PRIVACY NOTICE
When using our services or accessing our website we need to process your personal data (“you”, “your” or the “Customer”) and the purpose of this Privacy Notice (the “Notice”) is to provide you with information about how we use your data.
This Notice outlines, among others, information on who we are and how we process your personal data, the purposes for which personal data are collected and used, how long we use them, when they are shared with third parties, or what rights you have regarding your personal data.

WHO IS THE CONTROLLER OF YOUR PERSONAL DATA AND WHOM TO CONTACT?
The controller of your personal data is JV Prop Corporation, with its registered office at 1209 Orange Street, Wilmington, County of New Castle, Delaware 19801, United States (“we”, “our”, or “Controller”).
For any queries regarding the processing of your personal data or to exercise your rights, contact us at:
Email: [email protected]
Postal Address: FTMO, Quadrio Offices, Purkyňova 2121/3, Nové Město, 110 00 Prague 1, Czech Republic

WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE OBTAIN IT?
In order for us to be able to use our services we need to obtain and process personal data about you. In this section, you can find an overview of the data which we collect and how we collect it. Detailed information on the purposes for which we process personal data is given in Section 3 of this Notice. All information based on which we can directly or indirectly identify you or which is related to you is considered personal data.
We collect, in particular, following personal data:

1. Data that you provide to us yourself, especially when you register on the website, enter information into your user account, order services, participate in our events and projects, or when you communicate with us through customer support or social networks. These are identification and contact data, specifically the name, surname, telephone number, email address, postal address, date of birth, user name and password, and business identification number or tax registration number, if you are an entrepreneur; payment data, such as bank details; and other data, such as records of communication between you and us or details of any claims.
2. Data that we automatically collect when you use our services. These are data about your device (such as the IP address, device type, operating system, browser used, connection provider); website usage data (such as the date, time and duration of visit, a country from which you visit the website, website browsing history), and data on the use of services (such as the login and logout information, your account settings, the value of your fictitious capital, your account currency).

Some data about you is provided to us by third parties, such as providers of trading platforms that you choose for use of our services, and social network operators if you decide to link your social networking accounts to an account on the website. This includes:

• Data about the simulated transactions you have completed (such as the type of financial instrument, time of opening and closing the position, amount of investment, profit and loss) and data from social networks (username, profile picture, e-mail address associated with the account on the social network). For information on how your personal data are processed by trading platform providers and social network operators for their own purposes, please refer to the privacy notices of those parties.

PURPOSES AND LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
We use personal data for the following purposes:
Registration and user account
In order to use our services, you must first register on our website and create your profile with the following personal data:

1. Personal data: identification and contact data such as your e-mail address, name, country of residence, password, telephone number; we may also process your data related to the settings of your user account.
2. Legal ground for the processing: Processing is necessary for the performance of the contract, and the provision of these personal data is required, as we cannot create your user account without them.

Provision of services and exercise of rights and obligations under the contract between us and the customer.
In order to be able to provide you with our services, i.e. in particular to provide you with the relevant access, tools and support, and to carry out simulated trades, we need to process your personal data. For this purpose, the following data are used:

1. Personal data: Identification and contact data and, in the case of paid services, also payment data, data on the use of the services, data on the simulated trades and, if you decide to link your social networks accounts with the account on the website, also data from social networks.
2. Legal ground for the processing: Processing is necessary for the performance of the contract on the basis of which we provide our services, or on the basis of our legitimate interest. After we stop providing you with services, we process personal data for a limited period of time. Such processing is necessary for the purposes of exercising and protecting our rights based on our legitimate interests.
3. Marketing communication about our services and products or about events in which we take part

If you are our current or past customer, we may from time to time send you marketing communications that relate to our services. We may also send you commercial communications to the extent to which you give us your consent. Each of the e-mails sent will be marked as a business communication and each of them will contain a link with the help of which you can easily unsubscribe from the business communications. For this purpose, the following shall apply:

1. Personal data: Identification and contact data.
2. Legal ground for the processing: If we have provided you with our services, we may from time to time send you marketing communications based on our legitimate interest, namely keeping in touch with our customers. If you give us your consent to process your data for marketing purposes, then we process your data on the basis thereof.

Customer support and communication
During our relationship together we may need to communicate in order to address any of your inquiries or resolve your concerns. If you use our customer support services, we will process your personal data. For this purpose, the following personal data will be processed:

• Personal data: Identification data, contact data, other data on how you use our services and data from social networks, if you contact us through social networks.
• Legal ground for the processing: Processing is based on our legitimate interest, namely in maintaining customer satisfaction and supporting the use of our services.

Improving services
If you use some of our services, we will process your personal data in order to develop, test and enhance the services and improve their security. For this purpose, the following shall apply:

• Personal data: Identification and contact data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.
• Legal ground for the processing: Processing is based on our legitimate interest, namely in improving our services.

Analytics
To obtain information about how our website and our services are used, we analyze customer behavior. For this purpose, the following shall apply:

• Personal data: Identification data, contact data, payment data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.
• Legal ground for the processing: Processing is based on our legitimate interest, namely in ascertaining customer behavior and estimating customer preferences.

Protection of our legitimate interests
Sometimes we need to process your personal data to protect our own interests. This interest may vary but include mainly defense in case of any legal claims, general internal risk management including risk management relating to the use of our services by clients (including fraud prevention) and ensuring that our services are secure for use. For these purposes the following personal data will be processed:

• Personal data: Identification data, contact data, payment data, data about your device, website usage data, data on the use of the services, and data on the simulated trades and other relevant data according to specific situation.
• Legal ground for the processing: Processing is based on our legitimate interest. 

Fulfillment of our legal obligations
When providing our services we have various legal obligations we need to fulfil, mainly to keep our services secure, to have accounting and tax records of our services (including performance of necessary audits), to communicate with any regulators if necessary or to fulfil applicable international sanctions requirements.

• Personal data: Identification data, contact data, payment and invoice data, data on the use of the services, and other relevant data according to specific situation.
• Legal ground for the processing: Processing is necessary for compliance with legal obligations

HOW DO WE STORE PERSONAL DATA AND HOW ARE THEY SECURED?
We process your personal data in a secured database. In order to ensure protection against unauthorized access or unauthorized alteration, disclosure or destruction of the personal data that we collect and process, we have adopted organizational and technical measures to secure them, which we strictly adhere to.

DATA SHARING AND TRANSFERS TO THIRD COUNTRIES
Data Sharing
In the course of our activities, we may share your personal data with other persons for various reasons, primarily to ensure seamless provision of our services, the fulfillment of our legal obligations and to protect our legitimate interests. These persons – recipients fall into different categories, in particular:

1. Trading platform providers, in order to enable you to perform the simulated trades.
2. Other IT providers such as cloud service providers, IT contractors, providers of software we use and  providers managing its maintenance, IT development, and cybersecurity services, website service providers, including hosting providers;
3. Payment service providers and financial institutions, which facilitate payment processing, banking services, and related financial transactions.
4. Customer support providers, marketing and communication service providers, such as marketing agencies and social network operators, communication platforms, consultants, and postal service providers;
5. Advisors and consultants – consultants and auditors in the area of tax and accounting including external accountants and auditors; legal advisors who assist with legal compliance, dispute resolution, and representation before authorities;
6. Public authorities in case of requests from law enforcement authorities to meet national security or other law enforcement requirements or in order to protect our legitimate interests; and
7. Other group companies – as part of shared services arrangements and where appropriate and in specific circumstances we may share your personal data with other companies in our group in order to manage our risks on a consolidated bases or to facilitate client transfers.

We remain responsible and liable for the processing of personal data in case of our supplier or other persons we engage to process the personal data on our behalf.
Note that certain third parties collect personal data for their own purposes as controllers. In such a case, their own rules for the processing of personal data shall apply. 
Transfer outside of EU
Personal data collected in the European Union under this Notice may be transferred to countries outside the EU or European Economic Area. Such transfers to third countries will only occur in case appropriate safeguards are in place, for example Standard Contractual Clauses or Data Privacy Framework in case of transfer into the US.

HOW LONG DO WE PROCESS YOUR DATA?
We retain personal data only for as long as necessary to achieve the purposes described above or for a period directly set out by law. After such period your personal data will be deleted or anonymized. We process personal data for the following periods of time: 

1. for the purpose of performance of the contract and for the exercise of rights and obligations in connection with the contract, including any complaints, settlement of damage claims or related litigation, personal data are processed for the necessary period of time, but not more than 10 years from the termination of the last contract.
2. for the purpose of sending business communications without your given consent, personal data are processed for a maximum of 5 years from the expiry of the last contract between us or until you raise an objection or unsubscribe from the business communications;
3. for the purpose of enhancing our services, we usually process personal data for a maximum period of 6 months;
4. in order to fulfil our legal obligations, we process personal data for the period set out by the relevant legal regulations (e.g. in accordance with tax regulations for a period of 10 years from the issuance of the relevant documents for your order);
5. if you have given your consent, for the period specified in the consent.

YOUR PRIVACY RIGHTS 
You can exercise all your rights mentioned below, including your right to erasure of personal data and the withdrawal of your consent, by sending a request to us via email at [email protected].
Alternatively, you can use our contact details in Section 1 of this Notice. There are no specific words that you must use in your request, but please be specific enough, so we can help you with your request (e.g. identify yourself, specify the right you wish to exercise, what action you wish us to take, details of what personal data you want erased/deleted, etc.)
We respond to inquiries within 30 days.
In connection with the processing of personal data you have the following rights:
Right of access to personal data
You can ask us at any time to send you confirmation as to whether or not your personal data are being processed. If we process your data, we will provide you with further details on the processing. If you request it, we will also provide you with a copy of the personal data processed. Please note that the first copy is free of charge, but later copies will be provided for a small fee.
Right to rectification of personal data
If we process your personal data inaccurately, you can notify us of this fact, and we will rectify the inaccurate personal data without undue delay. If you register on the website, you will be able to rectify and amend your personal data yourself by editing your profile.

Right to erasure of personal data (“right to be forgotten”)
You have the right to obtain from us the erasure of personal data concerning you without undue delay in the following cases:

• If the data are no longer necessary in relation to the purposes for which we have collected or otherwise processed them;
• If you withdraw your consent to their processing and, at the same time, there will be no other legal ground for their processing (this only applies in the cases where we process personal data on the basis of your consent);
• If you object and there are no overriding legitimate grounds for the processing, or if you object to the processing for direct marketing purposes; or
• If your personal data are processed unlawfully.

We will not be able to act on the request for the erasure of personal data if their processing is necessary for exercising the right of freedom of expression and information, for compliance with any of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise, or defense of our legal claims, or for other reasons provided for by law.
Right to restriction of processing
You can request for us to restrict the processing of your personal data in certain circumstances. You can request this restriction when:

• You contest the accuracy of the data we hold about you, and we are verifying its accuracy;
• You believe the processing is unlawful, but you prefer us to restrict use of the processing of data instead of deleting it;
• We no longer need the data for our original purposes, but you need it to establish, exercise, or defend legal claims;
• You have objected to processing based on our legitimate interests, pending verification of whether our grounds override yours.

Right to data portability
In the case our processing is carried out by automated means and is (i) based on your consent, or (ii) necessary for performance of the contract, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have them transmitted by us to another personal data controller.
Right to object
If we process personal data on the basis of our legitimate interest, you have the right to object to such processing. If you file such an objection, we will not be able to process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests or rights and freedoms, or for the establishment, exercise or defense of our legal claims. In case we process your personal data for marketing purposes based on our legitimate interest, we will terminate the processing without undue delay upon receipt of the objection.
Right to withdraw consent
If processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on the consent given before its withdrawal.
Right not to be the subject of automated decision-making
Except where processing is necessary for entering into, or performance of, a contract, where this is permitted by applicable law, or based on your express consent, you have the right not to be the subject of any decision which is based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you to a significant extent.
Right to lodge a complaint with the supervisory authority
If you believe that we are processing your data in violation of the relevant legal regulations. Based on our registered office, you can file a complaint with the Federal Trade Commission (FTC).

DATA PRIVACY FRAMEWORK COMPLIANCE
We comply with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF“) as set forth by the U.S. Department of Commerce.  We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  If there is any conflict between this Notice and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https: https://www.dataprivacyframework.gov/
Certification to the DPF Program
We ensure collection, use, and retention of personal data comply with the EU-U.S. DPF Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability, as specified in this document.
Recourse, enforcement and liability
If we are unable to resolve your complaint relating to our processing of your personal data, you may submit your unresolved concern to the panel established by the EU data protection authorities (DPAs), in accordance with the EU-U.S. DPF. We are committed to cooperating with the DPAs and complying with their guidance regarding data protection complaints related to personal data received under the EU-U.S. DPF.
In case if we are unable to resolve a complaint through the DPAs, you may be able to invoke binding arbitration for residual claims not otherwise resolved by other recourse mechanisms. If your complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms). For more information about binding arbitration, please see the Annex I of the EU-U.S. DPF here: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction.
We note that we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission regarding privacy and data protection matters.

CHANGES TO THIS NOTICE
It may be necessary for us to make changes to this Notice consistent with the regulatory requirements, so please check this page occasionally. We will announce any material changes to this Notice via channels appropriate to our relationship with you.