Privacy Policy

INTRODUCTION

This Privacy Policy (“Policy”) outlines the privacy practices employed by Take Profit s.r.o., with registration number 06923020, located at Rybná 716/24, Staré Město, 110 00 Praha 1, Czech Republic (“Take Profit”), and jointly by L.F. Investment Limited, headquartered at Louki Akrita 11, Germasogeia 4044, Limassol, Cyprus (“L.F. Investment”) (collectively referred to as the “Joint Controllers”). The Joint Controllers provide educational, presentation, and supportive services, trading signals, tools for real investment, trading SW, and other inputs to customers, including potential service providers, referred to as “you” or “Client.”

For corporate clients, the Joint Controllers process personal data of directors, shareholders, and/or employees as needed.

INFORMATION WE COLLECT

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.

1. IMPORTANT INFORMATION AND WHO JOINT CONTROLLERS ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to inform you about how Joint Controllers collect and process your personal data when you use Take Profit’s website or affiliated websites, including any data provided during seminar/webinar sign-up or registration. These websites are not intended for children, and Joint Controllers do not knowingly collect data related to children.

It is crucial to read this privacy notice alongside any other notices Joint Controllers may provide on specific occasions when collecting or processing your personal data. This notice supplements other notices and does not override them.

CONTROLLER

Joint Controllers act as controllers and are responsible for your personal data. A data protection officer (DPO) oversees questions related to this privacy notice. Ensure that Joint Controllers are informed of any changes to your personal data during your relationship with them.

THIRD-PARTY LINKS

This website may contain links to third-party websites, plug-ins, and applications. Clicking these links may allow third parties to collect or share data about you. Joint Controllers do not control these third-party websites and are not responsible for their privacy statements. When leaving the website, it’s advised to read the privacy notice of every visited website.

2. THE DATA COLLECTED ABOUT YOU

Personal data refers to information that can identify an individual. It excludes anonymous data where identity has been removed.

Joint Controllers may collect, use, store, and transfer various personal data about you, grouped as follows:

Identity Data: First name, last name, username, or similar identifier.
Contact Data: Email addresses and telephone numbers.
Technical Data: Internet protocol (IP) address, login data, browser type, version, time zone setting, location, browser plug-in types, versions, operating system, platform, and device technology.
Profile Data: Username, password, interests, preferences, feedback, and survey responses.
Usage Data: Information about how you use the website, products, and services.
Marketing and Communications Data: Preferences for receiving marketing from Joint Controllers and third parties, and communication preferences.

Joint Controllers also collect, use, and share Aggregated Data, such as statistical or demographic data, derived from personal data but not considered personal data under the law. Aggregated Data may be used for various purposes.

While Joint Controllers do not collect Special Categories of Personal Data about you, nor information about criminal convictions and offenses, you may receive organizational and commercial messages and/or calls related to services. You can opt out of marketing communication through provided channels.

If you do not proceed with opening a Trading Account with L.F. Investment or a demo/training account, L.F. Investment will erase your personal data as applicable.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

The acquisition of your personal data by Joint Controllers involves various methods, such as:

Direct interactions: You may provide your personal data by completing forms or corresponding through post, phone, email, or other means. This encompasses information submitted when applying for services, creating an account on the website, participating in competitions, promotions, surveys, or providing feedback.
Automated technologies or interactions: Joint Controllers may automatically gather Technical Data about your equipment, browsing behavior, and patterns as you engage with the website. This is achieved through the use of cookies, server logs, and similar technologies. Additionally, Joint Controllers may receive Technical Data from other websites utilizing cookies.
Other public sources: Information about your potential status as a politically exposed person or the appearance on a sanction list may be obtained from public sources. Joint Controllers utilize this information to detect misuse, especially fraud.

4. HOW JOINT CONTROLLERS USE YOUR PERSONAL DATA

Joint Controllers will utilize your personal data in accordance with the law, primarily in the following scenarios:

Performance of a contract or in preparation for entering into a contract with you.
Pursuit of Joint Controllers’ legitimate interests (or those of a third party) when such interests do not override your fundamental rights and interests.
Compliance with legal or regulatory obligations.
Consent granted by you when freely given, specific, informed, and unambiguous (if applicable).

In general, Joint Controllers do not primarily rely on consent for processing personal data, except for third-party direct marketing communications via email or text message. Consent is also sought if you choose to extend the period for receiving marketing, as outlined herein. You retain the right to withdraw consent for marketing at any time by contacting them.

PURPOSES FOR WHICH JOINT CONTROLLERS WILL USE YOUR PERSONAL DATA

Joint Controllers have detailed the intended uses of your personal data in a table format, along with the legal bases they rely on for each purpose. The table also identifies the relevant legitimate interests where applicable.

It’s important to note that Joint Controllers may process your personal data based on more than one lawful ground, depending on the specific purpose. For details on the specific legal grounds, especially when multiple grounds are indicated in the table below.

Please be aware that Joint Controllers may process your personal data based on multiple lawful grounds, depending on the specific purpose for which they are utilizing your data. If you require details about the specific legal basis upon which Joint Controllers rely to process your personal data (especially when more than one ground is specified in the table below).

Regarding legitimate interest (article 6 (1) f GDPR), Joint Controllers may process your data beyond the actual contract performance to protect their legitimate interests or those of third parties.

Legitimacy is determined by:

Identification of legitimate interest (thoroughly analyzed and identified as most appropriate)
Conducting a necessity test (data processing necessary to fulfill a specified purpose)
Performing a balancing test (ensuring legitimate interest does not override individual’s rights and freedoms, respecting proportionality)

MARKETING

Joint Controllers aim to offer choices regarding personal data use, particularly concerning marketing and advertising.

L.F. Investment is authorized to send commercial newsletters or telemarketing calls under the conditions of directive 2002/58/EC. However, you can easily reject such marketing communication through the opt-out button in the newsletter, using the contact form.

THIRD-PARTY MARKETING

Joint Controllers will seek your express opt-in consent before sharing your personal data with any company outside L.F. Investment Limited group of companies for marketing purposes.

OPTING OUT

You can request Joint Controllers or third parties to stop sending you marketing messages at any time. This can be done by logging into the website and adjusting your marketing preferences or by following the opt-out links in marketing messages.

CHANGE OF PURPOSE

The Joint Controllers will utilize your personal data solely for the purposes for which it was initially gathered, unless they reasonably determine the necessity to employ it for another purpose that aligns with the original intent.

In the event that the Joint Controllers find it necessary to use your personal data for an unrelated purpose, they will inform you and provide an explanation of the legal basis permitting such usage. It is important to be aware that, in accordance with the aforementioned guidelines, the Joint Controllers may process your personal data without your knowledge or consent when mandated or allowed by law.

5. DISCLOSURES OF YOUR PERSONAL DATA L.F.

L.F. Investment may need to share your personal information with third parties, such as Introducing Brokers, Tied Agents, Affiliates, etc., in order to carry out services. In the event of such sharing, Joint Controllers will carefully review the matter.

L.F. Investment mandates that all third parties treat your personal data with utmost security and adhere to legal guidelines. Joint Controllers do not permit third-party service providers to use your personal information for their own purposes. They only authorize the processing of your personal data for specific purposes and in accordance with provided instructions.

Service providers and various agents involved may receive data for these purposes while maintaining business confidentiality. These entities offer services such as IT, logistics, printing, legal and accounting services, telecommunications, consulting, as well as sales and marketing.

Regarding the transfer of data to recipients outside joint controllers, it is crucial to note that as an investment service provider, Joint Controllers commit to keeping all customer-related information confidential. Joint Controllers may only disclose your information under specific conditions, such as legal requirements, your consent, or if they are otherwise authorized. In cases of legal or regulatory obligations, recipients of personal data may include public bodies and institutions (e.g., regulatory authorities, tax authorities, law enforcement authorities).

Other recipients of data may include those for whom you have provided consent for data submission or those to whom Joint Controllers may delegate personal information due to legitimate interests.

6. INTERNATIONAL TRANSFERS:

Joint Controllers may, on specific occasions related to the provision of services, find it necessary to transfer your personal data outside the European Economic Area (EEA). In the event of such transfers, they ensure an equivalent level of protection by implementing at least one of the following safeguards:

Personal data is only transferred to countries that the European Commission has deemed to offer an adequate level of protection for personal data.
In cases where specific service providers are utilized, Joint Controllers may employ contracts approved by the European Commission, ensuring that personal data receives the same protection as in Europe.
If Joint Controllers engage providers based in the US, data may be transferred to them under the Privacy Shield framework, which obligates them to provide comparable protection to personal data shared between Europe and the US.

7. DATA SECURITY:

The Joint Controllers have implemented suitable security measures to safeguard against unintentional loss, unauthorized use or access, alteration, or disclosure of your personal data. Furthermore, access to your personal data is restricted to employees, agents, contractors, and other third parties with a legitimate business necessity. These individuals will process your personal data solely based on explicit instructions and are bound by a duty of confidentiality.

Procedures have been established by the Joint Controllers to address any suspected breaches of personal data, and they commit to notifying you and any relevant regulatory authorities in cases where legal obligations dictate such notifications.

8. DATA RETENTION:

HOW LONG WILL JOINT CONTROLLERS RETAIN MY PERSONAL DATA?

Joint Controllers will keep your personal data only for the duration necessary to fulfill the purposes for which it was collected. This includes meeting legal, accounting, or reporting obligations.

To determine the suitable retention period for personal data, Joint Controllers take into account factors such as the quantity, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for processing the data, alternative means to achieve those purposes, and relevant legal requirements. According to the law, Joint Controllers must retain basic customer information (Contact, Identity, Financial, and Transaction Data) for five years after the customer relationship ends for regulatory purposes.

Under certain circumstances, you can request the deletion of your data (refer to the “Request erasure” section for details). Additionally, Joint Controllers may anonymize your personal data for research or statistical purposes, rendering it unassociated with you and allowing its indefinite use without further notice.

If the processing of your personal data relies on consent, the retention period may vary based on the specific purpose.

For service providers, the processing of their personal data continues for five years after they cease providing services.

Evidence preservation for other purposes is within the statutory limitation period. Personal data in emails, chats, phone calls, and other forms of remote communication may be processed for up to five years, aligned with the specified purpose.

9. YOUR LEGAL RIGHTS:

In specific situations, you possess certain rights under data protection laws regarding your personal data:

You can request access to your personal data, commonly referred to as a “data subject access request.” This allows you to obtain a copy of the personal data held by Joint Controllers, ensuring that they are processing it lawfully.
You have the right to request the correction of any incomplete or inaccurate personal data held by Joint Controllers. While they may need to verify the accuracy of the new information you provide, corrections will be made accordingly.
The right to request the erasure of your personal data allows you to ask Joint Controllers to delete or remove data when there’s no valid reason for continued processing. This includes situations where you’ve successfully objected to processing, processing has been unlawful, or erasure is required to comply with local law. However, legal constraints may prevent full compliance, and you will be informed of such reasons.
You can object to the processing of your personal data if Joint Controllers rely on legitimate interests or if the processing affects your fundamental rights and freedoms. This right also extends to cases where your data is processed for direct marketing. Joint Controllers may, however, demonstrate compelling legitimate grounds for processing that override your objections.
Requesting a restriction on the processing of your personal data allows you to suspend processing in various scenarios, including verifying data accuracy, addressing unlawful use without erasure, retaining data for legal claims, or verifying overriding legitimate grounds for use despite your objection.
You can request the transfer of your personal data to yourself or a third party in a structured, commonly used, machine-readable format. This right applies to automated information you initially consented to or when data was used to fulfill a contract with you.
You have the right to withdraw consent at any time when Joint Controllers rely on consent for processing your personal data. However, this won’t affect the lawfulness of processing before withdrawal. Note that withdrawing consent may impact the provision of certain products or services, and Joint Controllers will inform you accordingly.

NO FEE USUALLY REQUIRED

You won’t be charged for accessing your personal data or exercising any of your other rights. However, if your request is deemed clearly unfounded, repetitive, or excessive, Joint Controllers may impose a reasonable fee. In such cases, Joint Controllers also reserve the right to decline your request.

CHILDREN’S PRIVACY

Joint Controllers ensure that no information is knowingly collected from individuals under the age of 15. The websites, products, and services are intended for individuals aged 15 or older. If you are under 15, refrain from using these websites or providing any information through their features. Avoid registering on the websites, making purchases, or disclosing personal information such as your name, address, telephone number, or email address. In the event that Joint Controllers become aware of collecting personal data from a child under 15, they will promptly delete that information.

WHAT JOINT CONTROLLERS MAY NEED FROM YOU

Joint Controllers might require specific details from you to verify your identity and validate your entitlement to access your personal data (or exercise any other rights). This serves as a security precaution to prevent the unauthorized disclosure of personal data to individuals without the right to receive it. Additionally, Joint Controllers may reach out to you for additional information related to your request to expedite their response.

TIME LIMIT TO RESPOND

The Joint Controllers strive to address all valid requests within a month. However, if your request is especially intricate or if you’ve submitted multiple requests, there might be instances where the response time exceeds a month. In such situations, the Joint Controllers will inform you and provide regular updates.