Privacy & Policy

  • 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



    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.