PRIVACY NOTICE FOR MOBILE APPLICATION

Last updated April 12, 2021




INTRODUCTION

ISEC Wealth Management Limited (hereinafter the “Company”, “we”, “us“, “our“), is committed to protect your privacy and handling your data through a transparent manner. The Company understands the importance of maintaining the confidentiality and privacy of your personal data. By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security, and integrity of your Information.

When you use Company’s mobile application (the “App“) and more generally, use any of our services (the “Services“, which include the Website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

For anything not described in this document, the Privacy Notice of our website applies. Please read carefully our Privacy Notice, available at the following address: https://is-wm.com/documents/privacy_policy

As per the relevant sections of the Law 2016/679, if you are a natural person, the Company is the personal data processor and controller of your personal data in relation to the processing activities, which your personal data undergo as stated further below. For the purposes of this statement:

I) Personal Data shall mean any operation or set of operations, which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

II) Controller shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

III) Processor shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;







Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.




PRIVACY NOTICE

This Privacy notice aims to provide you with an overview of how the Company collects and processes your personal data and informs you about your rights under the local data protection law and the EU General Data Protection Regulation (hereinafter the “GDPR”). This statement is directed to natural persons, who are either current or potential clients of the Company. Furthermore, this statement is directed to natural persons, who had a business relationship with the Company in the past. Further to the above, this statement is providing you with information on the Circumstances that the Company may share your personal information with any third party related to the Company, such as payment service providers.




WHO WE ARE

The Company is an authorized firm, established in Cyprus, with registration number ΗΕ 360500. The Company is registered and licensed by the Cyprus Securities and Exchange Commission (hereinafter the “CySEC”) with license number 356/18. If you have any questions or want more details about how the Company uses your personal information, you can contact our Data Protection team at dataprotection@is-wm.com.




COLLECTION OF INFORMATION

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect phone numbers; email addresses; and other similar information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.


Information automatically collected

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information may include device and usage information, such as your IP address, browser and device characteristics, operating system, App version, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.


Information collected through our App

In Short:  We collect information regarding your mobile device, when you use our App.

When you use our App, we also collect the following information:

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, storage and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data. We automatically collect device information such as your operating system or platform, version information and system configuration information, device and application identification numbers, and Internet Protocol (IP) address (or proxy server) and information about the features of our App you accessed.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

 

USE OF THE INFORMATION

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).

To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our App and Service.

For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App and Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

 

TO WHOM THE COMPANY MAY DISCLOSE YOUR INFORMATION

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).




As part of using your personal information for the purposes mentioned above, we may disclose your information to the following parties:

a) Service providers and specialist advisers, who have been contracted to provide us with IT, financial, regulatory, compliance, accounting and/or other services.

b) Tied Agents, with whom the Company has established relationships and who are exclusively working for the Company.

c) Regulatory Authorities.

d) Anyone authorized by you.

e) Relevant authorities to investigate or prevent fraud, money laundering or other illegal activity.

f) Trade Repository or similar.

g) The Company’s employees to exercise their duties in accordance with the Agreement between the Company and yourself. The Company requires from organizations outside the Company, who handle or obtain personal information, to acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all the relevant data protection laws and this privacy notice.




HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

The Company shall keep your personal data for as long as the company has business relationship with you (physical person). Once the business relationship has been ended, we may keep your data for up to five (5) years in accordance with the Laws governing the Company. The Company may keep your personal data for longer than five (5) years for legal, regulatory and/or any other obligatory reason.

Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time..

 

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our App and Services is at your own risk. You should only access the App and Services within a secure environment.




DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

The Company considers a child to be anyone under the age of 18. We do not knowingly seek or collect personal information from or about children.

By using the App and Services, you represent that you are at least 18. If we discover that we’ve accidentally collected information from a child, we will remove that child’s information from our records as soon as feasibly possible. If you become aware of any data, we may have collected from children under age 18, please contact us at https://is-wm.com/contact.




WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

You may inform the Company at any time that your information has changed or that you wish the Company to delete information we hold about you by emailing us at dataprotection@is-wm.com

We will change or delete your information in accordance to your instructions, except to the extent that we are required to hold your information for regulatory or legal purposes, to provide you with the Services you have requested or to maintain adequate business records.

As a natural person you have the right to obtain a copy of any personal information which we hold about you and to advise us of any perceived inaccuracy. Additionally, you may also request the reasoning of holding such information.

To make a request, please contact us, verifying your identity and specifying what information you require. You may contact us via e-mail at dataprotection@is-wm.com




UPDATE OF THIS NOTICE

In Short:  Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.