AITrader.cz

Notes to legitimate interest (article 6 (1) f GDPR):
If necessary (and legitimately), Joint Controllers process your data beyond the actual performance of the contract for the protection of legitimate interest of them or third parties.


Legitimacy is considered to match these criteria:
•    Identification of legitimate interest
(Legitimate interest is well analyzed and identified as the most propriate)
•    Carrying out of necessity test
(Processing of the data is necessary for fulfilling specified purpose)
•    Carrying out of balancing test
(The legitimate interest does not, in any way, override individual’s interests, rights or freedoms and respect also proportional test so you might expect to be contacted by us).

MARKETING  
Joint Controllers strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.


L.F. Investment is entitled to send you a commercial newsletter (or give you telemarketing calls) under the conditions of directive 2002/58/EC of the European Parliament and of the Council. In any case, you are entitled to reject such marketing communication simply by (a) opting-out button in the newsletter body, (b) using the contact form, or c) contacting them at the following email dpo@purple-trading.com or info@aitrader.cz.

THIRD-PARTY MARKETING  
Joint Controllers will get your express opt-in consent before Joint Controllers share your personal data with any company outside L.F. Investment Limited group of companies for marketing purposes.

OPTING OUT  
You can ask them or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or] by them at any time at the following email address: dpo@purple-trading.com or info@aitrader.cz.
Third party acting as a controller shall provide you with its own policy.

CHANGE OF PURPOSE  
Joint Controllers will only use your personal data for the purposes for which Joint Controllers collected it, unless Joint Controllers reasonably consider that they need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact them at dpo@purple-trading.com or info@aitrader.cz.


If Joint Controllers need to use your personal data for an unrelated purpose, Joint Controllers will notify you and Joint Controllers will explain the legal basis which allows them to do so. Please note that Joint Controllers may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA  
L.F. Investment may have to share your personal data with third parties (including Introducing Brokers, Tied Agents, Affiliates, etc) for the purpose of carrying out the services but should this be the case Joint Controllers check the issue.


L.F. Investment requires all third parties to respect the security of your personal data and to treat it in accordance with the law. Joint Controllers do not allow third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with instructions.


Our service providers and various agents may also receive data for these purposes if they maintain business confidentiality. These companies deliver IT services, logistics, printing services, legal, accounting, telecommunications and consulting as well as sales and marketing.


With regard to the transfer of data to recipients outside of joint controllers, it should first be noted that as an investment service provider Joint Controllers commit themselfs to secrecy about all customer-related facts and valuations from which Joint Controllers become aware. In principle, Joint Controllers may only disclose information about you if required by statutory provisions, if you have given your consent, or if Joint Controllers are otherwise authorized to provide information. Under these conditions, in the case of a legal or regulatory obligation, recipients of personal data may be public bodies and institutions (e.g. regulatory authorities, tax authorities, law enforcement authorities).


Other data recipients may be those for whom you have given them your consent to submit the data or to whom Joint Controllers may delegate personal information due to legitimate interests.

6.  INTERNATIONAL TRANSFERS  
Joint Controllers might need on certain occasions for the purposes of carrying out the services to transfer your personal data outside the European Economic Area (EEA).
Whenever Joint Controllers transfer your personal data out of the EEA, they ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
•    Joint Controllers will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
•    Where Joint Controllers use certain service providers, Joint Controllers may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
•    Where Joint Controllers use providers based in the US, Joint Controllers may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please Contact them at dpo@purple-trading.com or info@aitrader.cz if you want further information on the specific mechanism used by them when transferring your personal data out of the EEA.
 
7.  DATA SECURITY  
Joint Controllers have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, Joint Controllers limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on their instructions and they are subject to a duty of confidentiality.


Joint Controllers have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where Joint Controllers are legally required to do so.
 
8.  DATA RETENTION  
HOW LONG WILL JOINT CONTROLLERS USE MY PERSONAL DATA FOR?  
Joint Controllers will only retain your personal data for as long as necessary to fulfil the purposes they collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


To determine the appropriate retention period for personal data, Joint Controllers consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which Joint Controllers process your personal data and whether Joint Controllers can achieve those purposes through other means, and the applicable legal requirements. By law Joint Controllers have to keep basic information about customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for regulatory purposes.


In some circumstances you can ask them to delete your data: see Request erasure below for further information. In some circumstances Joint Controllers may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case Joint Controllers may use this information indefinitely without further notice to you.


If the processing of your personal data requires consent, the data retention period may differ according its very purpose.


Processing of personal data of service providers defined above takes five years after they cease being service providers.


Preservation of evidence for other purposes within the statutory limitation period.
Personal data contained in email, chats, phone calls and other means of distant communication might be processed according to the related and relevant purpose specified herein. Processing period might be up to 5 years.

9.  YOUR LEGAL RIGHTS  
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
•    Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data Joint Controllers hold about you and to check that Joint Controllers are lawfully processing it.
•    Request correction of the personal data that Joint Controllers hold about you. This enables you to have any incomplete or inaccurate data Joint Controllers hold about you corrected, though Joint Controllers may need to verify the accuracy of the new data you provide to us.
•    Request erasure of your personal data. This enables you to ask them to delete or remove personal data where there is no good reason for them continuing to process it. You also have the right to ask them to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where Joint Controllers may have processed your information unlawfully or where Joint Controllers are required to erase your personal data to comply with local law. Note, however, that Joint Controllers may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
•    Object to processing of your personal data where Joint Controllers are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where Joint Controllers are processing your personal data for direct marketing purposes. In some cases, Joint Controllers may demonstrate that Joint Controllers have compelling legitimate grounds to process your information which override your rights and freedoms.
•    Request restriction of processing of your personal data. This enables you to ask them to suspend the processing of your personal data in the following scenarios: (a) if you want them to establish the data’s accuracy; (b) where their use of the data is unlawful but you do not want them to erase it; (c) where you need them to hold the data even if Joint Controllers no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to use of your data but Joint Controllers need to verify whether Joint Controllers have overriding legitimate grounds to use it.
•    Request the transfer of your personal data to you or to a third party. Joint Controllers will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for them to use or where Joint Controllers used the information to perform a contract with you.
•    Withdraw consent at any time where Joint Controllers are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, Joint Controllers may not be able to provide certain products or services to you. Joint Controllers will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact  dpo@purple-trading.com or info@aitrader.cz.

NO FEE USUALLY REQUIRED  
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, Joint Controllers may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, Joint Controllers may refuse to comply with your request in these circumstances.
 
CHILDREN’S PRIVACY
Joint Controllers do not knowingly collect any information from anyone under 15 years of age. The websites, products and services are all directed to people who are at least 15 years old or older. If you are under 15, do not use or provide any information on these websites or on or through any of its features / register on the websites, make any purchases through the websites or provide any information about yourself to us, including your name, address, telephone number or email address. If Joint Controllers learn that Joint Controllers have collected or received personal data from a child under 15, Joint Controllers will delete that information.

WHAT JOINT CONTROLLERS MAY NEED FROM YOU  
Joint Controllers may need to request specific information from you to help them confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Joint Controllers may also contact you to ask you for further information in relation to your request to speed up their response.

TIME LIMIT TO RESPOND  
Joint Controllers try to respond to all legitimate requests within one month. Occasionally it may take them longer than a month if your request is particularly complex or you have made a number of requests. In this case, Joint Controllers will notify you and keep you updated.