INVESTAGO (hereinafter referred to as “Investago”) is a registered trademark of WONDERINTEREST TRADING LTD.

WONDERINTEREST TRADING LTD (hereinafter referred to as the “Investment Company”) is committed to protecting your privacy and handling your data in a transparent manner. The Investment 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 keeping this information private. We have taken measurable steps to protect the confidentiality, security, and integrity of your information.

The purpose of this Privacy Policy is to provide you with an overview of how the Investment Company collects and processes your personal data and to inform you of your rights under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation – “GDPR”), as well as the Law on the Protection of Natural Persons with regard to the Processing of Personal Data and the Free Movement of such Data of 2018 (Law 125(I)/2018) (hereinafter the “Laws”), as amended. This statement is intended for natural persons who are current, former, or potential clients of the Investment Company and their representatives (such as lawyers acting on their behalf).

The Investment Company is an authorized company based in Cyprus, under registration number 332830.

The Investment Company is registered and licensed by the Cyprus Securities and Exchange Commission (hereinafter “CySEC”) with license number 307/16.

The Investment Company has registered tied agents under its name who are established in the European Union. The said tied agents work exclusively for the Investment Company. Each tied agent will have its own privacy notice published on its website, which may be linked to and/or refer to the Investment Company’s website and/or name.

If you have any questions or would like to obtain further details on how the Investment Company uses your personal data, you can contact our data protection team at: [email protected].

The reason why we may lawfully collect and process your personal data is called the legal basis. We rely on a legal basis depending on the reason for which we process the data. We use the following legal bases for processing personal data:

Contractual obligations – where it is necessary either to conclude a contract with you for the provision of our products, to fulfil our obligations under the contract, or to provide you with advice in relation to our products.

Compliance with legal obligations – where required by law or a regulator, we may need to collect and process your data and also provide it to the regulator.

Legitimate interests – where processing is required to operate our business. This includes managing business, financial, and administrative matters in order to protect our customers, employees, and assets. It is in our interest to ensure that our processes and systems function effectively so that we can continue providing services.

Consent – processing your data based on your consent. We may use it in specific situations. For these purposes, we collect only freely given, specific, informed, and unambiguous consent obtained before processing.

We may use the personal data we collect from you and about you for the purposes listed below.

Account opening and provision of services

·        Considering the application to open an account

·        Performing our risk assessments

·        Obtaining information about your relevant investment knowledge and experience so we can assess whether the service is suitable for you

Managing our relationship with you, including support

·        Contact regarding matters related to your account

·        Providing you with account-related notices, general updates, and market updates

·        Reviewing your ongoing needs

·        Responding to your inquiries

Complying with our legal and regulatory obligations

·        Verifying your identity and performing checks

·        Conducting screening

·        Record-keeping obligations

·        Performing anti–money laundering, counter-terrorism and sanctions checks, handling complaints, and investigations or litigation

·        Carrying out “know your customer” procedures

·        Providing information about you and your trading with us to the competent authorities

Executing financial transactions

·        Deposits

·        Withdrawals

·        Chargebacks

·        Any other payments

Monitoring and evaluating compliance

·        Monitoring whether the provision of our services complies with our policies, standards, and legal requirements

·        Monitoring the conduct of employees when communicating with clients or potential clients

Creating statistical data and analyzing the business

·        Managing the company’s business stratégy

Developing and marketing products

·        Tailoring the products and services offered

·        Conducting product development and analysis

Protecting security

·        Protecting the security of and access to our premises and systems

·        Detecting and preventing fraud and other harmful activities

When you register the Services

The Company may collect the mentioned information directly from you (during the account opening process) and/or from other persons, including for example credit reference agencies, fraud prevention agencies, banks, other financial institutions, third-party authentication service providers (e.g., Lexis-Nexis for verification and background purposes) and public registry providers.

Information about you – Use of the services

The Company may also collect your data regarding your use of our websites, such as – Financial information

A. The services you use, the products you trade, and their performance

B. Historical data about the trades and investments you have carried out, including the invested amount

C. Historical data about your payment activities, balances on trading accounts, and your withdrawal activities.

·        Log information

·        Device information

·        Location

·        On-site activity

·        Cookies and other tracking technologies

Information contained in mandatory recordings.

The Investment Company records all communication, electronic, telephone, in person or other, which we conduct with you in connection with the services that the Investment Company has provided to you, and in relation with you. The said records will be the exclusive property of the Investment Company and will constitute evidence of the communication between the Investment Company and you.

As part of the procedures of opening a trading account and the ongoing obligations the Investment Company must follow the legislative framework which is currently applied by the Cyprus Securities and Exchange Commission (“CySEC”). The Investment Company will specifically comply with its legal obligations arising from the Prevention and Suppression of Money Laundering Laws of 2007-2019, as amended, for the determination of the Client’s economic profile and the prevention of money laundering, as well as comply with the relevant record-keeping obligations under the Commission Delegated Regulation (EU) 2017/565, which supplements Directive of the European Parliament and of the Council 2014/65/EU, as regards organizational requirements and operating conditions of investment firms and defined terms for the purposes of the said Directive (“Delegated Regulation”), and the Law on the Provision of Investment Services, the Performance of Investment Activities and the Operation of Regulated Markets No. 87(I)/2017 for the determination of the suitability and appropriateness of each Client based on the services offered by each CIF (suitability and appropriateness tests) and records of telephone calls, client transactions, the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS).

Based on the above, the Company collects and retains the following categories and types of personal data:

Contact Information

·        First and last name

·        Email address

·        Phone number

·        Utility bill

Payment and Tax Information

·        IBAN

·        Tax Identification Number

·        Tax residence

Personal Information

·        Date of birth

·        Place of birth

·        Nationality

·        Copy of ID card, passport, driver’s license, or other identification document

Employment Information

·        Employer name

·        Occupation

·        Industry

Financial Information

·        Gross annual income

·        Net worth

·        Estimated investment amount

·        Knowledge and experience

Within the use of your personal data for the purposes set out above, we may disclose your data to:

a) Service providers and specialized advisors contracted to provide IT, financial, regulatory, compliance, accounting and/or other services.
b) Tied agents with whom the Investment Firm has arrangements and who work exclusively for the Investment Firm.
c) Regulatory authorities.
d) Anyone authorized by you.
e) Competent authorities for the investigation or prevention of fraud, money laundering, or other unlawful activity.
f) The business register or a similar register.
g) Employees of the Investment Firm so they can perform their duties to enforce the Agreement between us or to ensure the effective operation of our Platform and the Automated Orders and Trading Data features.

The Investment Firm requires third parties who process or obtain personal data on its behalf in order to fulfil their contractual obligations to us to acknowledge the confidentiality of such information, commit to respecting each individual’s right to privacy, and comply with all applicable data protection laws and this Privacy Notice.

The Investment Firm will use, retain, process, and handle your personal data in accordance with the GDPR and applicable law, as amended or replaced.

Your personal data (non-publicly available information and/or information already held by the Investment Firm for compliance with the General Data Protection Regulation) will be collected and processed expressly and specifically only for the purposes for which they were collected (“purpose limitation”), while the Investment Firm shall request only the information necessary in relation to those purposes.

We may transfer your personal data outside the European Economic Area. If we do so, we will ensure the transfer is lawful and that appropriate safeguards are in place to protect your personal data, as required by Applicable Regulations.

The Investment Firm will retain your personal data for as long as it maintains a business relationship with you. Once the business relationship has ended, we may retain your data for up to five (5) years in accordance with the laws governing the Investment Firm. The Investment Firm may keep your personal data for longer than five (5) years for legal, regulatory, and/or other mandatory reasons.

The retention period will be determined with regard to the type of information collected and the purpose for which it is collected, taking into account the requirements applicable to the given situation and the need to destroy outdated, unused information within the shortest reasonable time.