Privacy and Data Protection Policy

Your privacy and safety are very important to DIF BROKER FINANCEIRA DE CORRETAGEM S.A. (Hereinafter “DIF BROKER”). Therefore this policy contains the practices regarding the personal data processing on the websites owned by DIF BROKER, namely the database with the collected data and its processing, use and disclosure.

This policy explains your rights and how and for which purposes your data is collected.

This policy applies to all customers and users that use the mobile applications or have access to the DIF Broker’s websites, or that interact with DIF Broker through any other mean (for instance, social networks)

This policy defines our firm compromise to protect your personal data, thus we recommend the reading and acceptance of our privacy and data protection policy before continuing to navigate on the DIF Broker’s websites.

This privacy policy was updated on 20 September 2018.

1. Identification of the social entity responsible for the file

Accordingly to the provisions on REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND COUNCIL of 27 April 2016 on the protection of physical individuals regarding the personal data processing and free movement of data (hereinafter GDPR), we inform that the personal data collected or sent to DIF Broker shall be processed by the following Data Processing Officer:

  • Name: DIF BROKER – SOCIEDADE FINANCEIRA DE CORRETAGEM S.A
  • Registered office: Rua António Cardoso, no. 601-613, Lj 8, 4150-083 Oporto
  • Country: Portugal
  • Telephone: +351 211 201 595
  • E-mail: [email protected]
  • Address (office): Av. da Liberdade No. 244- 4º 1250-149 – Lisbon
  • N.C.P.I: 504.767.640
  • Object: Financial Intermediation and auxiliary services
  • Registries in Portugal: CMVM No. 276, Bank of Portugal No. 225.
Who is the Data Protection Officer of DIF BROKER, and how is it possible to contact them?

The Data Protection Officer is the individual responsible for protecting the fundamental right to the personal data protection on DIF BROKER , who undertakes the regulatory compliance of data protection. You may contact the Data

Protection Officer of DIF BROKER through the following email address: Contact of the Data Protection Officer: [email protected]

2. Information WTI collects and controls

We only collect the information that we actually need. Some of that is information that you give us when you sign up for WTI, register with a broker sponsor. We store your name.

When you visit one of our websites, we automatically log some basic information like how you got to the site, where you navigated within it. We use this information to improve our websites and services.

If you engage with our brand on social media (for instance, liking, commenting, retweeting, mentioning, or following us), we'll have access to your interactions and profile information. We'll still have that information even if you later remove it from the social media site

What we do with your information

We use your information to provide the services you've requested, create and maintain your rankings. We're required to have a legal basis for collecting and processing your information. In most cases, we either have your consent or need the information to provide the service you've requested from us. When that's not the case, we must demonstrate that we have another legal basis, such as our legitimate business interests.

You can also disable cookies to prevent your browser from giving us information, but if you do so, certain website features may not work properly. We completely disable third-party cookies from all WTI websites.

We limit access to your personal information to our employees and contractors who have a legitimate need to use it.

The European Economic Area (EEA) provides certain rights to data subjects (including access, rectification, erasure, restriction of processing, data portability, and the right to object and to complain). WTI undertakes to provide you the same rights no matter where you choose to live.

We keep your personal information for as long as it is required for the purposes stated in this Privacy Policy. When we no longer have a legitimate need to process your information, we will delete, anonymize, or isolate your information, whichever is appropriate.

3. Information that WTI processes on your behalf

You own your service data. We protect it, limit access to it, and only process it according to your instructions. You may access it, share it through third-party integrations.

We hold the data in your account as long as you choose to use WTI. After you terminate your competition, your data will be automatically deleted from our active database within 6 months and from our backups within 3 months after that.

4. General

There are some limitations to the privacy we can promise you. We will disclose personal information if it's necessary to comply with a legal obligation, prevent fraud, enforce an agreement, or protect our users' safety. We do not currently honor Do Not Track signals from internet browsers; when a universal standard for processing them emerges, we will follow it.

Third-party websites and social media widgets have their own separate privacy policies. Always check the relevant privacy policy before sharing personal information with third parties.

You can always alert us and ask to have your personal information removed from our blogs or forums.

We will contact you to let you know if we make any major changes to our privacy policy, or in the highly unlikely event that we ever decide to sell our business.

 

Privacy Policy

This Privacy Policy statement is made by WTI (collectively, "WTI", "we", "us" or "our") and is effective as of 25th May 2018.

WTI’s Privacy Commitment

WTI has worried about customer and user privacy for almost 10 years, long before it became fashionable, politically correct, or legally binding to take such a position. We ask for only the least amount of information necessary, gathering only what is essential for doing business. By far, our biggest commitment is that we do not make a single dollar from advertising revenue—never have, never will. means we avoid the fundamental conflict of interest between gathering customer information and fueling advertising revenue, and the unavoidable compromises in customer privacy that it brings.

The goal of this policy is to make explicit the information we gather on our customers and users, how we will use it, and how we will not. This policy is unfortunately longer than we would like, but we must unambiguously address all the relevant cases. We will try and keep the language simple and direct as much as possible.

Scope of this Privacy Policy

This Privacy Policy applies to all WTI websites that link to it.

This Privacy Policy is divided into three parts:

Part I – Information WTI collects and controls
This part deals with how WTI collects and uses information.

Part II – Information that WTI processes on your behal
This part deals with how WTI handles data that you entrust to WTI when you use our services, or when you share any personal information with us.

Part III – General
This part deals with topics that are relevant to both Parts I and II, and other general topics such as WTI's security commitments and how we will inform you when we change this Privacy Policy.

Part I – Information WTI collects and controls

What information WTI collects

We collect information about you only if we need the information for some legitimate purpose. WTI will have information about you only if (a) you have provided the information yourself, (b) WTI has automatically collected the information, or (c) WTI has obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.

Information that you provide us

  1. Account signup : When you sign up for an account to access one of our WTI Leagues, we ask for information like your name, email address, and country for you to be on the rankings. You may also provide us with more information such as your photo, and language, but we don’t require that information to sign up for an account.
  2. Testimonials : You authorize us to post your testimonials about your view on the markets on websites, we may include your name and other personal information in the testimonial.

Information that we collect automatically

  1. Information from browsers, devices and servers : When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information.
  2. Information from first party cookies and tracking technologies : We embed unique identifiers to track usage. We also use cookies, to identify visitors, track website navigation, gather demographic information about visitors and users, understand email campaign effectiveness. We only use first-party cookies and do not use third-party cookies or other third-party tracking technologies on our websites. You can learn more about the cookies used on our websites.

Information that we collect from third parties

  1. Signups from Broker sponsors of WTI: These Brokers will authenticate your identity and have their own Private Policy and only share certain personal information with us, such as your name and data of your portfolio to be able to calculate performance and establish rankings.
Purposes for using information

In addition to the purposes mentioned above, we may use your information for the following purposes:

  • To communicate with you (such as through email) about the WTI Competition that you have signed up for, changes to this Privacy Policy, changes to the Terms of Service, or important notices;
  • To keep you posted on news, upcoming events, and other information that we think will be of interest to you;
  • To set up and maintain your account, and to do all other things required for providing our services.
  • To provide customer support. To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of WTI, and WTI’s users.
Legal bases for collecting and using information

Legal processing bases applicable to WTI: If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of WTI or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.
Withdrawal of consent: Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.

Your choice in information use

Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.
Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
Optional information: You can choose not to provide optional profile information such as your photo. You can always choose not to fill in fields when you submit any post to our websites.

Who we share your information with

We do not sell any personal information. We share your information only in the ways that are described in this Privacy Policy, and only with parties who adopt appropriate confidentiality and security measures.
Employees and independent contractors: Employees and independent contractors of WTI have access to the information covered in Part I on a need-to-know basis.
Third-party service providers: We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such web analytics providers. These service providers are authorized to use information only as necessary to provide these services to us.

Your rights with respect to information we hold about you as a controller

If you are in the European Economic Area (EEA), you have the following rights with respect to information that WTI holds about you. WTI undertakes to provide you the same rights no matter where you choose to live.

Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared
Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to complain: You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

Retention of information

We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted or required by law, such as to maintain rankings, suppression lists, to enforce our agreements, or to comply with other legal obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

Part II – Information that WTI processes on your behalf

Information entrusted to WTI and purpose
Information provided in connection with services: You may entrust information that you control, to WTI in connection with participating in WTI.

Ownership and control of your service data
We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to (i) access your service data, (ii) share your service data.

How we use data
We process your data when you provide us instructions through registering with WTI competition.

Part III – General

Children’s personal information

Our services are not directed to individuals under 16. WTI does not knowingly collect personal information from children who are under 16 years of age.

How secure is your information

At WTI, we take data security very seriously. We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us.

Locations and international transfers

We share your personal information and service data within WTI. By accessing or using our services, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries where WTI operates. Such transfer is subject to a group company agreement that is based on EU Commission’s Model Contractual Clauses.

Do Not Track (DNT) requests

Some internet browsers have enabled 'Do Not Track' (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals

Blogs and forums

We offer publicly accessible forums on our websites. Please be aware that any information you provide on these forums may be used to contact you with unsolicited messages. We urge you to be cautious in disclosing personal information in our forums. WTI is not responsible for the personal information you elect to disclose publicly. Your posts and certain profile information may remain even after you terminate your participation with WTI. To request the removal of your information from our forums, you can contact us.

Social media widgets

Our websites include social media widgets such as Facebook "like" buttons and Twitter "tweet" buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.

Disclosures in compliance with legal obligations

We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.

Enforcement of our rights

We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.

Business Transfers

We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.

Compliance with this Privacy Policy

We make every effort, including periodic reviews, to ensure that personal information you provide is used in conformity with this Privacy Policy.

Notification of changes

We may modify the Privacy Policy at any time, upon notifying you through a service announcement or by sending an email to your primary email address. If you think that the updated Privacy Policy affects your rights with respect to your use of our services, you may terminate your use by sending us an email within 30 days. Your continued use after the effective date of changes to the Privacy Policy will be deemed to be your agreement to the modified Privacy Policy. You will not receive email notification of minor changes to the Privacy Policy. If you are concerned about how your personal information is used, you should check back periodically.