A. Introduction – Purpose of the Policy

When using our services we process personal data of our customers (“you”, “your” or the “Client”). This Privacy Policy (hereinafter the “Policy”) provides you with information about how your data are processed.

In this Privacy Policy, you will find information regarding the following:

• The controller of personal data is Roundwave CY LTD, with its registered office at Kremastis Rodou 62, Limassol, Cyprus. Registration Number: 463387 (hereinafter referred to as “we”, “our”, “our Company” or “Controller”).
  
  You can contact us at support@investingchallenges.com regarding any questions and the exercise of rights relating to the processing of your personal data.
  
  
• We are committed to securing your personal data and your privacy. As part of this commitment, it is important for us to be transparent about how we handle the information that we (or others on our behalf) collect about our users, when we collect information about them, and how we use such information.
  
  
• This Policy provides information regarding the use of data that we collect about the users of the www.investingchallenges.com website and the various services offered by the Company over any of its related products and services. By accessing and using the website or the services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy.
  
  
• This Policy is part of and should be read in conjunction with Our Terms of Service available at www.investingchallenges.com/en/terms-and-conditions.
  
  
• In this Policy, any reference to personal data is to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that we have or that we have access to.

B. Collection of Users’ Personal Data

i). In this section, you can read general information about which of your personal data we collect and how we collect it. All information on the basis of which we can directly or indirectly identify you or which is related to you is considered personal data.

ii).  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, username 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).
  
  

iii).  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. More specifically, 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 (username, 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.

iv). You are not obligated to provide us with any personal data about you. However, in some instances, not providing such personal data will prevent us from providing you with the services you requested us to provide you and will prevent your use of the services or a part thereof.

C. What types of Personal Data do We collect?

We (or others on our behalf) may collect the following types of Clients’ Personal Data:

a). When you register to the hub and the services.: Upon the creation of an account with us, you provide us with certain information that can be used to identify you, including your full name, email address and country of residence, as well as any other information as the Company may deem necessary to collect at the point of registration. While some of the details mentioned above are required fields in the pages of registration, others are not required, but we recommend that you complete them so that we can provide you with the best services we can.

b). When you choose to join the evaluation stage or become a funded user: Whenever you use our services for simulated trading, we collect your trading program, the amount you have invested, payment method for receiving funds and follow your trading behavior and monitor it for our analytical purposes, building trading strategies, evaluation users as well as to fraud prevention.

c). KYC AML information: We may require you to provide us or any other third party on our behalf with additional information for the purpose of compliance with Know-Your-Customer (“KYC”) and Anti-Money Laundering applicable legal requirements and best practices.

d). Communication information: When you contact us, though any channel whatsoever, or when you subscribe to our Newsletter on the website or social media networks, you may provide us with your full name, email address and the content of your communication with us.

e). Website or Services usage information: This information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, crash reports and type of browser used, and information regarding the device you used. Some of this information may not identify you personally, and therefore does not constitute Personal Data.

f). Website or Services activity information: Whenever you use the website, we monitor your use of the website and record your activity. The information that we gather about you in this context includes any activity that you perform in the website or services; please be advised that we may receive your trading data from the services, the length of time you will be watching content on the website, your interaction with content in the website, etc.

g). Aggregate Information: We will also create statistical, aggregated and anonymized data relating to our users and the service for analytical purposes, including business development and services improvements. We will share this aggregate information with our third-party partners. Aggregated data is derived from personal information and user data but in its aggregated form it does not relate to or identify any client or individual or any specific user’s data. This data is used to understand our customer base and to develop, improve and market our Services.

D. The Purposes of The Processing of Personal Data

i). We process your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

ii). We will not process your Personal Data unless there is a legal basis for such processing.

iii). The legal bases according to which the Company may process your Personal Data are as follows:

• Legitimate Interests – Processing is necessary for the purposes of provision of the services, or any other legitimate interests pursued by the Company or by a third party. For example, to improve our services, we will use the data collected during your use of the services to enhance our website or services, or for the exercise or defense of legal claims.
  
  
• Consent – Your consent that the Company will process your Personal Data for one or more specific purposes. For example, for the purpose of sending you marketing materials.

E. How Do We Use Personal Data?

We may use personal data for the following purposes:

• To operate the website and provide the services;
• To contact you for the purpose of operational purposes;
• To personalize content and offers for you;
• To respond to your queries, requests and/or complaints;
• To send you materials regarding the services, events and other information we think will be of interest to you, subject to your consent;
• To analyze and improve the services, as well as to develop and offer new services;
• To analyze and track usage to determine the usefulness or popularity of certain content and to better understand the online activity of the website users;
• Monitor and analyze trends, usage and activities in connection with the services;
• To perform and maintain various activities supporting the offering and provision of the services, including, but not limited to, the services (such activities include back-office functions, business development activities, strategic decision making, financing management, third party services integration etc.);
• To protect our and third parties’ interests, rights and assets, including detecting, investigating and preventing fraudulent transactions or unauthorized or illegal activities and initiation or exercise or defense of legal claims and preventing them;
• To perform KYC checks; and
• To fulfill our legal or regulatory requirements.

F. 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 unauthorized access or unauthorized alteration, disclosure or destruction of the data that we collect and process, we have adopted organizational and technical measures to secure them, which we strictly adhere to.

G. 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 anonymized. 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.

H. Personal Data Sharing and Transfer to Third Parties

We make your personal 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); and
• 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.

I. Cookies and Trackers

• We may use certain third-party services, such as analytics companies or companies delivering advertisements, which may also use cookies or other technologies, and those practices and providers are subject to their own policies.
• For more information regarding the use of cookies in our website please see our cookie policy available at: www.investingchallenges.com/en/cookies-policy.

J. Security

We have implemented suitable security policies, rules and technical measures to protect and safeguard your Personal Data under our control from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction.

K. Links to Other Websites

• The website may contain links to third-party websites and applications. Likewise, other websites and applications may also reference or link to our website. We do not control these third-party websites and applications, nor the collection and processing of Personal Data by these entities. Therefore, we are not responsible for the privacy practices. This Policy does not apply to any actions taken via such websites and applications.
• Whenever you access such third-party websites and applications, we recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data.

L. Clients’ Rights in respect of Personal Data

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 support@investingchallenges.com, alternatively you can contact us via livechat. 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 addition to the processing right of your 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:
  i). If the data are no longer necessary in relation to the purposes for which we have collected or otherwise processed them;
  ii). 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);
  iii). 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
  iv). 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 defense 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 defense 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. Based on our registered office, our relevant supervisory authority is Office of the Commissioner for Personal Data Protection with its address Kypranoros 15, Nicosia 1061 , Cyprus, Tel: +357 22818456, e-mail: commissionerdataprotection.gov.cy. More information about the Office can be found on the following website: https://www.dataprotection.gov.cy/.

M. Transfer of Personal Data to a third country or an international organization

• Clients’ Personal Data may be transferred to a third country (i.e. jurisdictions other than the clients’ residence) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Clients’ Personal Data and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.
• If the client is an EEA resident, please note that these safeguards and protection will be available if any of the following are met:
  i). The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”);
  ii). The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
  iii). The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR.

• The Client may request that the Company provides him with details concerning the safeguards employed by it to protect the Personal Data that are transferred to a third country or an international organization, by sending an email to the following address: support@investingchallenges.com.

N. Changes to the Policy

We may amend the terms of this Policy unilaterally, from time to time. Whenever we amend this Policy, we will notify you of such amendments by publishing the updated Policy on the website. In addition, when we make significant amendments to this Policy, we will strive to inform you about such amendments via means of communication we believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on our website. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our website or the designated page on the website.

O. Contact Details

For any queries relating to this Policy, please contact us at support@investingchallenges.com.