Privacy Policy
This Privacy Policy
is provided by WALFA, a brand of IT GUARDIA SP Z O.O, with its address at 14 Tuchlauben Vienna, Austria 1010. In this policy,
"WALFA," "we," "us," and "our" refer to
IT GUARDIA SP Z O.O and its subsidiaries within the WALFA group of companies,
located at Ljubotinjskih junaka br 13, Podgorica/Montenegro, unless otherwise
specified. "You" and "your" refer to our valued investors
and potential investors. We highly recommend that you carefully review this Privacy
Policy to understand how we collect, use, and protect your personal data.
Your Privacy
Matters
At WALFA, we are
dedicated to safeguarding and respecting your personal data. This Privacy
Policy outlines how and when we collect, use, and secure your personal data and
the types of information we gather when you choose to use our services. It is
essential that you regularly check this page for updates, as we reserve the
right to modify our privacy policy as necessary. Your personal information is
subject to our most current privacy statement, and we may notify our investors
of any significant changes. If you are an employee or third-party service
provider within the WALFA family, your personal data and contractual
relationships will be managed according to our policies in effect at that time.
About Us
- This Privacy Policy
pertains to the data processing activities of IT GUARDIA SP Z O.O and its
subsidiaries operating under the WALFA brand at the address: 14 Tuchlauben Vienna, Austria 1010
- Collection and
Storage of Personal Information
As part of our
business operations, we collect personal data from customers and potential
customers, including:
- Name, surname, and
contact information
- Date of birth and
gender information
- Information on
income and wealth, including assets, liabilities, account balances, transaction
history, tax and financial statements
- Occupation and
employment details
- Location data
- Data related to
trading risk tolerance and risk profile
- IP address, device
characteristics, and trading experience
- Bank account,
e-wallet, and credit card information
- Information about your visits to the WALFA website or applications, such as traffic data, location data, blogs, and other communication data
Cookies
We use cookies to
collect and store information about your use of the WALFA website. Cookies are
small text files stored on your device's hard drive that, upon accessing the
WALFA site, transmit data to our web server. These cookies allow us to
customize your settings and preferences to enhance your user experience. You
can learn more about our use of cookies in the "Our Cookies Policy"
section on the WALFA website.
Additionally, we
maintain records of your business activities, including:
- Products you trade
with WALFA
- Historical
investment data
- Choices you make
concerning our products or services
- If you are an
institutional investor, you may need to provide additional information, such as
company addresses, shareholder and director details, and other pertinent
information about shareholders and directors.
We reserve the
right to request additional information when necessary to comply with legal and
regulatory requirements. We may also acquire data about our investors from
third-party marketing lists, public sources, social media platforms, brokers,
affiliates, bankers, credit card processors, subscription-based intelligence
databases, and other third parties. At times, we may request additional
personal data through methods like market research, surveys, or special offers.
Please be aware
that if you choose not to provide information needed for a specific product or
service, we may not be able to fulfill your request. Additionally, we may
record electronic or telephone communications regarding the services we provide
to you and our relationship with you. These records remain the property of our
company and serve as evidence of communication between you and WALFA. Phone
conversations may be recorded without a warning tone or other notice.
Furthermore, our offices or facilities may have CCTV cameras to record your
image during visits.
Sharing of Your
Personal Data
For the purposes
outlined above, we may disclose your personal information to:
- Companies providing
financial and other services within the WALFA group
- Third-party
application providers when using WALFA applications, communication systems, and
trading platforms from third parties
- Service providers
and specialist consultants contracted for administrative, IT, analytics, online
marketing optimization, financial, regulatory, compliance, insurance, research,
or other services
- Brokers with whom
we have mutual relationships and those providing promotional services to their
affiliates
- Payment service
providers and banks processing your transactions
- Auditors,
consultants, or contractors overseeing any of our business purposes
- Law enforcement and
government agencies responding to regulatory requests as required by law
- Any third party
necessary for enforcing our Terms of Service and related agreements, as authorized
by you
- We strive to
disclose only the minimum personal data required for fulfilling contractual
obligations to these third parties. Our third-party service providers are not
allowed to share or use the personal data we provide for purposes other than serving
us. Please note that third-party websites linked from our websites or apps are
not covered by this Privacy Policy and do not adhere to our privacy standards
and procedures. To learn about the privacy practices and procedures of third
parties, please visit their respective websites.
When and How Do We
Obtain Your Consent?
We may process your
personal information based on one or more legal grounds defined by our company.
These legal bases include:
- Fulfilling
contractual obligations to investors
- Complying with
legal and regulatory requirements
- Pursuing our
legitimate interests
- In cases where any
of these legal bases do not apply to the use of your personal information, your
consent as an investor is required. You have the right to withdraw your consent
at any time by contacting WALFA using the contact information provided in this
privacy policy.
Management of
Personal Data
At WALFA, we are
committed to safeguarding the personal data that is transmitted, stored, or
otherwise processed. We employ appropriate technical and organizational
measures to protect against accidental or unlawful destruction, loss,
alteration, unauthorized disclosure, and to ensure the necessary level of
security for the personal data entrusted to us.
We have appointed a
Data Protection Officer to ensure compliance with this Privacy Policy and
applicable legislation. We also require anyone with access to personal
information to respect privacy rights and comply with relevant data protection
laws and these privacy statements.
The data protection
measures we implement include:
- Training our
employees on security measures, including the use of two-factor authentication
along with a password when accessing investor information and our systems.
These security measures ensure that our employees only access personal data
required for their specific tasks.
- Using data
encryption technologies for internet transactions.
- Employing
firewalls, intrusion detection systems, and virus scanning tools to protect
client access codes transferred between networks against unauthorized
individuals and viruses.
- Enforcing a clean
desk policy at all facilities that provide secure storage for physical records,
using private secure networks or encryption.
- Using physical and
electronic means like access cards, cameras, and guards to protect against
unauthorized access.
- Retention Period of
Personal Information
We maintain
personal data in secure computer storage facilities and paper-based records.
When we determine that personal data is no longer necessary, we will either
remove details that could identify the investor or securely destroy the
records. However, it may be necessary to retain certain records for an extended
period to comply with investment services and anti-money laundering laws,
regulatory codes of conduct, and other legal requirements. These records are
retained for at least five years after the end of our relationship with you or
longer as required by regulators.
Your data may be
transferred and stored outside the European Economic Area (EEA), and it may be
processed by personnel working outside the EEA who are employed by us, our
suppliers, or our affiliates. We will take all reasonable steps to ensure that
your data is handled securely and in accordance with this Privacy Policy. When
we transfer your data to third parties outside the EEA, we may rely on
applicable standard contractual clauses, binding corporate rules, EU-US Privacy
Shield, or other equivalent regulations in some cases. If you would like a copy
of these regulations, please contact us using the provided contact details.
Investor Rights
While not
applicable in all circumstances, the rights of investors include:
Requesting access
to personal data (commonly known as "Data subject access request").
Requesting the
correction of personal data we hold about you.
Requesting the
deletion of personal data. Note that we may not always comply with your
deletion request due to certain legal reasons, which we will communicate to you
upon request.
Notifying us of
situations where you feel uncomfortable or believe that your personal data is
being processed based on legitimate interests.
Objecting to the
processing of your personal data for direct marketing purposes. In some cases,
we may demonstrate legitimate grounds for processing your information that
outweigh your rights and freedoms.
Requesting the restriction
of the processing of your personal data. This allows you to request that we
suspend the processing of your personal data in certain scenarios, such as when
you question the accuracy of the data or when you object to our use of your
data.
Requesting the
transfer of your personal data to you or a third party. We will provide your
personal data in a structured, commonly used, machine-readable format. Please
note that this right applies only to automated information (not hard copies)
you have consented to be used or that we use to enter into a contract with you.
Withdrawing your consent at any time to process your personal information.
Investor Complaints
and Requests
We strive to
respond to all requests within one month. However, if a request is complex or
excessive, our response time may be longer. In such cases, we will inform you
within one month of receiving the request and provide updates. We may charge a
reasonable fee for requests that are manifestly unfounded, excessive, or
repetitive, or for providing additional copies of the same data. In these
situations, we will send a fee request that you must accept before processing
your request. Alternatively, we may refuse to comply with your request.
If you have any
questions, concerns, or requests related to this Privacy Policy or how we
handle your personal data, please contact us using the information provided
below.
Contact Information
If you have any questions, concerns, or requests related to this Privacy Policy or how we handle your personal data, please contact us at the following address: ul. Mikolaja Kopernika, 30, 415 00-336, Warszawa
We appreciate your
trust in us and are committed to protecting your personal data. Thank you for
choosing WALFA as your trusted partner.