When using
our services we process personal data of our customers (“you”, “your”
or the “Customer”). This Privacy Policy (the “Policy”) provides
you with information about how your data are processed.
In this
Privacy Policy, you will find information regarding the following:
- Who is the controller of your
personal data and whom to contact?
- What information do we collect
about you and how do we obtain it?
- How do we use your personal
data?
- How do we store personal data
and how are they secured?
- To whom do we make your
personal data available?
- Do we transfer your data to
third countries and international organisations?
- What are your rights and how
can you exercise them?
1. WHO IS
THE CONTROLLER OF YOUR PERSONAL DATA AND WHOM TO CONTACT?
The controller of personal data is Rovelata
Finance Limited, a legal entity organized as a private company limited by
shares, with its registered office at 5 Brayford Square, London, England, E1
0SG, Company Number 1606485, sic
codes: 66190 ((hereinafter referred to as “we”, “our”,
“our Company”, or “Controller “)
You can contact Rovelata Finance Limited at 5
Brayford Square, London, England, E1 0SG, or at [email protected] regarding any
questions and the exercise of rights relating to the processing of your personal
data.
2. WHAT
INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE OBTAIN IT?
In this section, you can read general
information about which of your personal data we collect and how we
collect it. Detailed information on the purposes for which we process personal
data is given in Section 3 of this Policy. All information on the basis of
which we can directly or indirectly identify you or which is related to you is
considered personal data.
We obtain most of the data we collect about you
directly from you in connection with your use of our services. This
includes, in particular:
- Data
that you provide to us yourself, especially when you register on the
website, enter information into your user account, order services,
participate in our events and projects, or when you communicate with us
through customer support or social networks. These are identification
and contact data, specifically the name, surname, telephone number, e‑mail
address, postal address, date of birth, user name and password, and
business identification number or tax registration 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
that we automatically collect when you use our services. These are data
about your device (such as the IP address, device type, operating
system, browser used, connection provider); website usage data (such
as the date, time and duration of visit, a country from which you visit
the website, website browsing history), and data on the use
of services (such as the login and logout information, your
account settings, the value of your fictitious capital, your account
currency, business strategy).
Some data about you is provided to us by third
parties, such as providers of trading platforms that you choose for use of our
services, and social network operators if you decide to link your social
networking accounts to an account on the website. This includes:
- Data
about the simulated transactions you have completed (such as the type of
financial instrument, time of opening and closing the position, amount of
investment, profit and loss) and data from social networks (user
name, profile picture, e-mail address associated
with the account on the social network). For information on how
your personal data are processed by trading platform providers and social
network operators for their own purposes, please refer to the privacy
policies of those parties.
3. HOW DO WE USE YOUR PERSONAL DATA?
We use personal data for the following
purposes:
- Registration and user account
In order to use the services, you must register
on the website and create your account, and for this purpose we process your
personal data.
Personal data: identification and contact data; we may also
process your data related to the settings of your user account.
Legal ground for the processing: Processing is necessary for the
performance of the contract, and the provision of these personal data is
required, as we cannot register your user account without them.
- Provision
of services and exercise of rights and obligations under the contract
between us and the customer
In order to be able to provide you with our
services, i.e. 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 shall apply:
Personal data: Identification and contact data and, in the
case of paid services, also payment data, data on the use of the services, data
on the simulated trades and, if you decide to link your social networks
accounts with the account on the website, also data from social networks.
Legal ground for the processing: Processing is necessary for the
performance of the contract on the basis of which we provide our services, or
on the basis of our legitimate interest. After we stop providing you with
services, we process personal information for a limited period of time. Such
processing is necessary for the purposes of exercising and protecting our
rights based on our legitimate interests.
- Marketing
communication about our services and products or about events in
which we take part
If you are our current or past customer, we may
from time to time send you marketing communications that relate
to our services. We may also send you commercial communications to
the extent to which you give us your consent. Each of the e-mails sent will be
marked as a business communication and each of them will contain a link
with the help of which you can easily unsubscribe from the business
communications. For this purpose, the following shall apply:
Personal data: Identification and contact data.
Legal ground for the processing: If we have provided you with our
services, we may from time to time send you marketing communications 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,
then we process your data on the basis thereof.
- Customer support and communication
If you use our customer support services, we
will process your personal data. For this purpose, the following shall
apply:
Personal data: Identification data, contact data, other data
and data from social networks, if you contact us through social networks.
Legal ground for the processing: Processing is based on our
legitimate interest, namely in maintaining customer satisfaction and supporting
the use of our services.
- Improving services
If you use some of our services, we will
process your personal data in order to develop, test and enhance the
services and improve their security. For this purpose, the following shall
apply:
Personal data: Identification and contact data, data about
your device, website usage data, data on the use of the services, and data on
the simulated trades.
Legal ground for the processing: Processing is based on our
legitimate interest, namely in improving our services.
- Analytics
To obtain information about how our website and
our services are used, we analyse customer behaviour. For this purpose, the
following shall apply:
Personal data: Identification data, contact data, payment
data, data about your device, website usage data, data on the use of the
services, and data on the simulated trades.
Legal ground for the processing: Processing is based on our
legitimate interest, namely in ascertaining customer behaviour and estimating
customer preferences.
4. HOW DO WE STORE PERSONAL DATA AND HOW ARE
THEY SECURED?
We process your personal data in an encrypted
database on computers and other devices. In order to ensure protection against
unauthorised access or unauthorised alteration, disclosure or destruction of
the data that we collect and process, we have adopted organisational and
technical measures to secure them, which we strictly adhere to.
5. HOW LONG DO WE PROCESS YOUR DATA?
Personal data are processed to the extent
necessary to fulfil the purposes described above
and for the time necessary to achieve those purposes or for a
period directly stipulated by law. Thereafter, the personal data are deleted or
anonymised. We process personal data for the following periods of time:
- for
the purpose of performance of the contract and for the exercise of rights
and obligations in connection with the contract, including any complaints,
settlement of damage claims or related litigation, personal data are
processed for the necessary period of time, but not more than 10 years
from the termination of the last contract;
- for
the purpose of sending business communications without your given consent,
personal data are processed for a maximum of 5 years from the expiry of
the last contract between us or until you raise an objection or
unsubscribe from the business communications;
- for
the purpose of enhancing our services, we usually process personal data
for a maximum period of 6 months;
- in
order to fulfil our legal obligations, we process personal data for the
period set out by the relevant legal regulations (e.g. in
accordance with tax regulations for a period of 10 years from
the issuance of the relevant documents for your order);
- if
you have given your consent, for the period specified in the consent.
6. DATA SHARING AND TRANSFERS TO THIRD
COUNTRIES
We make your data available or transfer them to
persons that help us provide our services, in particular the following persons:
- The
trading platform provider, in order to enable you to perform the simulated
trades.
- Other
third parties that help us run our website and provide 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 communication agencies, consultants and
postal service providers);
In addition, we may transfer your data to
persons in respect of which you give your consent thereto, as well as in the
cases where it is our obligation under the law or under a judicial or any other
legally binding decision. Each such entity to whom personal data are
transferred is contractually obligated to protect your personal data in
accordance with legal provisions and to process the data exclusively according
to our instructions.
Certain third parties collect personal data for
their own purposes as controllers. In such a case, their own rules for the
processing of personal data shall apply.
7. YOUR RIGHTS
You can exercise all your rights mentioned
below, including your right to erasure of personal data and the withdrawal of
your consent, by sending a request to us via email at [email protected], alternatively you can use our
contact details in Section 1 of this Privacy Policy. There are no specific
words that you must use in your request, but please be specific enough, so we
can help you with your request (e.g. identify yourself, specify the right you
wish to exercise, what action you wish us to take, details of what personal
data you want erased/deleted, etc.)
In connection with the processing of personal
data you have the following rights:
- Right
of access to personal data
You can ask us at any time to send you a
confirmation as to whether or not your personal data are being processed. If we
process your data, we will provide you with further details on the processing.
If you request it, we will also provide you with a copy of the personal data
processed. Please note that the first copy is free of charge, but later copies
will be provided for a small fee.
- Right
to rectification of personal data
If we process your personal data inaccurately,
you can notify us of this fact, and we will rectify the inaccurate
personal data without undue delay. If you register on the Website, you will be
able to rectify and amend your personal data yourself by editing your user
account.
- Right
to erasure of personal data (“right to be forgotten”)
You have the right to obtain from us the
erasure of personal data concerning you without undue delay in the following
cases:
- If
the data are no longer necessary in relation to the purposes for which we
have collected or otherwise processed them;
- If
you withdraw your consent to their processing and, at the same time, there
will be no other legal ground for their processing (this only
applies in the cases where we process personal data on the basis of your
consent);
- If
you object and there are no overriding legitimate grounds for the
processing, or if you object to the processing for direct
marketing purposes; or
- If
your personal data are processed unlawfully.
We will not be able to act on the request for
the erasure of personal data if their processing is necessary for exercising
the right of freedom of expression and information, for compliance with any of
our legal obligations, for the performance of a task carried out in the public
interest, for the establishment, exercise, or defence of our legal claims, or
for other reasons provided for by law.
- Right to restriction of processing
In cases stated in article 18 of the GDPR, you
have the right to obtain from us restriction of processing of your personal
data for a certain period.
- Right
to data portability and to the provision of data in a machine-readable
format
In the case of automated processing based on
your consent or performance of the contract, you have the right to receive the
data in a structured, commonly used and machine-readable format
and to have them transmitted by us to another personal data
controller.
- Right to object
If we process personal data on the basis of our
legitimate interest, you have the right to object to such processing. If
you file such an objection, we will not be able to process your personal data
unless we demonstrate compelling legitimate grounds for the processing which
override your interests or rights and freedoms, or for the establishment,
exercise or defence of our legal claims.
In case we process your personal data for
marketing purposes about our products and services, we will terminate the
processing without undue delay upon receipt of the 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 processing is based on your consent, you
have the right to withdraw that consent at any time. Withdrawal of consent does
not affect the lawfulness of processing based on the consent given before its
withdrawal.
- Right
not to be the subject of automated decision-making
Except where processing is necessary for
entering into, or performance of, a contract, where this is permitted by
applicable law, or based on your express consent, you have the right not to be
the subject of any decision which is based solely on automated processing,
including profiling, which produces legal effects concerning you or
similarly affects you to a significant extent.
- Right
to lodge a complaint with the supervisory authority
If you believe that we are processing your data
in violation of the relevant legal regulations, you can lodge a complaint with
the relevant supervisory authority. You have the right to make a complaint at
any time to the Information Commissioner’s Office (ICO), the UK supervisory
authority for data protection issues (www.ico.org.uk).
8. FINAL PROVISIONS
We may change this policy unilaterally, but we
will do so only when necessary and we will notify you about such change. You
can find the latest version of this policy in your Client Section.