“INVESTMARKET®”,”Investmarket“, “us,” or “we“) are committed to protecting your privacy. This Privacy Statement describes Investmarket’s information practices and the choices available to you regarding Investmarket’s use of information that can be used to identify you (“Personal Data“). If you are in the European Union (“EU“), please pay particular attention to the information for EU users in Section 5 below.
This Privacy Statement addresses Investmarket’s use of information collected through any of our web properties (collectively, the “Sites“) or our software or maintenance products (collectively, “Products“). We will only collect and use information from you as described in this Privacy Statement. We will not sell your data to any third parties.
If you have any questions about our Privacy Statement, you can contact our Data Privacy Officer at firstname.lastname@example.org.
- The Data We Process; Purposes of Processing
Depending on how you interact with us, we process different kinds of data and in different ways. Some data is automatically processed if you visit our Sites or use our Products. Other data is only processed if you actively submit it to us (like using our web forms to get in touch with us or uploading content to our Sites).
Data we process if you visit our Sites:
Even if you are only a visitor on one of our Sites, your computer or device automatically sends technical information to our web servers that we store in log files, including the following “Website Usage Data“:
- Date and time of the visit and the duration of use of the Site;
- The IP address of your device as well as your internet service provider (ISP);
- The referral/exit URL;
- The visited subsites of the Site;
- Clickstream data; and
- Information about your device (type of device, browser type and version, as well as settings, installed plug-ins, operating system).
We process Website Usage Data to allow you to surf the Site and to ensure its functionality. We also process Website Usage Data to perform analyses on the performance of the Site, to continuously improve the Site and correct errors, to ensure IT security and operation of our systems, as well as to prevent or uncover abuse. We further process this data in aggregated or pseudonymized form to analyze trends, administer the Sites, track users’ movements around the Sites, and to gather demographic information about our user base as a whole or to improve marketing (including serving you personalized, interest-based ads) as well as the user experience on our Site and guaranteeing the safety of our IT systems.
Data we process if you use our Products:
Investmarket® processes Personal Data when you install and register one of our Products. Some of this information will be processed automatically when installing our Products. This includes the following “Product Installation Data“:
- your browser type
- operating system
- device hardware
- other software on your system
- IP address
- product version
We request certain “Product Registration Data” during installation of our Products. Although only email address is mandatory for registration, we may ask you to submit other information, including:
- your name
- postal address, including country
- telephone number
We use Product Installation Data and Product Registration Data to keep a record of your product license (that is, authenticating and periodically verifying your licensing rights in the product for anti-piracy purposes) and to enable the provision of maintenance or support services to you. We will also use this information to provide in-product messaging with information about products, features, or services offered by Investmarket®.
We collect information about the way you use our Products after you have installed and registered them. The specific “Product Usage Data” varies depending upon which Product you are using, but may include:
- Launch data
- Hardware fingerprint
- Feature usage
- Page clicks
- Sign-in information
We process Product Usage Data so that we can facilitate, evaluate, and verify your use of our products and services. We will also use the Product Usage Data for our own internal statistical and analytical purposes, and to evaluate and enhance users’ experience of the Products by identifying customer preferences and analyzing crash data.
In addition, certain of our products may allow you to store, send, receive, edit, sync, share, or otherwise organize or manage files and folders (including any information or data stored in those folders) (“User Files“). We will record and store information regarding the size and name of all User Files that you make available via these Products.
Data we process only if you submit it to us:
When you interact with us on our Sites or using our Products, you can submit Personal Data to us in various situations, including:
Account Data: On some of our Sites (“Interactive Sites”), you can register for an account with your e-mail address and a password you create. If you register one of our Products, you will automatically create an account you can use to manage your licensed Products and communication settings, including making updates to your Personal Data. On Interactive Sites, you can create a profile, which may include your Personal Data. We will store your account data for you to be able to communicate with others on our interactive Sites. Some of our Interactive Sites offer publicly accessible blogs or forums. Any information you provide in these areas may be read, collected, and used by others who access them with a registered account as well as anyone surfing the community pages as an unregistered user.
Transaction Data: In relation to purchases you may make online or over the telephone, we will process your contact and billing information, such as your name, address, and credit card information. You can view the exact information required in the form provided at point of purchase. We will only use this data to complete your order, for billing purposes, and for internal accounting.
Customer Support Data: You can communicate with us through the different web-forms and chat functionalities on our Sites. For example, you can use the contact forms to request technical assistance, request information on the status of your order, or otherwise reach out to our customer support team. In order to respond to your request, we will process your IP address and contact data as well as the contents of your request. We will delete this data as soon as we have complied with your request.
Survey Data: From time to time we may conduct surveys in respect of our products and services. Participation in our surveys is optional. However, if you respond to one of our surveys, you may provide us with personal information about you. Unless you otherwise consent, we will only use this information to determine the types of Products that may be of interest to you and to operate and improve our Product offerings.
Email/Direct Mail Campaign Data: From time to time, we may contact our customers directly by mail, email, or telephone to inform you about upgrades, new products, promotions, or special offers that you told us you were interested in receiving (including our newsletters). However, we will not contact you with any commercial communications that are unrelated to the Products that you have purchased from us unless you have given us your prior consent to receiving such information. When responding to one of these campaigns, you may have the option to provide us with personal information, which we will use for the purpose indicated. See Section 5 below for information on how to change your account’s communication preferences.
Special Collaborative Programs: We may collaborate with another company to provide you with a unique product or service (a “Collaborative Program“). Our use of your Personal Data is limited to the specific Collaborative Program that you have joined or elected to use and we will disclose to you the specific Personal Data we will share and for what purpose before sharing with our collaboration partner.
Applicant Data:If you would like to apply for employment with Investmarket, you can apply online at www.investmarket.eu, on our Careers page. We will process your application data solely for the purpose of responding to your application. Your data will be deleted within two years after finalizing your application unless you give us your explicit consent to keep your application on file to contact you with further job offers in the future.
Business Contact or Sales Prospect Data: If you are a business contact or sales prospect that has provided us your Personal Data, we will store your data in our database so that we can follow up on previous business conversations we’ve had with you, provide you additional information about our Products, or assist you in purchasing our Products. We may also share your Personal Data with sales representatives employed with our local affiliates or resellers so that they can work with you to complete any requested purchase of our Products.
- Sharing Personal Data with Third Parties
We treat your Personal Data with care and confidentially and will only pass it on to third parties to the extent described below and not beyond. We do not share, sell, rent, or trade Personal Data with third parties for any promotional purposes. Where our affiliates, resellers, or service providers process Personal Data, they will do so solely on our instructions and have undertaken to comply with strict contractual requirements for the security of your data (including, but not limited to, complying with this Privacy Statement).
Affiliated Companies: Investmarket® is a global company, with partners worldwide, including in the UE, USA, Germany, the UK, Japan, China, and Taiwan. We share data with our subsidiaries in the ordinary course of our business. For example, if one of our resellers makes contact with you on our behalf, this data will be shared with the relevant Investmarket® subsidiary, such as Investmarket GmbH in Germany. For an overview of our affiliates, you can refer to the Contact Us page at https://investmarket.eu/contact/ to view the mailing addresses of our local affiliates.
Service Providers: Investmarket® transmits data to service providers that enable us to provide our Site and market, sell, and deliver our Products. This includes the parties providing our third-party cookies and tracking tools, as well as parties providing us with services to assist us in processing transactions, including credit card transactions, handling shipping and processing of orders, providing customer support, managing customer relationships (like paypall.com), hosting the Sites (like Amazon Web Services), collecting, storing, or removing your information, or performing statistical analysis of our Sites (such as Google). We occasionally also share Personal Data with independent auditors acting on our behalf, for anti-piracy or revenue accounting purposes in connection with the internal operations of our business. We sometimes need to share your information with these companies in order for them to provide the applicable services.
Business Transactions: In the event Investmarket® goes through a business transaction such as a merger, an acquisition by another company, or a sale of all or a portion of its assets to which this Privacy Statement relates, your information will likely be among the assets transferred and, in such case, you will be notified in advance via email and/or a prominent notice on our Sites of such change in ownership or a change in the use of your Personal Data, as well as any choices you may have regarding your Personal Data (including, if applicable, your right to object to such transfer).
Public Authorities: Although we make every effort to preserve user privacy, we may need to disclose personal information when required by law, such as when we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order, or litigation or other legal process or action (whether or not initiated by Investmarket®) to protect Investmarket’s, our users’ or third parties’ rights, property or safety. We will transmit data to public authorities such as law enforcement or tax authorities only in the case of a legal obligation to do so based on a request for information from the respective authority.
Promotional Offers: As a registered Investmarket® customer, you have the opportunity to receive news and special offers from Investmarket® regarding our Products or the products of third parties who we think may offer products or services that would be of interest to you.
- Timeframe for Keeping Data
We process and store your Personal Data as long as necessary for the fulfillment of our contractual or legal obligations. Thus, we store the data as long as our contractual relationship with you as our customer obliges us to do so. After termination of our contract, we will store Personal Data only to the extent and for as long as applicable law requires. All other data will be deleted immediately when you, as a customer, unsubscribe from our Products or other services. If the remaining data is no longer required for the fulfillment of legal obligations, it will be regularly deleted, unless its further processing is necessary for the preservation of evidence or the prevention of legal claims from becoming time-barred.
- Reviewing and Requesting Changes to Your Information
EU users: please refer to Section 6 below for your statutory rights under the GDPR
Upon request, Investmarket® will make a reasonable effort to inform you regarding whether we hold any of your personal information. Customers may update, delete, access, or change their account information by editing their user, group, or team records. To update a customer profile, login to your account at www.investmarket.eu and click on “My Account”, or email us a email@example.com. We will respond to any requests for access to personal information within 30 days after receipt of such request.
To update customer billing information, contact Accounts Receivable firstname.lastname@example.org for assistance.
If you have signed up to receive marketing emails from Investmarket®, you can opt-out of receiving future marketing emails by following the foregoing process. Customers cannot opt-out of receiving all transactional emails related to their Investmarket® account, but may change their account settings (as described above) to reduce the frequency or eliminate certain Investmarket® notification emails.
- Information for EU Residents:
Privacy-related questions can be directed to: email@example.com.
You are not legally required to provide Investmarket® with the Personal Data described in this Privacy Statement. Further, the contractual relationship that you might have entered into with us by purchasing our Products does not imply any obligation to provide your Personal Data. However, you might not be able to use our Service to the full extent if you do not provide us with certain data or object to the use of these data.
Our Legal Basis for Processing
When processing your Personal Data, we rely on the General Data Protection Regulation (“GDPR“), an EU-wide legal framework for the standardization of data protection. InvestMarket® primarily processes data as a controller, for the purposes explained above under Sections 1 and 2 of this Privacy Statement. These purposes represent our legitimate interests for the purposes of Article 6 (1) f) GDPR. At the same time, some of the Personal Data we process is necessary for us to perform a contract with you or in order to take steps at your request prior to entering into a contract with you. For example, if you express your interest in purchasing one of our Products, such as by filling out a webform, we will process the Personal Data submitted to comply with your request. This may include sharing your Personal Data with one of our authorized resellers, who will then use your Personal Data to complete the purchase transaction. In addition, we are legally obliged to provide certain information to criminal prosecution or tax authorities in individual cases upon request. In these cases, the legal basis for the processing is either legal requirements (Article 6 (1) c) GDPR) or reasons of public interest (Article 6 (1) e) GDPR).
Transferring your Data outside the EU or the EEA
Investmarket’s principal place of business is in UE. Investmarket still provides an adequate level of protection for your Personal Data – decision 2002/2/EC of the EU Commission states is deemed to provide an adequate level of data protection regarding commercial organizations such as Investmarket®.
We have ensured that our service providers and affiliates have either certified under the EU-U.S. Privacy Shield Framework and will process all Personal Data received from EU member states in reliance on the Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee that an adequate level of data protection for your data is guaranteed.
We use your data for “Profiling“. This means that we use your data to make tailored offers based on your previous behavior as well as to serve you personalized ads. However, we will never process and analyze your Personal Data in the context of Profiling in a way would lead to an automated decision that has a legal effect on you or significantly impairs you in a similar way.
Your rights regarding the processing of your Personal Data
As a natural person, you have certain rights as “Data Subject“. You can assert the following rights against us under the GDPR:
Your right to information and access under Article 15 GDPR,
Your right to correction under Article 16 GDPR,
Your right to erasure under Article 17 GDPR,
Your right to restriction of processing under Article 18 GDPR, and
Your right to data transferability under Article 20 GDPR.
In addition, you have a right of objection to the competent data protection supervisory authority under Article 77 GDPR, but only with respect to the data processing we conduct on our own behalf, as a controller. In the event InvestMarket acts as a processor of your data for a third party, you must refer to the entity acting as controller to assert this right.
Information about your Right of Objection under Article 21 GDPR
- Right of objection in individual cases
In addition to the rights already mentioned, you have the right, for reasons arising from your particular situation, to object at any time to the processing of Personal Data relating to you, which is processed on the basis of Article 6 (1) e) GDPR (data processing in the public interest) and Article 6 (1) f) GDPR (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Article 4 (4) GDPR. If you file an objection, we will no longer process your Personal Data unless we can prove compelling grounds for the processing that outweigh your interests, rights and freedoms or the processing serves to assert, exercise, or defend legal claims. Please also note that, if we terminate the processing due to your objection, the Sites or Products may no longer be available to you or only to a limited extent.
- The right to object to the processing of data for advertising purposes
You also have the right to object at any time to the processing of your Personal Data for the purpose of direct marketing, including any subscription to our newsletters or personalized ads; this also applies to Profiling, insofar as it is associated with such direct marketing. If you object, we will no longer process your Personal Data in the future.
The objections can be made form-free and should be addressed to: firstname.lastname@example.org
- Collecting Information from Children
Investmarket’s Sites are not intended for use by children under the age of 18 and we do not intentionally collect any information from users under the age of 18. If a parent or guardian becomes aware that their child has provided Investmarket with Personal Data or that we have otherwise inadvertently collected this information, contact us at email@example.com, so that we may immediately delete the information from our servers.
InvestMarket® reserves the right to change this Privacy Statement. We will provide notification of the material changes to this Privacy Statement through our Sites at least 30 days prior to the change taking effect.
Last Updated: May 2020