

This website can be accessed worldwide however the information on the website is related to UniFin ApS (UNIFIN) and is not specific to any entity of UNIFIN Group. All clients will directly engage with UNIFIN and all client agreements will be entered into with UNIFIN and thus governed by Danish Law.

Any fact, assessment, analysis, forecasts, opinion and other information (collectively “Information”) released by:

UniFin ApS
any owner, subsidiary, affiliates or branch office of UniFin ApS, and
any director, officer, employee or representative here (collectively the “UNIFIN Group”) whether provided on the UNIFIN Group’s websites, on third party websites, in marketing materials, newsletters, in individual e-mails and letters, in lectures, individual conversations or in any other form of written or verbal communication (collectively “Publications”) are provided for informational and/or marketing purposes only.

Unless specifically stated, no Publication of the UNIFIN Group should be construed as an offer (or solicitation of an offer) to:

buy or sell any currency, product or financial instrument,
make any investment, or
participate in any particular trading strategy (collectively “Offers”) Notwithstanding anything to the contrary (not even if specifically stated), no Publication of the UNIFIN Group should be construed as an Offer in any jurisdiction in which such Offer would be illegal. Any such perceived Offer will not be honored by the UNIFIN Group.

No Representation, No Warranty

The UNIFIN Group uses reasonable efforts to obtain information from reliable sources, but all Publications are provided on an «as is» basis without representation or warranty of any kind (neither express nor implied) and the UNIFIN Group disclaims liability for any Publication not being complete, accurate, suitable and relevant for the recipient.

The Publications of the UNIFIN Group are not updated after their release and may due to changing circumstances become inaccurate and possibly misleading after a period of time which may vary from seconds and minutes to days, weeks and months depending on the Information. The UNIFIN Group gives no guarantee against, and assumes no liability towards any recipient for, a Publication being outdated.

If a Publication becomes outdated the UNIFIN Group shall be under no obligation to: - update the Publication,

inform the recipients of a Publication, or
perform any other action.

Any Publication may be personal to the author and may not reflect the opinion of the UNIFIN Group. The UNIFIN Group reserves the right at its sole discretion to withdraw or amend any Publication or Information provided at any time without notice (prior or subsequent).

No recommendations

The UNIFIN Group does not in any of its Publications take into account any particular recipient’s investment objectives, special investment goals, financial situation, and specific needs and demands. Therefore, all Publications of the UNIFIN Group are, unless otherwise specifically stated, intended for informational and/or marketing purposes only and should not be construed as:

business, financial, investment, hedging, legal, regulatory, tax or accounting advice,
a recommendation or trading idea, or
any other type of encouragement to act, invest or divest in a particular manner (collectively “Recommendations”)

The UNIFIN Group shall not be responsible for any loss arising from any investment based on a perceived Recommendation.

Notwithstanding anything to the contrary (not even if specifically stated), no Publication (including possible Recommendations) shall be construed as a representation or warranty (neither express nor implied) that the recipient will profit from trading in accordance with a trading strategy set forth in a Publication or that the recipient will not sustain losses from trading in accordance with a trading strategy set forth in a Publication.

The UNIFIN Group shall only be liable (in accordance with the “Limitation of Liability” section below) if a possible Recommendation is not of a good professional standard.

Risk Warning

Trading in the products and services of the UNIFIN Group may, even if made in accordance with a Recommendation, result in losses as well as profits.

Speculative trading is not suitable for all investors

Any mentioning, if any, in a Publication of the risks pertaining to a particular product or service may not and should neither be construed as a comprehensive disclosure nor full description of all risks pertaining to such product or service and the UNIFIN Group strongly encourages any recipient considering trading in its products and services to employ and continuously consult suitable financial advisors prior to the conclusion of any investment or transaction.

Local regulatory restrictions

The UNIFIN Group’s Publications may be accessed worldwide. The Information provided in such Publications is however only intended for use by recipients located in countries where such use does not constitute a violation of applicable legislation or regulations. None of the products and services referred to in the Publications of the UNIFIN Group are available to recipients residing in countries where the provision of such products and services would constitute a violation of mandatory applicable legislation or regulations.

It is the sole responsibility of any recipient employing or requesting a product or service of the UNIFIN Group to comply with all applicable legislation or regulation.

Use of the website

Any use of the UNIFIN Group’s websites is subject to UNIFIN Group’s “Terms of Use”, as amended from time to time, and the “Copyright” provisions, as amended from time to time, both of which shall be construed as constituting an integrated part of this disclaimer.

The UNIFIN Group shall not be liable for any damage or injury arising out of any person’s or entity’s access to, or inability to access, any website of the UNIFIN Group. This limitation includes, but is not limited to, any damage to computer equipment and computer systems caused by virus, malware and any other harmful computer coding.

Consulting a website of the UNIFIN Group does not constitute a customer relationship and the UNIFIN Group shall not have any duty or incur any liability or responsibility towards any person or entity as a result of such person or entity consulting a website of the UNIFIN Group.

Any market data displayed on this Trading Platform may only be used for your own internal business purposes and only in connection with this specific service. Distribution of any market data to anyone else is prohibited.

Translation discrepancies

The UNIFIN Group offers its Publications in a wide range of languages for the recipient’s comfort of use. In case of discrepancy between the original English text and any translation, the original English text shall prevail.

All recipients are advised to carefully examine the original English text before acting upon a translation thereof. Any user who does not fully understand the original English text is strongly encouraged to contact the UNIFIN Group by e-mail at [email protected].

The UNIFIN Group shall not be bound by, or liable to any recipient for, an incomplete or inaccurate translation of an original English text to another language.

Client relationship

When applying for an account with any entity within the UNIFIN Group, each applicant will be subject to the relevant set of business terms. All applicants and clients are deemed to have read and understood the business terms and related policies applicable to them and their relationship with the relevant entity of the UNIFIN Group.

Consulting a website or receiving a Publication of the UNIFIN Group does not constitute a customer relationship and the UNIFIN Group shall not have any duty or incur any liability or responsibility towards any person or entity as a result thereof.

Third party services

Persons or entities not belonging to the UNIFIN Group may advertise on the UNIFIN Group’s websites, through links, banners or otherwise. The UNIFIN Group shall not be held responsible or liable for the offerings, information or acts of any such third party. If a user of the UNIFIN Group’s websites decides to act upon any such advertising, such user does so entirely at its own risk.

Limitation of Liability

If the UNIFIN Group at any time and for any reason, should become liable for the loss of any person and/or entity, including without limitation, if any provision of this disclaimer is, or at any time becomes to any extent or in any circumstances invalid, illegal or unenforceable for any reason, the liability of the UNIFIN Group shall be limited to such person’s and/or entity’s duly documented direct loss, which for the avoidance of doubt, and without limitation, shall not include damages for any incidental and consequential losses, damages for lost opportunity, damages for lost profit, statutory damages, nominal damages, punitive damages, restitutionary or disgorgement damages, damages for costs, including legal costs, and damages for any other indirect loss.

Conflict of interest

In order to prevent conflicts of interest, the UNIFIN Group has established appropriate business procedures, including procedures applicable to research and analysis to ensure objective research reports. The UNIFIN Group’s research reports are never disclosed to nor discussed with any of the subject of the analysis, e.g. issuers of securities or others.

The UNIFIN Group may hold, take, transfer or alienate positions in securities, foreign exchange or other financial instruments covered by a research reports.

The UNIFIN Group may act as market maker in all products and services not traded on an exchange (i.e. OTC products such as foreign exchange and CFDs) and may therefore be the counterparty in any trade conducted by customers in these products.

The UNIFIN Group does not engage in corporate finance activities. Accordingly, none of the UNIFIN Group’s directors, officers, employees or representatives, namely people in charge of analysis reports, receives remuneration in connection with the release of any analysis.

Privacy and Use of Personal Data

When signing up for a demo or live account with any entity of the UNIFIN Group, this entity will, for administrative, commercial and/or legal purposes, require and store information about the user, including, but not limited to, name and address. Furthermore, the UNIFIN Group may require some financial information for credit assessment purposes, as well as users’ e-mail address to be able to mail the login information. Users’ e-mail addresses will not be passed on to third parties, but may be used by any entity of the UNIFIN Group for the promotion of its products and services.

The UNIFIN Group is obliged by law to treat personal data as confidential and may not pass on or use any personal data without valid legal grounds.

All personal data benefits from this full protection and will only be disclosed to third parties such as administrative or judicial authorities if the UNIFIN Group is compelled to do so pursuant to the applicable law, or if the registered has given its written consent to such disclosure. The registered may revoke such consent or modify its extent at any time.

Without prejudice to the above, the UNIFIN Group can disclose the following information:

General customer data, such as name, address and personal registration number, to companies carrying out administrative tasks for the UNIFIN Group.
General customer data about corporate customers to financial institutions subject to professional secrecy, for the purpose of marketing and advisory services.
In accordance with the provisions of the Danish Act on Processing of Personal Data, any UNIFIN Group customer has a right to be informed about the data that the UNIFIN Group holds about him/her/it. The UNIFIN Group may charge a fee for providing such information in writing to the registered, according to rates fixed by the Danish Ministry of Justice.
If the data held about a registered of the UNIFIN Group proves inaccurate or outdated, the UNIFIN Group will correct the registered data immediately upon the request of the registered. The registered may also choose to modify its data on its own initiative by contacting the UNIFIN Group directly. Questions and concerns can be directed to the UNIFIN Group by visiting our Contact Us Page.

Supervision

The UNIFIN Group is under the supervision of the Danish Financial Supervisory Authority (in Danish: «Finanstilsynet») and is subject to the Danish Executive Order on Good Business Practice for Financial Undertakings.

Disputes

This disclaimer and any dispute arising from or in relation thereto, including disputes regarding its legality, validity, binding effect (including adoption) and enforceability, shall be settled by the district court of Lyngby, Denmark in accordance with and subject exclusively to the laws of Denmark. However, the UNIFIN Group reserves the right to start legal proceedings wherever it deems fit, namely, but not exclusively, in places where the defendant possesses assets.

Non-Independent Investment Research

Any information which could be construed as investment research has not been prepared in accordance with legal requirements designed to promote the independence of investment research. Further it is not subject to any prohibition on dealing ahead of the dissemination of investment research. UNIFIN, its owners, subsidiaries, affiliates or employees of the same (collectively “UNIFIN Group”), may perform services for, solicit business from, hold long or short positions in, or otherwise be interested in the investments (including derivatives), of any issuer mentioned herein.

Forward-Looking Statements

Where there are statements contained in this website which are not historical facts, such statements could be data obtained as a result of simulated past performance or future performance based on current expectations, estimates, projections, opinions and beliefs of members of the UNIFIN Group. Such statements involve known and unknown risks, uncertainties and other factors, and undue reliance should not be placed thereon. Additionally, this website may contain ‘forward-looking statements. Actual events or results or actual performance may differ materially from those reflected or contemplated in such forward-looking statements. None of any opinions that may be inferred from the contents of this website is intended to be relied upon as advice or recommendation of any action. They are intended merely as articulations of personal musings and speculations factually.

Market in Financial Instruments Directive

MiFID, the Market in Financial Instruments Directive, is an EU Directive which has been in effect from 1 November 2007.

MiFID sets forth a range of requirements for the entire European financial sector with the aim of introducing a single European market in financial instruments. Its main goal is to promote the emergence of an efficient, transparent and integrated financial trading infrastructure, including ensuring a high degree of investor protection. The Directive contains measures that changed and improved the organization and functioning of investment firms, facilitating cross border trading, while creating strategic opportunities.

UniFin ApS (UNIFIN), as an professional stock market participant, falls under the MiFID’s jurisdiction and has as such implemented all necessary legal requirements, protocols and policies to ensure full compliance with the Directive. With regards to MiFID implementation for partners, UNIFIN proactively supports them by offering a range of services, which will facilitate the partners themselves to meet their local national MiFID requirements and hence reduce costs.

The Danish Financial Supervisory Authority (Finanstilsynet) monitors the Danish banking industry’s compliance with MiFID.

Areas of MiFID legislation impacting UNIFIN clients and partners

Single Passport and New Financial Instruments covered
Client Classification — Suitability & Appropriateness Tests
Post-Trade Transparency
Best Execution
Transaction Reporting
Conflict of Interest

Single Passport and New Financial Instruments covered

UNIFIN, being a fully licensed bank and investment firm covered by MiFID, uses the MiFID passport to provide services to customers in other EEA countries.

Client Classification — Suitability & Appropriateness Tests

MiFID requires firms to classify clients in three main categories, as «Eligible Counterparties», «Professional Clients» and «Retail clients» (the latter having the highest level of protection) and to assess their suitability and appropriateness for the products offered.

UNIFIN notifies all its clients of their classification and appropriateness/suitability status and the information is available on the platform.

Post-Trade Transparency

UNIFIN ensures that transparency of transactions is achieved in accordance with MiFID. In order to enable investors or market participants to assess the terms of potential stock transactions at any time and to verify afterwards the conditions in which these transactions were carried out, UNIFIN publics details of completed stock transactions and disclose details of current opportunities to trade in shares. More specifically, all types of trading in financial instruments, whether on regulated markets, MTFs or over-the-counter (OTC) are subject to a post-trade transparency obligation.

Best Execution

MiFID requires that investment firms take all reasonable steps to obtain the best overall result in the execution of an order for a client. The best possible result is not limited to execution price, but also includes a variety of factors, such as speed, likelihood of execution and likelihood of settlement.

UNIFIN’s Order Execution Policy creates transparency for the clients of UNIFIN’s means of ensuring best execution hereunder relying on: (i) state-of-the-art technology for routing, monitoring and executing orders; (ii) careful consideration of the elements of order execution; (iii) regular and rigorous examination of the overall execution quality.

Transaction Reporting

UNIFIN must report all transactions to the Danish Financial Supervisory Authority.

Conflicts of Interest

In accordance with MiFID, UNIFIN Group’s Conflicts of Interest Policy identifies and discloses a range of circumstances which may constitute or may give rise to a conflict of interest, potentially but not necessarily entailing a material risk of damage to the interests of one or more clients.

If you have any questions regarding MiFID and its impact on your trading, please contact your account manager.

Privacy Policy

Introduction
1. In order to service our clients UniFin ApS (hereinafter “UNIFIN” “we” or “us”) needs to collect personal data from our clients and /or potential clients and employees.
  
  In light of the above, UNIFIN wants to ensure a high level of data protection as privacy is a cornerstone in gaining and maintaining the trust of our clients, employees and suppliers and thus, ensuring UNIFIN’s future business.
  
  Protection of personal data requires that appropriate technical and organisational measures are taken to demonstrate a high level of data protection. UNIFIN has adopted a number of internal and external data protection policies, which must be followed by employees of UNIFIN.
  
  Additionally, UNIFIN will monitor, audit and document internal compliance with the data protection policies and applicable statutory data protection requirements.
  
  UNIFIN will also take the necessary steps in order to enhance data protection compliance within the organisation. These steps include the assignment of responsibilities, raising awareness and training of staff involved in processing operations. Please note that this privacy policy will be reviewed from time to time to take into account any new obligations. Retention and processing of personal data will be governed by our most recent policy.
  
  This privacy policy, along with guidelines for processing of personal data, constitutes the overall framework for processing of personal data within UNIFIN.
2. “Personal data” is any information which may be related to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, location data, phone number, age, gender, an employee, a job applicant, clients, suppliers and other business partners. This also includes special categories of personal data (sensitive personal data) and confidential information such as health information, account number, identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
3. Although information regarding companies/businesses is not as such personal data, please note that information relating to contacts within such companies/businesses, e.g. name, title, work email, work phone number, etc. is considered personal data.
4. UNIFIN collects and uses personal data for a variety of legitimate business purposes, including establishment and management of customer and supplier relationships, completion of purchase agreements, recruitment and management of all aspects of terms and conditions of employment, communication, fulfilment of legal obligations or requirements, performance of contracts, providing services to clients, etc.
5. Personal data shall always be:
  - Processed lawfully, fairly and in a transparent manner in relation to the data subject;
  - collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  - adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  - accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  - kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed;
  - processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
6. UNIFIN shall be responsible for and be able to demonstrate compliance with the above as part of UNIFIN’s accountability.
Legal basis for the processing personal data
1. Processing of personal data requires a legal basis. The most predominant legal basis for processing personal data within UNIFIN are:
  - Consent from the data subject(s) for one or more specific purposes;
  - The performance of a contract to which the data subject is party;
  - A legal obligation or requirement;
  - Legitimate interests pursued by UNIFIN;
2. Consent
  1. If the collection, registration and further processing of personal data on clients, suppliers, other business relations and employees are based on such a person’s consent to the processing of personal data for one or more specific purposes, UNIFIN shall be able to demonstrate that the data subject has consented to processing of such personal data.
  2. Consent shall be: freely given, specific, informed and unambiguous.
    
    The data subject must actively consent to the processing of personal data by a statement or by a clear affirmative action.
  3. A request for consent shall be presented in a manner, which is clearly distinguishable from other matters, in an intelligible and easily accessible form, using clear and plain language.
  4. To process special categories of personal data (sensitive personal data) the consent shall also be explicit.
  5. The data subject is entitled to withdraw his/her consent at any time and upon such withdrawal, we will stop collecting and/or processing personal data about that person unless we are obligated or entitled to do so based on another legal basis.
3. Performance of a contract:
  1. It will be legitimate to collect and process personal data relevant to the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. This applies to all contractual obligations and agreements signed with UNIFIN, including the pre-contractual phase irrespective of the success of the contract negotiation.
4. Compliance with a legal obligation
  1. UNIFIN must comply with various legal obligations and requirements, which are based on Union or Member State law. Such legal obligations, to which UNIFIN is subject, may be sufficient as a legitimate basis for the processing of personal data.
  2. Such legal obligations include obligations to collect, register and/or make available certain types of information relating to employees, clients, etc. Such legal requirements will then form the legal basis for us to process the personal data, however, it is important to note whether the provisions allowing or requiring UNIFIN to process certain personal data also set out requirements in relation to storage, disclosure and deletion.
5. Legitimate interests
  1. Data will only be processed where it is necessary for the purposes of the legitimate interests pursued by UNIFIN, and these interests or fundamental rights are not overridden by the interests of the data subject. UNIFIN will, when deciding to process data, ensure that the legitimate interests does not override the rights and freedoms of the individual and that the processing will not cause unwarranted harm. An example of legitimate interest of UNIFIN is to process personal data on potential clients in order to expand the business and develop new business relations. The data subject must be given information on the specific legitimate interest if a processing is based on this provision, cf. section 4.1 below.
Processing and transfer of personal data
1. UNIFIN as Data Controller
  1. UNIFIN will be considered a data controller to the extent that we decide by which means the data subject’s personal data shall be processed e.g. when a data subject signs an agreement with UNIFIN.
2. Use of data processors
  1. An external data processor is a company, which processes personal data on behalf of UNIFIN and in accordance with UNIFIN’s instructions, e.g. in relation to HR systems, third party IT providers, etc. When UNIFIN outsources the processing of personal data to data processors, UNIFIN ensures that said company as a minimum applies the same degree of data protection as UNIFIN. If this cannot be guaranteed, UNIFIN will choose another data processor.
3. Data processing agreements
  1. Prior to transfer of personal data to the data processor, UNIFIN shall enter into a written data processing agreement with the data processor. The data processing agreement ensures that UNIFIN controls the processing of personal data, which takes place outside UNIFIN for which UNIFIN is responsible.
  2. If the data processor/sub-data processor is located outside the EU/EEA,the conditions of clause 3.4.4 below will apply.
4. Disclosure of personal data
  1. Before disclosing personal data to others, it is the responsibility of UNIFIN to consider whether the recipient is employed by us or not. Furthermore, we may only share personal data within UNIFIN if the disclosure is based on a legitimate business purpose.
  2. It is UNIFIN’s responsibility to ensure that the recipient has a legitimate purpose for receiving the personal data and to ensure that the sharing of personal data is restricted and kept to a minimum.
  3. UNIFIN must show caution before sharing personal data with persons, data subjects or entities outside of UNIFIN.
    
    Personal data shall only be disclosed to third parties acting as individual data controllers if a legitimate purpose for such transfer exists. If the recipient is acting as a data processor, please refer to clause 3.2 above.
  4. If the third party recipient is located outside the EU/EEA in a country that does not ensure an adequate level of data protection, the transfer can only be completed if a transfer agreement has been entered into between UNIFIN and the third party. The transfer agreement shall be based on the EU Standard Contractual Clauses.
Rights of the data subjects
1. Duty of information
  1. When UNIFIN collects and registers personal data on data subjects, UNIFIN is obligated to inform such persons about:
    - The purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
    - The categories of personal data concerned;
    - The legitimate interests pursued by UNIFIN, if the processing is based on a balancing of interests;
    - The recipients or categories of recipients of the personal data, if any;
    - Where applicable, the fact that UNIFIN intends to transfer personal data to a third county and the legal basis for such transfer;
    - The period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
    - The existence of the right to request from UNIFIN access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;
    - Where the processing is based on the data subject’s consent, the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
    - The right to lodge a complaint with UNIFIN via the correct procedure or with a supervisory authority;
    - Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;
    - The existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2. Right to access
  1. Any person whose personal data UNIFIN is processing, including but not limited to, UNIFIN employees, job applicants, external suppliers, clients, potential clients, business partners, etc. has the right to request access to the personal data which UNIFIN processes or stores about him/her.
  2. If UNIFIN processes or stores personal data about the data subject, the data subject shall have the right to access the personal data and the reasons for the data to be processed in relation to the criteria set out in 4.1.1.
3. The data subject shall have the right to obtain from UNIFIN without undue delay the rectification of inaccurate personal data concerning him or her.
4. The data subject shall have the right to obtain from UNIFIN the erasure of personal data concerning him or her and UNIFIN shall have the obligation to erase personal data without undue delay, unless it is required by law to retain any information for a prescribed period of time, for example, by financial regulators or tax authorities.
5. The data subject shall have the right to obtain from UNIFIN restriction of processing, if applicable.
6. The data subject shall have the right to receive the personal data registered in a structured and commonly used and machine-readable format.
7. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on a balancing of interests, including profiling.
8. Any requests received from a data subject to exercise the rights in this clause will be answered as soon as reasonably possible, and no later than 30 days from receipt. Requests shall be forwarded without delay to UNIFIN’s Service Center. The Service Center will be supported by the UNIFIN’s Data Protection Officer to process the request to meet the reply deadline.
Data Protection by Design and Data Protection by Default
1. New products, services, technical solutions, etc. must be designed so they meet the principles of data protection by design and data protection by default settings.
  1. Data protection by design means that when designing new products or services, key considerations to data protection must be shown.
    - UNIFIN will take the following factors into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the data processing.
    - UNIFIN shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet data protection requirements and protect the rights of data subjects.
  2. Data protection by default requires that relevant data minimization techniques are implemented.
    - UNIFIN shall implement appropriate technical and organisational measures ensuring that, by default, only personal data which is necessary for each specific purpose of the processing is processed.
    - This minimization requirement applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility.
    - Such measures shall ensure that by default, personal data is not made accessible without careful consideration.
Records of processing activities
1. UNIFIN shall as data controller maintain records of processing activities under UNIFIN’s responsibility. The records shall contain the following information:
  1. UNIFIN shall make the records available to relevant data protection authorities upon request.
Deletion of personal data
1. Personal data shall be deleted when UNIFIN no longer has a legitimate purpose for the continuous processing or storage of the personal data, or when it is no longer required to store the personal data in accordance with applicable legal requirements.
2. Detailed retention periods with respect to various categories of personal data are specified in UNIFIN’s Data Retention and Information Sharing policy.
3. In compliance with privacy regulation, UNIFIN’s clients/potential clients have the right to request personal information relating to their account with UNIFIN be deleted or anonymised when their client relationship with UNIFIN has ended.
4. UNIFIN will balance the privacy rights of its clients/potential clients with other requirements of applicable regulations taking precedence over the deletion requirement. The registration of personal data in UNIFIN’s systems is regulated by a wide range of various legal requirements such as the Financial Business Act, bookkeeping rules, consumer protection etc.
5. Personal data will be deleted or anonymised when there is no longer any legal basis for keeping it. The typical deletion deadline for clients are current year plus 5 years after the end of a client relationship.
6. For UNIFIN’s potential clients, personal data relating to their engagement with UNIFIN will delete or anonymised upon their request and as soon as possible, but please be advised that it may take up to 1 month to comply with such request.
7. Personal information about UNIFIN’s clients/potential clients who have incurred a loss to UNIFIN may be stored for a longer period of time to protect UNIFIN from further loss or for the purpose of pursuing a legitimate financial claim.
8. After any such period as stated above, UNIFIN will permanently delete or anonymise all personal data.
Assessment of risk
1. If UNIFIN processes personal data that is likely to result in a high risk for the persons whose personal data is being processed, a Data Protection Impact Assessment (“DPIA”) shall be carried out.
  1. A DPIA implies that UNIFIN will, taking into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, implement appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with data protection requirements.
2. The technical and organisational measures shall be reviewed and updated where necessary and no later than every 6 months.
  1. Adherence to approved codes of conduct or approved certification mechanisms may be used as an element by which to demonstrate compliance with the appropriate technical and organisational measures pursuant to this clause.
Profiling
1. “Profiling” in the context of this Privacy Policy is the use of an automated process to analyses personal data in order to assess or predict aspects of a person’s behavior. UNIFIN may use profiling in the following circumstances:
National requirements
1. UNIFIN shall comply with both the GDPR and national data protection legislation.
2. If national legislation requires a higher level of protection for personal data than the GDPR, such stricter requirements are to be complied with. If UNIFIN’s policies/guidelines are stricter than the local legislation, our policies/guidelines must be complied with.
Contact and complaints
1. If you have any questions regarding the content of this policy, please contact UNIFIN at [email protected].
2. If you would like to file a complaint about UNIFIN’s processing of personal data, please contact the Danish Data Protection Agency.

Protection of Client Funds

UniFin ApS (UNIFIN) bears full financial responsibility for the safety and repayment of assets of their clients.

Responsibility for the safety and repayment of clients’ monetary assets is not limited to anything. The recoverability of monetary assets is governed by the terms of the Grounds on which the funds were transferred to UNIFIN.

Responsibility for the safety and repayment of clients’ non-monetary assets is not limited to anything. The recoverability of non-monetary assets is governed by the terms of the grounds on which such assets were transferred to UNIFIN. Any non-monetary assets held in custody (management) in UNIFIN, have Estimated values that determine the amount of financial responsibility of the UNIFIN. Such estimated values are signed by the UNIFIN and the client, together with the Grounds on which they are transferred.

The format of the Estimated Cost document is determined by the UNIFIN and the client in each case individually. The Appraisal Document is a necessary attachment to the Basis of Transfer. The basis of the transfer is a form of legal document (Contract, Agreement, Memorandum and other legitimate form) signed by the UNIFIN and the client, governing the administrative and business relations of the UNIFIN and the client.

Risk Warning

Trading in the products and services of the UNIFIN Group may, even if made in accordance with a Recommendation, result in losses as well as profits.

Speculative trading is not suitable for all investors

No recommendations

business, financial, investment, hedging, legal, regulatory, tax or accounting advice,
a recommendation or trading idea, or
any other type of encouragement to act, invest or divest in a particular manner (collectively “Recommendations”).

The UNIFIN Group shall not be responsible for any loss arising from any investment based on a perceived Recommendation.

No Representation, No Warranty

If a Publication becomes outdated the UNIFIN Group shall be under no obligation to:

update the Publication,
inform the recipients of a Publication, or
perform any other action.

Internet Trading Risks

There are risks associated with utilizing an Internet-based deal execution trading system including, but not limited to, the failure of hardware, software, and Internet connection. Since UNIFIN does not control signal power, its reception or routing via Internet, configuration of your equipment or reliability of its connection, we cannot be responsible for communication failures, distortions or delays when trading via the Internet. UNIFIN employs back up systems and contingency plans to minimize the possibility of system failure, and trading via telephone is available.

Use of The Website

UNIFIN Vulnerability Disclosure Policy

We take the security of our systems and services seriously, and we value the global security community. Responsible disclosure of security vulnerabilities helps us ensure the security and privacy of our customers, partners and employees.

Guidelines

If you follow these guidelines when reporting an issue to us, we commit to:

Not pursue or support any legal action related to your research
Work with you to understand and resolve the issue quickly (including an initial confirmation of your report within 72 hours of submission)
Recognize your contribution, if you are the first to report the issue and we make a code or configuration change based on the issue.

We require that all researchers:

Make every effort to avoid privacy violations, degradation of user experience, disruption to production systems, and destruction of data during security analysis- Perform analysis only within the scope set out below
Use the defined communication channels (as identified below) to report vulnerability information to us - Keep information about any suspected or confirmed security issues you’ve discovered confidential between yourself and UNIFIN until we’ve had 90 days to resolve the issue

Scope

www.UNIFIN.finance

Simulation UNIFINTraderPRO Simulation UNIFINOpenAPI

Out of Scope

Any services hosted by 3rd party providers and services are excluded from scope. These services include:

News feeds
Price feeds

In the interest of the safety of our users, staff, the Internet at large, and you as a security researcher, the following test types are excluded from scope:

Findings from physical testing such as office access (e.g. open doors, tailgating)
Findings derived primarily from social engineering (e.g. phishing, vishing)
Findings from applications or systems not listed in the ‘Scope’ section
UI and UX bugs and spelling mistakes
Network level Denial of Service (DoS/DDoS) vulnerabilities
Missing cookie flags and security headers
Form spamming

Information we do not want to receive:

Personally identifiable information (PII)
Credit card holder data
Results from automated scanning tools

Reporting security vulnerabilities

If you believe you’ve found a security issue in one of our products or platforms please send it to us by emailing [email protected].

Please include the following details with your report:

Description of the location and potential impact of the identified issue(s)
A detailed description of the steps required to reproduce your findings (POC scripts, screenshots, and compressed screen captures are all helpful to us) and
Your name/handle and a link for recognition in our Hall of Fame.

Whistleblowing

UNIFIN Group is committed to the highest standard of openness, integrity and accountability which is why we have established a whistleblowing system not only for employees but also covering clients, partners and other stakeholders.

If you contrary to our expectations should experience breaches committed by UNIFIN Group of applicable laws, policies, guidelines, UNIFIN Group’s own policies etc. you will be able to report your concerns with full confidentiality. If you prefer so, it will even be possible to report anonymously.

All grounded suspicions reported via the whistleblowing system will be treated carefully and in cases where regulation permits it, we will provide feedback if you ask for it.

Link to our whistleblowing system: www.UNIFINfinance.ethicspoint.eu

If you have a complaint which relates to e.g. a single trade or an issue where you have not received a satisfactory answer these types of incidents should typically be reported via our channel for complaints which you find [email protected].

Copyright

All content of the www.UNIFIN.finance website is the property of UniFin ApS (UNIFIN) unless otherwise stated. For pages where no third-party rights are listed (in the copyright statement at the bottom of each page), the following rules apply:

You may print the pages and store one copy on your PC for personal use.
You may not distribute the information to others but you may quote opinions and information on the site if you include a clear reference to UNIFIN and to the website and to the disclaimer available on www.UNIFIN.finance
You may also link to any portion of the site if the link clearly states the name of www.UNIFIN.finance and if it opens the page in a new browser window and not in a foreign frameset.

No other uses of the website and its content than the ones described above are allowed or may be inferred unless expressly permitted in writing by UNIFIN.

Cookies Policy

Any fact, assessment, analysis, forecasts, opinion and other information (collectively “Information”) released by:

UniFin ApS
any owner, subsidiary, affiliates or branch office of UniFin ApS, and
any director, officer, employee or representative here (collectively the “UNIFIN Group”) whether provided on the UNIFIN Group’s websites, on third party websites, in marketing materials, newsletters, in individual e-mails and letters, in lectures, individual conversations or in any other form of written or verbal communication (collectively “Publications”) are provided for informational and/or marketing purposes only.

Unless specifically stated, no Publication of the UNIFIN Group should be construed as an offer (or solicitation of an offer) to:

buy or sell any currency, product or financial instrument,
make any investment, or
participate in any particular trading strategy (collectively “Offers”)

Notwithstanding anything to the contrary (not even if specifically stated), no Publication of the UNIFIN Group should be construed as an Offer in any jurisdiction in which such Offer would be illegal. Any such perceived Offer will not be honored by the UNIFIN Group.

No Representation, No Warranty

If a Publication becomes outdated the UNIFIN Group shall be under no obligation to: - update the Publication,

inform the recipients of a Publication, or
perform any other action.

No recommendations

business, financial, investment, hedging, legal, regulatory, tax or accounting advice,
a recommendation or trading idea, or
any other type of encouragement to act, invest or divest in a particular manner (collectively “Recommendations”)

The UNIFIN Group shall not be responsible for any loss arising from any investment based on a perceived Recommendation.

The UNIFIN Group shall only be liable (in accordance with the “Limitation of Liability” section below) if a possible Recommendation is not of a good professional standard.

Risk Warning

Trading in the products and services of the UNIFIN Group may, even if made in accordance with a Recommendation, result in losses as well as profits.

Speculative trading is not suitable for all investors.

Local regulatory restrictions

It is the sole responsibility of any recipient employing or requesting a product or service of the UNIFIN Group to comply with all applicable legislation or regulation.

Use of the website

Translation discrepancies

The UNIFIN Group shall not be bound by, or liable to any recipient for, an incomplete or inaccurate translation of an original English text to another language.

Client relationship

Third party services

Limitation of Liability

Conflict of interest

The UNIFIN Group may hold, take, transfer or alienate positions in securities, foreign exchange or other financial instruments covered by a research reports.

Privacy and Use of Personal Data

When signing up for a demo or live account with any entity of the UNIFIN Group, this entity will, for administrative, commercial and/or legal purposes, require and store information about the user, including, but not limited to, name and address. Furthermore, the UNIFIN Group may require some financial information for credit assessment purposes, as well as users’ e-mail address to be able to mail the login information. Users’ e-mail addresses will not be passed on to third parties but may be used by any entity of the UNIFIN Group for the promotion of its products and services.

The UNIFIN Group is obliged by law to treat personal data as confidential and may not pass on or use any personal data without valid legal grounds.

All personal data benefits from this full protection and will only be disclosed to third parties such as administrative or judicial authorities if the UNIFIN Group is compelled to do so pursuant to the applicable law, or if the registered has given its written consent to such disclosure. The registered may revoke such consent or modify its extent at any time.

Without prejudice to the above, the UNIFIN Group can disclose the following information:
General customer data, such as name, address and personal registration number, to companies carrying out administrative tasks for the UNIFIN Group.

General customer data about corporate customers to financial institutions subject to professional secrecy, for the purpose of marketing and advisory services.

In accordance with the provisions of the Danish Act on Processing of Personal Data, any UNIFIN Group customer has a right to be informed about the data that the UNIFIN Group holds about him/her/it. The UNIFIN Group may charge a fee for providing such information in writing to the registered, according to rates fixed by the Danish Ministry of Justice.

If the data held about a registered of the UNIFIN Group proves inaccurate or outdated, the UNIFIN Group will correct the registered data immediately upon the request of the registered. The registered may also choose to modify its data on its own initiative by contacting the UNIFIN Group directly. Questions and concerns can be directed to the UNIFIN Group by visiting our Contact Us Page.

Supervision

Disputes

Non-Independent Investment Research

Forward-Looking Statements

This material is confidential and should not be copied, distributed, published or reproduced in whole or in part or disclosed by recipients to any other person.

Content

Complaints

Compliance & AML Statement

Statement regarding Anti-Money Laundering, Counter Terrorist Financing and Know-Your-Customer measures within UniFin ApS (UNIFIN).

Disclaimer

No Representation, No Warranty

No recommendations

Risk Warning

Market in Financial Instruments Directive

Privacy Policy

Protection of Client Funds

Risk Warning

UNIFIN Vulnerability Disclosure Policy

Whistleblowing

Copyright

Cookies Policy