If you as a client or a prospective client of Scandinavian Capital Association K/S have raised a question or an issue with Scandinavian Capital Association K/S for instance with your account manager or another employee of Scandinavian Capital Association K/S without receiving a satisfactory answer you may file a complaint with Scandinavian Capital Association K/S.

Please contact us in writing by using the following address:
      Attn:   Christians Brygge 28,
                1559 København, Denmark
      Or send information via e-mail to:
                 [email protected]

The Scandinavian Capital Association K/S is committed to adhering to the highest standards of compliance with rules, regulations and ethical standards.

Scandinavian Capital Association K/S is licensed by the DFSA and as such is subject Denmark 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 Scandinavian Capital Association K/S.

Anti-Money Laundering (AML), Counter Terrorist Financing (CTF) and Know-Your-Customer (KYC) measures are focus areas within Scandinavian Capital Association K/S. 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 Scandinavian Capital Association K/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, Scandinavian Capital Association K/S pays special attention to:

• Understanding the ownership and control structure of our customers,
• Obtaining 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 Scandinavian Capital Association K/S is used to execute transactions related to money laundering and terrorist financing.

Scandinavian Capital Association K/S does not allow anonymous accounts.
We co-operate with law enforcement and regulatory agencies in accordance with national regulation.

All content of the scadk.finance website is the property of Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S and to the website and to the disclaimer available on scadk.finance.
• You may also link to any portion of the site if the link clearly states the name of scadk.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 Scandinavian Capital Association K/S.

This website can be accessed worldwide however the information on the website is related to Scandinavian Capital Association K/S and is not specific to any entity of SCA GROUP. All clients will directly engage with Scandinavian Capital Association K/S and all client agreements will be entered into with Scandinavian Capital Association K/S and thus governed by Denmark.

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

• Scandinavian Capital Association K/S
• any owner, subsidiary, affiliates or branch office of Scandinavian Capital Association K/S, and
• any director, officer, employee or representative here (collectively the “SCA GROUP”) whether provided on the SCA GROUP 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 SCA 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 SCA 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 SCA GROUP.

No Representation, No Warranty

The SCA 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 SCA GROUP disclaims liability for any Publication not being complete, accurate, suitable and relevant for the recipient.

The Publications of the SCAA 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 SCA GROUP gives no guarantee against, and assumes no liability towards any recipient for, a Publication being outdated.

If a Publication becomes outdated the SCA 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 SCA GROUP.

The SCA 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 SCA 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 SCA 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 SCA 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 SCA 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 SCA 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 SCA 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 SCA GROUP 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 SCA 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 SCA GROUP to comply with all applicable legislation or regulation.

Use of the website

Any use of the SCA GROUP websites is subject to SCA GROUP “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 SCA 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 SCA 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 SCA GROUP does not constitute a customer relationship and the SCA 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 SCA 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 SCA 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 SCA GROUP by e-mail at [email protected]

The SCA 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 SCA 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 SCA GROUP.

Consulting a website or receiving a Publication of the SCA GROUP does not constitute a customer relationship and the SCA 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 SCA GROUP may advertise on the SCA GROUP websites, through links, banners or otherwise. The SCA GROUP shall not be held responsible or liable for the offerings, information or acts of any such third party. If a user of the SCA GROUP websites decides to act upon any such advertising, such user does so entirely at its own risk.

Limitation of Liability

If the SCA 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 SCA 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 SCA GROUP has established appropriate business procedures, including procedures applicable to research and analysis to ensure objective research reports. The SCA GROUP research reports are never disclosed to nor discussed with any of the subject of the analysis, e.g. issuers of securities or others.
The SCA GROUP may hold, take, transfer or alienate positions in securities, foreign exchange or other financial instruments covered by a research reports.

The SCA 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 SCA GROUP does not engage in corporate finance activities. Accordingly, none of the SCA GROUP 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 SCA 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 SCA 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 SCA GROUP for the promotion of its products and services.

The SCA 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 SCA 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 SCA 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 SCA 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 Denmark Act on Processing of Personal Data, any SCA GROUP customer has a right to be informed about the data that the SCA GROUP holds about him/her/it. The SCA GROUP may charge a fee for providing such information in writing to the registered, according to rates fixed by the Denmark Ministry of Justice.
• If the data held about a registered of the SCA GROUP proves inaccurate or outdated, the SCA 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 SCA GROUP directly.

Questions and concerns can be directed to the SCA GROUP by visiting our Contact Us Page.

Supervision

The SCA GROUP is under the supervision of the Denmark FSA and is subject to the Denmark 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 Copenhagen, Denmark in accordance with and subject exclusively to the laws of Denmark. However, the SCA 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. Scandinavian Capital Association K/S, its owners, subsidiaries, affiliates or employees of the same (collectively “SCA 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 SCA 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.

General

Please note that the contents of this website are not intended for distribution to, or use by, any person in any jurisdiction or country where such distribution or use would be unlawful or otherwise attract for Scandinavian Capital Association K/S additional regulatory or business or tax presence compliance requirements in those countries in addition to Denmark that Scandinavian Capital Association K/S does not already comply with. It is your responsibility to ascertain the terms of access and usage of the contents in this website comply with the local laws and regulations that you are subject to.

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.


No Representations/Warranties

None of the information contained herein is intended to and shall not constitute any offer (or solicitation of an offer) to buy or sell any currency, product or financial instrument, to make any investment, or to participate in any particular trading strategy. This information is produced only for value added marketing and/or informational purposes and no member of the SCA GROUP makes any representation or warranty, and assumes no liability, for the accuracy or completeness of the information provided herein. In providing this information, neither the content provider nor any member of the SCA GROUP has taken into account the investment objectives, special investment goals, financial situation, and specific needs and demands of any recipient and nothing herein is intended as a recommendation for any recipient to invest or divest in a particular manner. No member of the SCA GROUP assumes any liability for any recipient sustaining a loss from trading in accordance with a perceived recommendation.

Risk Warning

All investments entail risks and may result in both profits and losses. In particular, investments in leveraged products, such as, but not limited to foreign exchange, derivatives and commodities can be very speculative and profits and losses may fluctuate both violently and rapidly. Speculative trading is not suitable for all investors and all recipients should carefully consider their financial situation and consult financial advisor(s) in order to understand the risks involved and ensure the suitability of their situation prior to making any investment, divestment or entering into any transaction. Any mention herein of any risks may not be and should not be considered to be a comprehensive disclosure or description of such risks. Any expression of opinion is personal to the author and may not necessarily reflect the opinion of any member of the SCA GROUP and all expressions of opinion are subject to change without notice (neither prior nor subsequent).

Past Performance Is No Indication

This website may make reference to past performance. Past performance is not a reliable indicator of future performance. Indications of past performance displayed on this website will not necessarily be repeated in the future. No representation is being made that any investment will or is likely to achieve profits or losses similar to those achieved in the past or that significant losses will be avoided.

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 SCA 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 disclosed by recipients to any other person.

1. Introduction

1.1. In order to service our clients Scandinavian Capital Association K/S needs to collect personal data from our clients and /or potential clients and employees.

In light of the above, Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S future business.

Protection of personal data requires that appropriate technical and organisational measures are taken to demonstrate a high level of data protection. Scandinavian Capital Association K/S has adopted a number of internal and external data protection policies, which must be followed by employees of Scandinavian Capital Association K/S.

Additionally, Scandinavian Capital Association K/S will monitor, audit and document internal compliance with the data protection policies and applicable statutory data protection requirements.

Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S.

1.2. “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.

1.3. 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.

1.4. Scandinavian Capital Association K/S 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.

1.5. 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.

1.6. Scandinavian Capital Association K/S shall be responsible for and be able to demonstrate compliance with the above as part of Scandinavian Capital Association K/S accountability.

2. Legal basis for the processing personal data

2.1. Processing of personal data requires a legal basis. The most predominant legal basis for processing personal data within Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S;

2.2. Consent

2.2.1. 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, Scandinavian Capital Association K/S shall be able to demonstrate that the data subject has consented to processing of such personal data.

2.2.2. 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.

2.2.3. 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.

2.2.4. To process special categories of personal data (sensitive personal data) the consent shall also be explicit.

2.2.5. 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.

2.3. Performance of a contract:

2.3.1. 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 Scandinavian Capital Association K/S, including the pre-contractual phase irrespective of the success of the contract negotiation.

2.4. Compliance with a legal obligation.

2.4.1. Scandinavian Capital Association K/S must comply with various legal obligations and requirements, which are based on Union or Member State law. Such legal obligations, to which Scandinavian Capital Association K/S is subject, may be sufficient as a legitimate basis for the processing of personal data.

2.4.2. 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 Scandinavian Capital Association K/S to process certain personal data also set out requirements in relation to storage, disclosure and deletion.

2.5. Legitimate interests

2.5.1. Data will only be processed where it is necessary for the purposes of the legitimate interests pursued by Scandinavian Capital Association K/S, and these interests or fundamental rights are not overridden by the interests of the data subject. Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S 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.

3. Processing and transfer of personal data

3.1. Scandinavian Capital Association K/S as Data Controller

3.1.1. Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S.

3.2. Use of data processors

3.2.1. An external data processor is a company, which processes personal data on behalf of Scandinavian Capital Association K/S and in accordance with Scandinavian Capital Association K/S instructions, e.g. in relation to HR systems, third party IT providers, etc. When Scandinavian Capital Association K/S outsources the processing of personal data to data processors, Scandinavian Capital Association K/S ensures that said company as a minimum applies the same degree of data protection as Scandinavian Capital Association K/S. If this cannot be guaranteed, Scandinavian Capital Association K/S will choose another data processor.

3.3. Data processing agreements

3.3.1. Prior to transfer of personal data to the data processor, Scandinavian Capital Association K/S shall enter into a written data processing agreement with the data processor. The data processing agreement ensures that Scandinavian Capital Association K/S controls the processing of personal data, which takes place outside Scandinavian Capital Association K/S for which Scandinavian Capital Association K/S is responsible.

3.3.2. If the data processor/sub-data processor is located outside the EU/EEA, the conditions of clause 3.4.4 below will apply.

3.4. Disclosure of personal data

3.4.1. Before disclosing personal data to others, it is the responsibility of Scandinavian Capital Association K/S to consider whether the recipient is employed by us or not. Furthermore, we may only share personal data within Scandinavian Capital Association K/S if the disclosure is based on a legitimate business purpose.

3.4.2. It is Scandinavian Capital Association K/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.

3.4.3. Scandinavian Capital Association K/S must show caution before sharing personal data with persons, data subjects or entities outside of Scandinavian Capital Association K/S. 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.

3.4.4. 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 Scandinavian Capital Association K/S and the third party. The transfer agreement shall be based on the EU Standard Contractual Clauses.

4. Rights of the data subjects

4.1. Duty of information

4.1.1. When Scandinavian Capital Association K/S collects and registers personal data on data subjects, Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S, 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 Scandinavian Capital Association K/S intends to transfer personal data to a third country 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 Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S 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.

4.2. Right to access

4.2.1. Any person whose personal data Scandinavian Capital Association K/S is processing, including but not limited to, Scandinavian Capital Association K/S employees, job applicants, external suppliers, clients, potential clients, business partners, etc. has the right to request access to the personal data which Scandinavian Capital Association K/S processes or stores about him/her.

4.2.2. If Scandinavian Capital Association K/S 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.

4.3. The data subject shall have the right to obtain from Scandinavian Capital Association K/S without undue delay the rectification of inaccurate personal data concerning him or her.

4.4. The data subject shall have the right to obtain from Scandinavian Capital Association K/S the erasure of personal data concerning him or her and Scandinavian Capital Association K/S 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.

4.5. The data subject shall have the right to obtain from Scandinavian Capital Association K/S restriction of processing, if applicable.

4.6. The data subject shall have the right to receive the personal data registered in a structured and commonly used and machine-readable format.

4.7. 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.

4.8. 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 Scandinavian Capital Association K/S Service Center. The Service Center will be supported by the Scandinavian Capital Association K/S Data Protection Officer to process the request to meet the reply deadline.

5. Data Protection by Design and Data Protection by Default

5.1. 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.

5.1.1. Data protection by design means that when designing new products or services, key considerations to data protection must be shown.

• Scandinavian Capital Association K/S 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.
• Scandinavian Capital Association K/S 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.

5.1.2. Data protection by default requires that relevant data minimization techniques are implemented.

a) Scandinavian Capital Association K/S 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.

b) This minimization requirement applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility.

c) Such measures shall ensure that by default, personal data is not made accessible without careful consideration.

6. Records of processing activities

6.1. Scandinavian Capital Association K/S shall as data controller maintain records of processing activities under Scandinavian Capital Association K/S responsibility. The records shall contain the following information:

• name and contact details;
• the purposes of the processing;
• a description of the categories of data subjects and of the categories of personal data;
• the recipients to whom the personal data have been or will be disclosed, including recipients in third countries or international organisations;
• where applicable, transfers of personal data to a third country, including the identification of that third country and, if relevant, the documentation of suitable safeguards;
• where possible, the envisaged time limits for erasure of the different categories of data;
• where possible, a general description of the applied technical and organisational security measures.

6.1.1. Scandinavian Capital Association K/S shall make the records available to relevant data protection authorities upon request.

7. Deletion of personal data

7.1. Personal data shall be deleted when Scandinavian Capital Association K/S 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.

7.2. Detailed retention periods with respect to various categories of personal data are specified in Scandinavian Capital Association K/S Data Retention and Information Sharing policy.

7.3. In compliance with privacy regulation, Scandinavian Capital Association K/S clients/potential clients have the right to request personal information relating to their account with Scandinavian Capital Association K/S be deleted or anonymised when their client relationship with Scandinavian Capital Association K/S has ended.

7.4. Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S systems is regulated by a wide range of various legal requirements such as the Financial Business Act, bookkeeping rules, consumer protection etc.

7.5. 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.

7.6. For Scandinavian Capital Association K/S potential clients, personal data relating to their engagement with Scandinavian Capital Association K/S 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.

7.7. Personal information about Scandinavian Capital Association K/S clients/potential clients who have incurred a loss to Scandinavian Capital Association K/S may be stored for a longer period of time to protect Scandinavian Capital Association K/S from further loss or for the purpose of pursuing a legitimate financial claim.

7.8. After any such period as stated above, Scandinavian Capital Association K/S will permanently delete or anonymise all personal data.

8. Assessment of risk

8.1. If Scandinavian Capital Association K/S 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.

8.1.1. A DPIA implies that Scandinavian Capital Association K/S 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.

8.2. The technical and organisational measures shall be reviewed and updated where necessary and no later than every 6 months.

8.2.1. 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.

9. Profiling

9.1. “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. Scandinavian Capital Association K/S may use profiling in the following circumstances:

• To help identify potential cases of financial crime;
• To provide clients and leads with information on Scandinavian Capital Association K/S products and services that seem likely to be of their interest;
• To assess creditworthiness.

10. National requirements

10.1. Scandinavian Capital Association K/S shall comply with both the GDPR and national data protection legislation.

10.2. If national legislation requires a higher level of protection for personal data than the GDPR, such stricter requirements are to be complied with. If Scandinavian Capital Association K/S policies/guidelines are stricter than the local legislation, our policies/guidelines must be complied with.

11. Contact and complaints

11.1. If you have any questions regarding the content of this policy, please contact Scandinavian Capital Association K/S at support@scadk.finance.

11.2 If you would like to file a complaint about Scandinavian Capital Association K/S processing of personal data, please contact the Denmark Data Protection Agency.

Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S.

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 Scandinavian Capital Association K/S. Any non-monetary assets held in custody (management) in Scandinavian Capital Association K/S, have Estimated values that determine the amount of financial responsibility of the Scandinavian Capital Association K/S. Such estimated values are signed by the Scandinavian Capital Association K/S and the client, together with the Grounds on which they are transferred.

The format of the Estimated Cost document is determined by the Scandinavian Capital Association K/S 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 Scandinavian Capital Association K/S and the client, governing the administrative and business relations of the Scandinavian Capital Association K/S and the client.

Trading in the products and services of the SCA 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 SCA 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.

No recommendations

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

No Representation, No Warranty

The SCA 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 SCA GROUP disclaims liability for any Publication not being complete, accurate, suitable and relevant for the recipient.

The Publications of the SCA 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 SCA GROUP gives no guarantee against, and assumes no liability towards any recipient for, a Publication being outdated.
If a Publication becomes outdated the SCA 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 SCA GROUP.

The SCA 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).

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 SCA 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. SCA employs back up systems and contingency plans to minimize the possibility of system failure, and trading via telephone is available.

Use of The Website

Any use of the SCA GROUP websites is subject to SCA “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 SCA 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 SCA 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 SCA GROUP does not constitute a customer relationship and the SCA 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 SCA GROUP.

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 Scandinavian Capital Association K/S until we’ve had 90 days to resolve the issue

Scope

Scadk.finance
Simulation SCAPortalPRO
Simulation SCAPortalOpenAPI

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.

SCA 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 SCA GROUP of applicable laws, policies, guidelines, SCA GROUP 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.scadk.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 complaints@scadk.finance.