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Privacy Policy

This Privacy Policy (hereinafter later referred to only as the “Policy”) defines the privacy practices employed by Axiory Global Ltd (hereinafter later referred to only as the “Company”) in providing the Service (as they defined in the License Agreement) to its customers (hereinafter later referred to only as the “Client”,) and shall be read in the light of the legal agreements and policies agreement provided by Company.


This Policy aims to define the process how Axiory Global Ltd. collects and processes personal data of the Clients through the use of (hereinafter later referred to only as the “Website”), including any data the Client may provide through the Website when signing up thereto.

This Website is not intended for children and no data related to children may be collected.


Axiory Global Ltd. is the controller and responsible person/entity for Client’s personal data. It is important that the personal data the Company holds about the Client is accurate and current. The obligation to inform the Company about any changes in personal data will be on Client’s side


Full name of legal entity: Axiory Global Ltd.
Title of DPO: Chief Executive Officer
Email address:
Postal address: No. 1 Corner of William Fonseca Street, Marine Parade, Belize City, Belize, C.A.
Telephone number: +357 25030444

The Client has the right to make a complaint at any time. He may contact the Company in case of any unclear issues or complaints on the above-mentioned address.


Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The Company may collect, use, store and transfer different kinds of personal data about the Client which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier.
  • Contact Data includes email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, Client’s login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices the Client uses to access this website.
  • Profile Data includes the username and password of the Client, his orders, interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and his communication preferences.


The Company will collect the following personal information about the Client in the event of opening an fxSimulator account with the Company:

  • Name;
  • Email address;
  • Phone number

This information will be held by the Company until the moment when such Client becomes a Company’s Client with real account opened. If he initiates the process of becoming a real account Client, he shall be requested to provide additional personal information and supporting documentation.

If the Client does not proceed with the opening of a real trading account with the Company, the Company will consider him as only an fxSimulator Client and shall keep only respective fxSimulator personal data of the Client.


Where the Company needs to collect personal data by law, or under the terms of a trading agreement with such Client, but the Client does not provide such data after being requested so, the Company may not be able to perform the agreement with the Client (concluded or in the process of conclusion). In this case, the Company may have to cancel the agreement with the Client with the obligation to notify the Client thereabout.


The Company uses different methods to collect data from and about the Client, including the following:

  • Direct interactions. The Client may provide his personal data to the Company by filling in forms or by distant communication with the Company via post, phone, email or otherwise. This includes personal data the Client provides, if he:
    • applies for the fxSimulator services by filling the registration form;
    • applies for the fxSimulator services by contacting Company’s representatives, assigned for the communication with clients;
    • applies for the fxSimulator services through any form of marketing tool (newsletter, landing page, etc.)
  • Automated technologies or interactions. As the Client interacts with the Website, his Technical Data about his equipment, browsing actions and patterns may be collected automatically. The Company collects such personal data by using cookies, server logs and other similar technologies. Technical Data about the Client may also be requested if such Client visits other websites by employing cookies of the Company.


Client’s personal data with be used only in case where the law allows the Company to do so. Most commonly, we will use Client’s personal data in the following circumstances:

  • Where there is a need to perform the agreement (concluded or in a process of conclusion with the Client).
  • Where it is necessary for Company’s legitimate interests (or those of a third party) and if such interests and fundamental rights do not override these interests.
  • Where the Company shall comply with a legal or regulatory obligation.

In general, the Company does not rely on respective consent, forming a legal basis for processing of Client’s personal data, other than in relation to sending third party direct marketing communications to you via email or text message. The Client has the right to withdraw his consent to marketing purposes at any time by contacting the Company at the following email


In a table format below, there is a description of all the ways the Company plans to use the personal data of its clients and the legal bases the Company relies on in such case. The Company has also identified what its legitimate interests are, where appropriate.

Client’s personal data may be processed for more than one lawful ground depending on the specific purpose for which we are using your data. If necessary, the Client shall contact the Company at for the purpose of obtaining necessary details about the specific legal ground the Company relies on to process his personal data where more than one ground has been set out in the table below

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register the Client as a new customer (a) Identity
(b) Contact
Performance of agreement with the Client.
To manage Company’s relationship with the Client, including:
(a) Notification of any changes to the terms or privacy policy
(b) Asking the Client to leave a review or to take a survey
(a) Identity
(b) Contact
(c) Marketing data
Performance of agreement with the Client.
To deliver relevant website content and advertisements to the Client and to measure or understand the advertising efficiency. (a) Identity<br>(b) Contact Performance of a contract with the Client. Necessary for our legitimate interests (study of Client‘s behaviour and their use of fxSimulator, business growth, marketing strategy information).
To use data analytics to improve the Website, products/services, marketing, customer relationships and experiences. (a) Identity
(b) Contact
Performance of a contract with the Client. Necessary for our legitimate interests (definition of respective Clients‘ categories, website update, business development, marketing strategy development).
To make suggestions and recommendations to the Client with regard to any product that may be of interest to the Client. (a) Identity
(b) Contact
Necessary for our legitimate interests (business growth and development of portfolio of Clients of real accounts).
To administer and protect Company‘s business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
Performance of a contract with the Client. Necessary for our legitimate interests (provision of administration and IT services, network security, fraud prevenetion, business reorganisation).


The Company provides option to the Client with regard to certain personal data uses, particularly related to marketing and advertising.


Company may use Client‘s identity, contact, technical, usage and profile data to form a view with regard to potential needs of such Client or what may be of his interest. Thus, the Company may decide on products, services and offers relevant for the Client (so for the marketing purpose).

The Client may receive marketing communications from the Company only if he has requested information from the Company or provided his details when entering the Website for the purpose of receiving information and, in each case, not opting out the receipt of marketing notifications.


Before sharing Client‘s personal data for marketing purposes with any company outside Axiory Global Ltd. group of companies, the Company needs an express opt-in consent of the Client.


The Client shall have the right to ask the Company or third parties to stop sending any marketing messages at any time by following the opt-out links on any marketing message sent to him or by contacting the Company at any time at the following email address:


The Client shall have the right to set his browser to refuse all or some browser cookies, or to alert the Company of any setting or access of cookies on the Website.


Personal data of the Client may be used for the purposes for which they have been collected, unless any other reason is considered and such reason is compatible with the original purpose.

In case of any unrelated purpose, the Company shall notify the Client and explain the legal basis thereof. Client‘s personal data may be processed without the knowledge or consent of such client, in compliance with the rules specified above, where required or permitted by the law.


The Company may share Client‘s personal data with third parties for the purpose of carrying out its services related to fxSimulator properly. Security of Client‘s personal data shall be fully respected by such third parties and treated in accordance with the law. Such Client‘s personal data may not be used by third parties for their own purposes while they may be processed only for specified purposes by the Company and in accordance with Company‘s instructions.


The Company is obliged to put appropriate security measures in place to prevent Client‘s personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, the Company shall limit access to Client‘s personal data to only such employees or third parties that are actively participating on the performance of subject of the License Agreement. Such employees or third parites will only process Client‘s personal data on the basis of Company‘s instructions while respecting the duty of confidentiality.

The Company shall implement procedures to deal with any suspected personal data breach and notify the Client and any applicable regulator thereabout, where legally required so.


Personal data of the Client shall be retained for as long as necessary to meet the purposes for which they were collected, including the purposes of satisfying any legal, accounting, or reporting requirements.

For the purpose of determination of appropriate retention period for personal data, the Company shall consider the number, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of such personal data, the purposes for which such personal data is processed and if these purposes may be achieved through other means, and the applicable legal requirements.


Any Client shall have following rights under data protection laws in relation to his personal data:

  • Request access to his personal data (commonly known as a “data subject access request”). The Client is allowed to receive a copy of personal data the Company keeps about him and to check that such data is lawfully processed.
  • Request correction of Client‘s personal data. The Client may request correction of any incomplete or inaccurate data the Company keeps about him, though the Company may need to verify the accuracy of the new data the Client provides.
  • Request erasure of Client‘s personal data. The Client has the right to request the Company to delete or remove personal data where there is no appropriate reason for the Company to process it. The Client may also request the Company to delete or remove his personal data where he has successfully exercised his right to object to processing (see below), where hi information may have been processed unlawfully or where the Company is required to erase his personal data to comply with local law. Nevertheless, the Company may refure to comply with Client’s request for specific legal reasons, which it shall notify the Client thereabout.
  • Object to processing of Client‘s personal data where the Company relies on a legitimate interest (or those of a third party) and there is something about his particular situation making him wanting to object to processing on this ground as the Client believes it affects his fundamental rights and freedoms. The Client may also object processing of his personal data for direct marketing purposes. In some cases, the Company may demonstrate that it has compelling legitimate grounds to process Client‘s information, overriding his rights and freedoms.
  • Request restriction of processing of Client‘s personal data. This allows the Client to ask the Company to suspend the processing of his personal data in the following scenarios: (a) if the Client wants the Company to establish the data’s accuracy; (b) where Company‘s use of the data is unlawful but the Client does not want the Company to erase it; (c) where the Client needs the Company to keep the data, even if no longer required by the Company, as he may need it to establish, exercise or defend legal claims; or (d) the Client has objected to Company‘s use of his data but the Company needs to verify whether it has overriding legitimate grounds to use it.
  • Request the transfer of Client‘s personal data to him or to any third party. The Company will provide such personal data to the Client or respective third party of his choice in a structured, commonly used, machine-readable format. This right only applies to automated information which the Client initially provided consent for to the Company to use or where the Company used the information to perform a contract with the Client.
  • Withdraw consent at any time where the Company relies on consent to process Client‘s personal data. However, this will not affect the lawfulness of any processing carried out before the Client withdraws his consent.
This Privacy Policy takes effect on December 20, 2018

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Terms and conditions

1. Provider

The service provider is Axiory Global Limited, registration number 127 090, No. 1 Corner of William Fonseca Street, Marine Parade, Belize City, Belize, C.A. (hereinafter referred to as the “Provider”).

2. Services

The Provider offers the service fxSimulator. This service is available at the Internet address and is designed to simulate trading on forex (foreign exchange) markets. is only a simulator of forex markets and it is not a real platform providing a real purchase or a real sale of currency pairs. All trades in the application are only a simulation. Any profit or loss resulting from trading in the platform is solely a fictional amount and no liabilities and claims arise from them.

3. Registered Users

3.1. Any natural or legal person may become the user of services at (hereinafter the "User").

3.2. The service shall be ordered by the User on the basis of a completed and submitted registration form via the Internet.

3.3. By submitting the registration form via the Internet, the User accepts all general terms and conditions as if these conditions were signed in the form of a contract. These general terms and conditions are legally binding in unabridged and up-to-date version that is accessible to the public on web sites

3.4. The service Provider reserves the right to verify registration data given by the User in the registration form. For the purpose of verification, the User shall proceed in accordance with the instructions specified by the Provider in the verifying email. To use the service in the long term, it is necessary to perform a so-called Activation. The User shall then receive information about a successful activation by email to the provided email address.

3.5. The User shall register to use the service. As a part of registration, the User is prompted to create a password to their customer account. The User shall keep the password confidential and shall not share it with other persons. The User is held responsible for all activities performed from their account. In the case of any suspicion of their password’s abuse or making their password accessible to a third party, the User shall instantly notify the Provider. In the event of a well-founded concern that the User's account may be abused, the Provider is entitled to block the User's account or as the case may be to prompt the User to change their password. The Provider is not liable for damages that may arise to the User as a result of disclosure or abuse of their password by a third party.

3.6. The Provider is entitled to suspend or abolish the User's registration if the Provider has a reasonable ground to assume that the User breaches the terms and conditions or other mutual agreements. In the case of termination or abolishment of the registration, none of the general terms and condition regarding the User are remain legally binding to the Provider.

4. Price Programs

The service is offered by the Provider using the following price programs:

4.1. Program Free

Program Free has limited data and functions according to the up-to-date configuration.

5. Service Termination

5.1. The service shall be terminated after submitting an account deletion request from the User's profile.

5.2. The User agrees that the Provider is entitled to promptly terminate the provision of services under any of the following conditions:

  • The User shall breach the general terms and conditions,
  • The User shall abuse, block, modify or anyhow change the functions of the Provider's service and/or has attempted to interfere with the stability, operation or the service data.

6. Protection of Intellectual Property Rights

6.1 The Provider is a licensed provider of the template, software, application and the service itself.

6.2. The User shall be obligated not to:

  • copy, download and spread any of the Provider's or other Users' content without their permission.
  • interfere with safety services.
  • create false messages for the purpose of falsifying the User's identity or attempting to penetrate accounts of other Users.

6.3 The Provider is entitled to delete accounts with speculative nature.

Unless stated otherwise, all rights, the title and interests in and to fxSimulator and all content accessible at fxSimulator including its services in various languages, formats and media as well as copyrights are the exclusive property of the provider of service fxSimulator.

The User is not allowed to use robots, data mining or data gathering, to extract tools and frame and reproduce or sublicense any part of fxSimulator and its content.

The User is not allowed to evade any mechanism and legal regulations for the purpose of unauthorized reproduction or distribution of the content including the services at

7. Additional terms and agreements

7.1. The Provider reserves the right to change these conditions at any time without prior notice:

  • incompatibility of with the end device, the User's software or their connection to electronic communications networks;
  • technical inconveniences including errors and connection failures to

7.2. The Provider shall attempt maximum functionality and accessibility of the provided services. Nevertheless, regarding technical aspects of the service, the Provider cannot guarantee absolute accessibility of the service. The Provider reserves the right to limit the access to the service for necessary period of time to perform repairs, maintenance or system upgrade and to implement new system features.

7.3. The Provider shall not be liable for damages resulting from any loss of data or damage to any stored data.

7.4. Shall any errors in the course of registration occur, contact the Provider at

7.5. Snowly Code s.r.o. hereby agrees to indemnify, defend and hold harmless Axiory Global Ltd. from and against any and all claims, losses, demands, liabilities, costs and expenses suffered or incurred by Axiory Global Ltd as a result of, or in connection with, any third-party claims to the extent caused, in whole or in part, by the fraud, gross negligence or wilful misconduct of Snowly Code s.r.o. in performing the Services. In no event shall the aggregate liability of Snowly Code s.r.o. to Axiory Global Ltd, for any damages concerning Snowly Code s.r.o. in performing the services.

7.6. The data is free to use under these circumstances:
Anyone using and/or putting free web products including all or parts of the information taken from the Dukascopy Trading Tools and/or any other data available as free product form Ducascopy Bank's website shall put a clear note to the public that such data are not meant to indicate the actual value at any given point in time but to represent a discretionary assessment by Dukascopy Bank SA only. The data source is

7.7. These terms and conditions are valid and effective as of 1.9.2018