This Privacy Policy (the «Policy») explains how I.T.S. INTELLIGENCE TRADE SOLUTIONS LTD, Business ID: HE475032, registered in the Cyprus Registrar of Companies («we», «us», «our», «Company» or «Сontroller») processes personal data of our customers («you», «your», or the «Customer») when you use our services through our website (https://itrade.money). We provide trading challenge services to evaluate and fund skilled traders. We are committed to safeguarding your privacy and ensuring compliance with the General Data Protection Regulation (GDPR) and Cyprus data protection law.
This Policy offers a detailed overview of how we collect, use, store, protect, and share your personal data, ensuring transparency and trust.
This Policy addresses the following:
- Who is the controller of your personal data and how to contact us?
- Why do we process your personal data, what personal data do we collect and how?
- How do we use your personal data?
- How long do we store your personal data?
- How do we secure your personal data?
- Who do we share your personal data with?
- Do we transfer your data to third countries?
- What are your rights and how can you exercise them?
- How do we use tracking and analytics tools?
- Updates to this Privacy Policy.
- Who is the controller of your personal data and how to contact us?
The controller of your personal data is I.T.S. INTELLIGENCE TRADE SOLUTIONS LTD, a company incorporated under the laws of Cyprus with the following details:
- Registered Office: Thessalias, 30 Flat/Office 21, 1057, Nicosia, Cyprus
- Email: [email protected]
We are responsible for determining the purposes and means of processing your personal data. Our dedicated team is available to assist with any questions, concerns, or requests related to your data or this Policy. You can reach us at [email protected] for inquiries about our data processing practices, your rights, or any issues related to your experience with our services. We aim to respond promptly, typically within two business days, to ensure your concerns are addressed effectively.
- Why do we process your personal data, what personal data do we collect and how?
We collect personal data to deliver our trading challenge services, manage user accounts, verify identities for funded accounts, and enhance your experience on our website (https://itrade.money). Our services involve simulated trading challenges where users demonstrate their skills to qualify for funded trading accounts. Below, we detail the categories of personal data we collect, how we obtain them, and the context of their use.
- Data Provided Directly by You
We collect personal data you voluntarily provide when interacting with our website or services:
- Identification and Contact Data: When you register an account, participate in trading challenges, or communicate with us, we collect:
- Full name (first name and surname) to identify you and personalize your account.
- Email address to send account-related communications and updates.
- Phone number to facilitate customer support or verification processes.
- Verification Data: If you successfully complete a trading challenge and qualify for a funded account, we require additional information to comply with anti-money laundering (AML) and know-your-customer (KYC) regulations. This includes:
- Passport information (e.g., passport number, date of issue, expiry date, issuing authority) to verify your identity.
- Proof of residence (e.g., utility bill, bank statement, or other official document showing your address) to confirm your place of residence.
- Communication Data: Information you provide when contacting our support team at [email protected], such as inquiries, feedback, complaints, or technical issues. This may include details about your account, trading activities, or specific challenges you encounter.
- Payment Data: When you make payments to participate in trading challenges, we collect:
- Cryptocurrency wallet addresses for payments in supported tokens (USDT, USDC, ETH, LTC, SOL, TRX, or additional tokens). These addresses are stored securely and used solely to process and verify payments. Note that cryptocurrency transactions are recorded on public blockchains, but we take measures to ensure your wallet addresses are not linked to your personal identity beyond what is necessary for transaction processing.
- Transaction details (e.g., amount, date, and payment method) processed through our payment processors, such as Confirmo, Radom, or others processors.
- Data Collected Automatically
We use automated technologies, such as cookies and analytics tools, to collect data about your interactions with our website and services:
- Website Usage Data: When you visit https://itrade.money, we collect:
- IP Address: To identify your device and approximate your location (e.g., country or region) for security and analytics purposes.
- Device Information: Details about your device, including type (e.g., desktop, mobile), operating system (e.g., Windows, macOS, iOS, Android), and browser type (e.g., Chrome, Firefox, Safari) to optimize your experience.
- Browsing Behavior: Information about how you navigate our website, such as pages visited, time spent on each page, links clicked, and the date and time of your visit, to improve usability and functionality.
- Analytics Data: Through third-party tools like Meta Ads, Google Ads, and other analytics platforms, we collect aggregated or anonymized data to understand user behavior and enhance our services. This includes:
- Clickstream data (e.g., the sequence of pages you visit).
- Engagement metrics (e.g., time spent on the website, bounce rates, or scroll depth).
- Referral sources (e.g., whether you arrived via a search engine, social media, advertisement, or direct link).
- Data Obtained from Third Parties
We may receive personal data from trusted third-party providers that support our operations:
- Tech Provider (Volumetrica): Our technology partner, Volumetrica, stores and processes data on secure cloud servers to support our trading platform. This includes:
- Trading activity data (e.g., details of simulated trades, such as trade type, volume, profit/loss, and performance metrics) to evaluate your performance in challenges.
- Account settings (e.g., preferred currency, challenge parameters, or trading preferences) to customize your experience.
- Third-Party Service Providers:
- CRM and Affiliate CRM Systems: We use customer relationship management (CRM) platforms to manage interactions with you and track affiliate referrals. These systems store your name, email, phone number, and interaction history (e.g., communications or referrals).
- Trading Platforms: Integrated platforms collect data on your trading activities, such as trade execution details, to facilitate your participation in challenges and funded accounts.
- Payment Processors: Confirmo, Radom, and other processors provide transaction confirmation details (e.g., payment status, amount) to verify your payments, including those made in cryptocurrencies.
- Marketing and Analytics Providers: Platforms like Google Ads and Meta Ads provide anonymized or aggregated data about your interactions with our advertisements or campaigns to optimize marketing efforts.
- Data We Do Not Collect
To ensure clarity and compliance, we explicitly do not collect:
- Personal Data of Minors: We do not process personal data of individuals under the age of 18, as our services are designed for adult users.
- Sensitive Data: We do not collect or process special categories of data, such as racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health, or data concerning a person’s sex life or sexual orientation.
- Real-Time Location Data: We do not collect GPS or other real-time location data.
- How do we use your personal data?
We process your personal data for specific, lawful purposes to deliver our trading challenge services, comply with legal obligations, and improve your user experience. Below, we outline each purpose, the data involved, and the legal basis under GDPR.
- Registration and Account Management
Purpose: To create and manage your user account on https://itrade.money, enabling you to participate in trading challenges, access your dashboard, and track your progress.
Data Processed: Name, surname, email address, phone number, and account settings (e.g., preferred currency, challenge type, or trading preferences).
Legal Basis: Necessary for the performance of a contract (your agreement to use our services, as outlined in our Terms and Conditions). Providing this data is mandatory to register and maintain an account.
- Provision of Trading Services
Purpose: To enable your participation in trading challenges, provide access to our trading platform, evaluate your performance, and verify your identity for funded accounts. This includes processing simulated trades and ensuring compliance with regulatory requirements.
Data Processed:
- Identification and contact data (name, surname, email, phone number).
- Verification data (passport information, proof of residence).
- Trading activity data (e.g., trade types, volumes, performance metrics, and results).
Legal Basis: Necessary for the performance of a contract (to deliver trading challenge services) and compliance with legal obligations (e.g., AML/KYC regulations requiring identity verification for funded accounts).
- Marketing Communications
Purpose: To keep you informed about your account and our services through emails, including:
- Registration confirmation to verify your account creation.
- Login credentials for secure access to your account.
- Updates on your trading challenge progress (e.g., phase completion or performance feedback).
- Notifications of successful challenge completion and funded account eligibility.
- Marketing offers, promotions, or event announcements related to our trading services.
Data Processed: Name, surname, email address.
Legal Basis: For existing customers, we rely on our legitimate interest to keep you informed about services directly related to your account. For non-customers or additional promotional content, we obtain your explicit consent during registration or through our website. You can unsubscribe at any time by emailing [email protected] or clicking the unsubscribe link in our emails.
- Customer Support and Communication
Purpose: To address your inquiries, provide technical assistance, troubleshoot issues, and ensure a seamless experience with our services.
Data Processed: Name, surname, email address, phone number, and any details provided in your communications (e.g., issue descriptions, account details, or trading activity concerns).
Legal Basis: Legitimate interest in maintaining customer satisfaction, resolving issues, and supporting your use of our platform.
- Analytics and Service Improvement
- Purpose: To analyze user behavior, monitor website performance, and enhance our services, including the user interface, trading tools, challenge design, and overall customer experience.
- Data Processed: Website usage data (IP address, device information, browsing behavior) and analytics data from tools like Meta Ads, Google Ads, and other platforms.
- Legal Basis: Legitimate interest in improving our services, optimizing website functionality, and ensuring a user-friendly experience.
- Remarketing for Advertising
- Purpose: To deliver personalized advertisements through platforms like Google Ads and Meta Ads, targeting users who have previously interacted with our website or services to promote relevant offers or challenges.
- Data Processed: Anonymized or aggregated data (e.g., browsing behavior, ad clicks, or campaign interactions) collected via cookies or similar technologies.
- Legal Basis: Your consent, obtained through our website’s cookie consent mechanism, or legitimate interest for processing anonymized data to improve advertising effectiveness.
- Legal Compliance and Disclosure
- Purpose: To comply with legal obligations, such as responding to requests from law enforcement, regulatory bodies, or government agencies, or fulfilling tax, AML, or KYC requirements.
- Data Processed: All relevant personal data, including name, surname, email, phone number, passport information, proof of residence, and transaction details.
- Legal Basis: Compliance with legal obligations under Cyprus or other applicable laws.
- How long do we store your personal data?
We retain your personal data only for as long as necessary to achieve the purposes outlined in this Policy or to comply with legal requirements. Our services require ongoing account management and regulatory compliance, so we store data for the duration of your active engagement with our platform (i.e., while you maintain an account or participate in trading challenges) and for specified periods thereafter to address potential claims, disputes, or legal obligations. The retention periods are as follows:
- Contract Performance and Account Management: Identification, contact, and account settings data are stored for the duration of your active account and up to 10 years after account termination to address potential claims, disputes, or tax obligations.
- Marketing Communications: Data used for marketing emails is retained until you unsubscribe or for a maximum of 5 years after your last interaction with us (e.g., last login or challenge participation), unless you explicitly consent to longer retention.
- Analytics and Service Improvement: Website usage and analytics data are retained for up to 6 months, after which they are anonymized or deleted to prevent identification.
- Legal Obligations: Data required for legal obligations may be kept for up to 10 years. Legal obligations may also require specific retention periods.
Once these retention periods expire, your personal data is securely deleted or anonymized to ensure it cannot be linked to you. We regularly review our data retention practices to ensure compliance with GDPR’s storage limitation principle.
- How do we secure your personal data?
We prioritize the security of your personal data and implement robust technical and organizational measures to protect against unauthorized access, alteration, disclosure, or destruction:
- Encryption: All personal data, including identification, verification, and payment data, is stored in encrypted databases managed by our tech provider, Volumetrica, on secure cloud servers. Data transmitted between your device and our platform is protected using industry-standard encryption protocols (e.g., TLS/SSL).
- Access Controls: Only authorized personnel with a legitimate business need can access your data. Access is restricted through multi-factor authentication, role-based permissions, and secure login systems.
- Regular Audits and Monitoring: We conduct periodic security audits, vulnerability assessments, and penetration testing to identify and address potential risks. Our systems are monitored continuously for suspicious activity.
- Employee Training: Our staff undergoes regular training on data protection and GDPR compliance to ensure proper handling of your data.
- Third-Party Compliance: All third-party providers (e.g., Volumetrica, Confirmo, Radom, Google Ads, Meta Ads) are contractually obligated to maintain equivalent security standards, comply with GDPR, and process your data only according to our instructions. We conduct due diligence to verify their security practices.
- Incident Response: In the unlikely event of a data breach, we have a robust incident response plan to promptly investigate, mitigate, and notify affected users and authorities, as required by GDPR.
These measures ensure your data is protected at every stage of processing, from collection to storage.
- Who do we share your personal data with?
To deliver our trading challenge services, we share your personal data with trusted third parties under strict confidentiality agreements, only to the extent necessary to provide our services.
- Tech Provider (Volumetrica): Stores and processes trading activity data (e.g., trade types, volumes, performance metrics) and account settings (e.g., currency, challenge preferences) on secure cloud servers to support our trading platform’s functionality.
- Third-Party Service Providers:
- CRM and Affiliate CRM Systems: Manage customer relationships and track affiliate referrals, storing your name, email, phone number, and interaction history (e.g., communications, referral details). These systems help us personalize your experience and manage partnerships.
- Trading Platforms: Process trading activity data to enable your participation in simulated trading challenges and funded accounts, ensuring seamless trade execution and performance tracking.
- Payment Processors: Confirmo, Radom, and future processors handle payment transactions, including cryptocurrency payments. They store transaction confirmation details (e.g., amount, date) to verify payments.
- Marketing and Analytics Providers: Google Ads, Meta Ads, and other platforms process anonymized or aggregated data (e.g., browsing behavior, ad interactions) to analyze user engagement and deliver targeted advertisements.
- Legal Authorities: We may disclose your personal data (e.g., name, surname, email, phone number, passport information, proof of residence, transaction details) to law enforcement, regulatory bodies, or government agencies if required by law or a legally binding decision.
We do not sell your personal data or share it for commercial purposes beyond what is strictly necessary to provide our services. All third parties are contractually obligated to process your data only according to our instructions, maintain confidentiality, and comply with GDPR, Cyprus data protection law and other applicable data protection laws. We regularly review our third-party agreements to ensure ongoing compliance.
- Do we transfer your data to third countries?
Your personal data may be transferred to third countries (outside the European Economic Area) if our service providers, such as Volumetrica, Google Ads, or Meta Ads, operate in those jurisdictions (e.g., the United States or other regions). To ensure your data remains protected, we comply with GDPR by:
- Using Standard Contractual Clauses (SCCs) approved by the European Commission to govern data transfers and ensure equivalent protection.
- Verifying that third parties implement adequate data protection measures, such as encryption and access controls, through contractual agreements and audits.
- Obtaining your explicit consent for specific transfers where required (e.g., for certain marketing or analytics purposes).
- Assessing the data protection frameworks of third countries to ensure compliance with GDPR requirements.
We maintain a list of third-country recipients and their data protection measures, which you can request by contacting us at [email protected]. We are committed to ensuring your data remains secure during international transfers.
- What are your rights and how can you exercise them?
As a user, you have several rights under GDPR to control how your personal data is processed. These rights empower you to access, correct, delete, or restrict the use of your data:
Right of Access: Request confirmation of whether we process your data and receive a copy of it, along with details about the processing (e.g., purposes, recipients). The first copy is free; subsequent copies may incur a small administrative fee.
Right to Rectification: Correct inaccurate or incomplete data (e.g., outdated email or phone number) by contacting us or updating your account settings on our website.
Right to Erasure (“Right to be Forgotten”): Request deletion of your data if:
- It is no longer necessary for the purposes for which it was collected (e.g., after account closure).
- You withdraw your consent, and no other legal basis applies (e.g., for marketing).
- You object to processing, and there are no overriding legitimate grounds.
- The data is processed unlawfully.
- Note: We may retain data if required for legal obligations (e.g., tax or AML records), public interest, or defense of legal claims.
Right to Restriction of Processing: Request temporary restriction of processing if:
- You contest the accuracy of your data (until we verify it).
- Processing is unlawful, but you prefer restriction over erasure.
- We no longer need the data, but you require it for legal claims.
- You object to processing, pending verification of legitimate grounds.
Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format (e.g., CSV or JSON) or have it transferred to another controller, if processing is based on consent or a contract (e.g., account or payment data).
Right to Object: Object to processing based on our legitimate interests (e.g., analytics or marketing). We will cease marketing communications immediately upon objection and review other objections to determine if legitimate grounds override your request.
Right to Withdraw Consent: Withdraw consent for processing (e.g., marketing emails or cookies) at any time by emailing [email protected] or using the unsubscribe link in our emails. Withdrawal does not affect the lawfulness of prior processing.
Right to Avoid Automated Decision-Making: Not be subject to decisions based solely on automated processing (including profiling) that produce significant legal effects, unless necessary for a contract or based on your explicit consent. Our trading challenge evaluations may involve automated scoring, but funded account decisions include human oversight.
To exercise any of these rights, please email us at [email protected] with a clear description of your request (e.g., specify the right you wish to exercise, the data involved, and any relevant details, such as your account ID). You may also update certain data (e.g., email, phone number) directly in your account settings on our website. We will respond within one month, as required by GDPR, unless your request is complex or voluminous, in which case we may extend the response time by up to two additional months and notify you accordingly.
If you believe our processing violates data protection laws, you may lodge a complaint with:
Cyprus Data Protection Commissioner: https://www.dataprotection.gov.cy, Office of the Commissioner for Personal Data Protection, P.O. Box 23378, 1682 Nicosia, Cyprus.
We encourage you to contact us first to resolve any concerns, and our support team will work with you to address your request promptly.
- How do we use tracking and analytics tools?
We use tracking and analytics tools to understand how users interact with our website, optimize its performance, and deliver targeted advertising:
Tools Used: Meta Ads, Google Ads, and other analytics platforms collect data such as IP addresses, device information (e.g., browser, operating system), browsing behavior (e.g., pages visited, time spent), and ad interactions (e.g., clicks, impressions).
Purpose: To analyze website performance (e.g., identifying popular features or bottlenecks), track user engagement (e.g., time on site, bounce rates), and improve our services and marketing strategies. This helps us enhance the user interface, streamline trading challenges, and offer relevant promotions.
Remarketing: We use Google Ads, Meta Ads, and other platforms to deliver personalized advertisements based on your prior interactions with our website (e.g., visiting a challenge page). This involves cookies or similar technologies to track anonymized behavior, ensuring ads are relevant to your interests.
User Control: You can manage tracking preferences through our website’s GDPR-compliant cookie consent banner, which allows you to opt out of non-essential cookies (e.g., analytics, marketing).
We ensure that analytics and remarketing data is processed in compliance with GDPR, prioritizing anonymized or aggregated data where possible to minimize privacy impact.
- Updates to this Privacy Policy
We may update this Policy to reflect changes in our services, legal requirements, or operational practices. Significant changes (e.g., new data processing purposes or third-party sharing) will be communicated via email or a prominent notice on our website (https://itrade.money) at least 30 days before they take effect. Minor updates (e.g., clarifications or formatting changes) will be reflected in the latest version available on our website.
We review this Policy at least annually to ensure ongoing compliance with GDPR, Cyprus data protection law. Each version is assigned a version number and effective date for transparency. The latest version is always accessible at https://itrade.money. We encourage you to check this page periodically to stay informed about how we protect your data.
