ironwavecapital Privacy Policy
When using our services, we process the personal data of our customers (“you”, “your” or the “Customer”). This privacy policy (the “Policy”) informs you about how your data is processed.
In this privacy policy you will find information on the following:
- Who is responsible for your data and who can you contact?
- What information do we collect about you and how do we obtain it?
- How do we use your data?
- How do we store personal data and how is it secured?
- Who do we make your data available to?
- Do we transfer your data to third countries and international organizations?
- What rights do you have and how can you exercise them?
1. WHO IS RESPONSIBLE FOR YOUR DATA AND WHO CAN YOU CONTACT?
The controller of personal data is ironwavecapital EDUCATION MARK LIMITED, business ID 15495042, with registered office at 20 Wenlock Road, London, N1 7GU, GB-ENG, United Kingdom (hereinafter referred to as “we”, “our”, “our company” or “controller”).
You can contact ironwavecapital EDUCATION MARK LIMITED at 20 Wenlock Road, London, N1 7GU, GB-ENG, United Kingdom or at privacy@test.ironwavecapital.com if you have any questions or wish to exercise your rights in relation to the processing of your data.
2. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE OBTAIN IT?
In this section you can read general information about what data we collect from you and how we collect it. For detailed information about the purposes for which we process personal data, please see section 3 of this policy. Any information that allows us to identify you, directly or indirectly, or that relates to you is considered personal data.
Most of the information we collect about you comes directly from you as part of your use of our services. This includes in particular:
- Data that you provide to us yourself, in particular when you register on the website, enter information in your user account, order services, participate in our events and projects or communicate with us via customer support or social networks. These are identification and contact details, in particular first and last name, telephone number, e-mail address, postal address, date of birth, username and password, as well as the company identification number or tax number if you are an entrepreneur; payment data, such as bank details; and other data, such as records of communication between you and our company or details of any warranty claims.
- Data we collect automatically when you use our services. This is data about your device (such as IP address, device type, operating system, browser used, connection provider); website usage data (such as date, time and duration of visit, a country you visit the website from, website browsing history) and service usage data (such as login and logoff information, your account preferences, the value of your notional capital, your account currency, business strategy).
Some of your information is provided to us by third parties, such as providers of trading platforms you select to use our services and social network operators when you link your social network accounts to an account on the Site. This includes:
- Data about the simulated transactions you have concluded (such as the type of financial instrument, time of opening and closing the position, investment amount, profit and loss) and data from social networks (username, profile picture, email address linked to the social network account). For information on how your personal data is processed by trading platform providers and social network operators for their own purposes, please refer to the privacy policies of these parties.
3. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use personal data for the following purposes:
- Registration and user account
To use the Services, you must register on the Website and create your account. For this purpose, we process your personal data.
Personal data: identification and contact details; we may also process your data in connection with the settings of your user account.
Legal basis for processing: The processing is necessary for the performance of the contract and the provision of this personal data is required because we cannot register your user account without this data.
- Provision of services and exercise of rights and obligations arising from the contract between us and the customer
In order to provide you with our services, in particular to provide you with the relevant access, tools and support and to carry out trades, we need to process your personal data. For this purpose, the following applies:
Personal data: identification and contact details and, in the case of paid services, payment data, data on the use of the services, data on the simulated trading transactions and, if you decide to link your social network accounts to the account on the Website, also data from social networks.
Legal basis for processing: The processing is necessary for the performance of the contract on the basis of which we provide our services or based on our legitimate interests. After we have stopped providing our services to you, we will process personal data for a limited period of time. This processing is necessary for the exercise and protection of our rights based on our legitimate interests.
- Marketing communications about our services and products or about events in which we participate
If you are our current or former customer, we may send you marketing communications about our services from time to time. We may also send you commercial communications, provided you give us your consent to do so. Each of the emails sent will be marked as a commercial communication and will contain a link that will allow you to easily unsubscribe from the commercial communications. For this purpose:
Personal data: identification and contact details.
Legal basis for processing: Where we have provided our services to you, we may send you marketing communications from time to time based on our legitimate interest, namely keeping in touch with our customers. If you give us your consent to process your data for marketing purposes, we will process your data on this basis.
- Customer support and communication
If you use our customer service, we will process your data. The following provisions apply:
Personal data: identification data, contact details, other data and data from social networks if you contact us via social networks.
Legal basis for processing: The processing is based on our legitimate interest, namely maintaining customer satisfaction and supporting the use of our services.
- Improving services
When you use some of our services, we process your data to further develop, test, improve and increase the security of the services. For this purpose, the following applies:
Personal data: identification and contact details, data about your device, data about website usage, data about usage of the services and data about simulated trades.
Legal basis for processing: The processing is based on our legitimate interest, namely the improvement of our services.
- analysis
To obtain information about how our website and services are used, we analyze customer behavior. For this purpose, the following applies:
Personal data: identification data, contact details, payment data, data about your device, website usage data, service usage data and simulated trade data.
Legal basis for processing: The processing is carried out on the basis of our legitimate interest, namely the determination of customer behavior and the assessment of customer preferences.
4. HOW DO WE STORE PERSONAL INFORMATION AND PROTECT IT?
We process your personal data in an encrypted database on computers and other devices. To ensure protection against unauthorized access or unauthorized modification, disclosure or destruction of the data we collect and process, we have taken organizational and technical measures to secure them, which we strictly adhere to.
5. HOW LONG DO WE PROCESS YOUR DATA?
Personal data will be processed to the extent necessary to fulfil the purposes described above and for the time necessary to achieve these purposes or for a period directly specified by law. After this, the personal data will be deleted or anonymised. We process personal data for the following periods:
- For the purpose of performance of the contract and exercise of rights and obligations related to the contract, including any complaints, settlement of claims for damages or related legal disputes, personal data will be processed for the necessary period, but not longer than 10 years after the termination of the last contract;
- For the purpose of sending business communications without your consent, personal data will be processed for a maximum of 5 years from the expiry of the last contract between us or until you object or unsubscribe from receiving business communications;
- To improve our services, we generally process personal data for a maximum period of 6 months;
- In order to comply with our legal obligations, we process personal data for the period provided for by the relevant legislation (e.g. under tax regulations for 10 years from the date of issue of the documents relevant to your order);
- If you have given your consent, for the period specified in the consent.
6. DATA SHARING AND DATA TRANSFER TO THIRD COUNTRIES
We make your data available or transfer it to people who help us provide our services. These are in particular the following people:
- The provider of the trading platform allows you to carry out simulated trades.
- Other third parties who assist us in operating our website and providing our services (such as other companies in our group, hosting and cloud service providers, payment system operators and financial institutions, providers of customer support tools and services, IT companies and system administrators, marketing and communications agencies, consultants and postal service providers);
In addition, we may share your information with people to whom you have given your consent, and in cases where we are required to do so by law or by a court or other legally binding decision. Any entity to which personal information is shared is contractually obliged to protect your personal information in accordance with the law and to process the data exclusively in accordance with our instructions.
Certain third parties collect personal data for their own purposes as data controllers. In such a case, their own rules for the processing of personal data will apply.
7. YOUR RIGHTS
You can exercise any of the rights set out below, including your right to erasure of personal data and to withdraw your consent, by sending us a request via email to privacy@test.ironwavecapital.com . Alternatively, you can use our contact details in Section 1 of this Privacy Policy. There are no specific words you must use in your request, but please be specific enough so that we can help you with your request (e.g., identify yourself, state the right you wish to exercise, what action you would like us to take, specify what personal data you would like to be erased, etc.).
In connection with the processing of personal data, you have the following rights:
- Right to information about personal data
You can always ask us for confirmation as to whether or not your data is being processed. If we are processing your data, we will provide you with further details about the processing. Upon request, we will also provide you with a copy of the personal data being processed. Please note that the first copy is free of charge, but subsequent copies are provided for a small fee.
- Right to rectification of personal data
If we process your data incorrectly, you can inform us and we will correct the incorrect personal data immediately. If you register on the website, you can correct and change your data yourself by editing your user account.
- Right to erasure of personal data (“right to be forgotten”)
You have the right to request that we immediately delete your personal data in the following cases:
- When the data is no longer necessary for the purposes for which we collected it or otherwise processed it;
- If you withdraw your consent to processing and at the same time there is no longer any other legal basis for the processing (this only applies to cases where we process personal data based on your consent);
- If you object and there are no overriding legitimate grounds for the processing or if you object to processing for direct marketing purposes; or
- If your personal data is processed unlawfully.
We cannot comply with the request to delete personal data if their processing is necessary for the exercise of the right to freedom of expression and information, for the fulfillment of one of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise or defense of our legal claims or for other reasons provided for by law.
- Right to restriction of processing
In the cases referred to in Article 18 of the GDPR, you have the right to request that we restrict the processing of your personal data for a certain period of time.
- Right to data portability and provision of data in a machine-readable format
In the case of automated processing based on your consent or the fulfillment of a contract, you have the right to receive the data in a structured, commonly used and machine-readable format and to have us transmit it to another controller.
- Right to object
If we process personal data based on our legitimate interest, you have the right to object to such processing. If you lodge such an objection, we will no longer be able to process your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests or rights and freedoms, or the processing serves to establish, exercise or defend our legal claims.
If we process your data for marketing purposes relating to our products and services, we will stop processing immediately after receiving your objection. In such a case, we will no longer be able to send you offers of our products and services.
- Right to withdraw consent
If the processing is based on your consent, you have the right to withdraw this consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.
- Right not to be subject to automated decision-making
Unless the processing is necessary for entering into or fulfilling a contract, is permitted by applicable law or is based on your explicit consent, you have the right not to be subject to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you.
- Right to complain to the supervisory authority
If you believe that we are processing your data in violation of the relevant legal provisions, you can complain to the competent supervisory authority. Based on our registered office, our competent supervisory authority is the Office for Personal Data Protection, with address 20 Wenlock Road, London, N1 7GU, GB-ENG.
United Kingdom, or send an email to support@test.ironwavecapital.com .
8. FINAL PROVISIONS
We may unilaterally change this policy, but will only do so when necessary and will notify you of any such change. The most recent version of this policy can be found in your Client Area.
