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Privacy policy

Stocktraderpro, RubiCap d.o.o (hereinafter also referred to as “STP“, ˝we˝, or ˝us˝) issues this privacy policy, in which you will find all the information about the processing of personal data carried out by us.

In this privacy policy you will find:

  • information about what personal data we collect and process about you,
  • how we use that information (for what purposes),
  • when we share data with third parties,
  • how long we keep it,
  • what rights you have in relation to the processing of your personal data.

This privacy policy is intended to:

  • Users of the Stocktraderpro Platform and
  • users of our website.

Basic definitions:

In this section, we provide you with the basic definitions we use in this Privacy Policy. In the event that a particular term is not defined below, the definition derived from relevant legislation shall apply.

Personal data is any information relating to an identified or identifiable individual (this includes, for example, first name, last name, email address, telephone number, as well as identifiers that can identify you as an individual, such as information about the use of our website, etc.).

Controller means the legal person who determines the purposes and means of the processing of your personal data. The controller of your personal data is STP.

Processor means a legal or natural person who processes personal data on behalf of the Controller. These are third parties who assist us in the performance of certain services or obligations that we have. For more information on processors, please see Section 3 of this Policy.

Processing means the collection, storage, access and any other use of personal data.

1. Who manages my personal data?

Contact details of the controller:

2. How do you use my personal data?

At STP, we make sure that we only ever process your personal data for lawful and pre-declared purposes. If in the future there is a need for further processing of personal data (for additional purposes), we will inform you in advance in this policy. At STP, we only process personal data on the relevant legal bases set out in applicable law.

Am I obliged to provide my personal data?

It is only mandatory to provide the personal data we process in order to comply with our legal obligations.

When you provide us with personal data in the context of a contract or on the basis of your consent , the provision of personal data is always voluntary.

However, please note that if you do not provide us with personal data, we may not be able to provide you with certain services (e.g. we cannot provide you with access to the Platform if you do not provide us with the information we need for registration).

Please see the table below for a description of the processing we carry out at STP:

Purpose Legal basis Types of personal information Storage period
Registering a user account Contractual relationship Username, email, payment card details For the duration of the contractual relationship and for 5 years after the end of the contractual relationship
Register a user account via your Facebook account, Gmail account or Apple ID Contractual relationship Username, your FB, gmail account details or Apple ID, payment card details For the duration of the contractual relationship and for 5 years after the end of the contractual relationship
Creating and using a profile Contractual relationship Username, email, profile photo, About information shared by the user, device information For the duration of the contractual relationship and for 5 years after the end of the contractual relationship
Sending newsletters to our users The law Email Until revoked
Sending newsletters to registered individuals Consent Email Until revoked
Performing basic segmentation when sending newsletter based on subscription type Legitimate interest in providing adequate information to users Username, email, subscription type, trial period information For the duration of the newsletter
Communicating with potential users and responding to enquiries Legitimate interest in ensuring effective communication Email, enquiry details 1 month after cessation of communication
Keeping records of free-trial only users Legitimate interest of fraud prevention Email 5 years until the expiry of the free trial period
Conducting user satisfaction surveys Legitimate interest in ensuring business performance Email, individual survey data 1 month after the survey
Carrying out statistical analyses on the use of the app Legitimate interest in optimising and improving the product Only aggregated data on how the app is used is collected and processed Data shall be anonymised immediately after collection and converted into non-identifiable aggregates
Carrying out statistical analyses of website usage Legitimate interest in optimising and improving the website Only aggregated data on how the website is used is collected and processed Data shall be anonymised immediately after collection and converted into non-identifiable aggregates
Performing an overview of the performance data on the receipt of emails Legitimate interest in providing access to the service to our users Email, date and time of dispatch, delivery status For the duration of the contractual relationship and for 5 years after the end of the contractual relationship

3. Who do you share my personal data with?

In addition to STP, personal data is processed on our behalf by our processors, namely: IT support providers for the processing of personal data, online advertising agencies, marketing automation tools and payment service providers.

Personal data of customers is exported to third countries. In the event of personal data being exported outside the EU, we ensure that appropriate security measures are in place to ensure the same level of protection for personal data as is required within the EU.

We only allow contractual processors to process personal data on the condition that they have a sufficient level of protection of personal data as set out in the applicable data protection legislation.

We have appropriate agreements in place with all our contractual processors, which specify the processing of personal data carried out by each processor.

4. How do you protect my personal data?

At STP, we are committed to ensuring the security of your personal data and we use a variety of technical and organisational measures to protect your personal data from destruction, erasure, unauthorised access and unauthorised consultation and access, and any other unauthorised modification.

We never rent, sell or allow the personal data we hold to be processed by any third party other than our contractual processors as defined in this policy.

Personal data may only be processed by persons authorised to do so by us or our contractual processors.

We amend and update our data protection rules in line with changes in data protection legislation.

In the event of a security incident that could result in consequences for individuals, we will notify the Information Commissioner within 72 hours of the identification of the security incident.

In the event that there are serious consequences for individuals, we will also notify the individuals affected by the security incident.

5. What rights do I have?

You have the rights set out below in relation to the processing of your personal data. You can exercise all your rights by writing to us at info@stocktraderapp.com.

We will respond to your request within one month; in the case of more extensive requests, we have the right to extend this period reasonably.

In order to comply with your request, we have the right to verify your identity. For this purpose, we may request additional personal data from you to ensure reliable identification. If you do not provide us with the additional information, or if we are unable to provide reliable identification, we have the right to refuse the request to exercise the rights.

You have the right to:
  • Access to your personal data: you have the right to request confirmation of whether we are processing your personal data and information about the processing (purposes of processing, legal basis, retention period, users of the personal data). If we process your personal data, you have the right to access and extract this data.
  • Rectification of personal data: if the personal data we process about you is inaccurate or incomplete, you have the right to request rectification of your personal data.
  • Withdrawal of consent: you can withdraw your consent at any time without any negative consequences for you. If you withdraw your consent, we will no longer be able to provide you with certain services (e.g. if you withdraw your consent to receive our newsletter, you will no longer receive this newsletter).
  • Erasure of personal data: you have the right to request that we erase the personal data we process about you. The right to erasure of personal data is not absolute, as we cannot erase data that we need, for example, for the performance of a contract or that we are required by law to retain.
  • Restrictions on the processing of personal data: you may request that we temporarily restrict the processing of your personal data in the following cases:
    • where you have lodged an objection to processing and an overriding legitimate interest test is underway,
    • where the processing has been unlawful and you request a restriction of processing instead of erasure,
    • where the purpose of the processing is fulfilled and you need the data for the defence or exercise of legal claims,
    • where the accuracy of the personal data is being verified.
  • Portability of personal data: you have the right to request to receive your personal data in a structured, machine-readable format. You also have the right to transmit this data to another controller. The right to data portability applies to personal data based on your explicit consent or a contractual relationship and to processing carried out by automated means.
  • Objection to the processing of personal data: you may object to the processing of personal data where the processing is based on legitimate interests, including profiling based on the processing referred to above. In the event of an objection, we will cease the processing unless it is established that there are compelling legitimate interests which override your rights and freedoms. Where personal data is processed for marketing purposes, you have the right to object at any time to the processing of personal data for marketing purposes, including profiling. If you object, we will no longer process your data for direct marketing purposes.
  • Lodging a complaint with a supervisory authority: If you consider that there have been irregularities in the processing of your personal data, you have the right to lodge a complaint with a supervisory authority. The competent supervisory authority for Slovenia is the Information Commissioner.

6. How long do you keep my personal data?

We only keep your personal data for as long as is necessary to fulfil the purposes of the processing of your personal data. After the expiry of the respective retention periods, we will delete (or destroy) or anonymise the personal data so that individuals can no longer be identified. An overview of the retention periods in relation to the processing purposes we carry out can be found in the table above.

7. Web plugins

We allow the use of the following plug-ins on our website: Facebook, Instagram and LinkedIn. If you use these plug-ins, please note that the use of social networks is entirely at the discretion of the respective social network. Each social network is subject to separate rules and conditions which are not related to ours; the same applies to the processing of personal data handled by each social network. We remind you that you are responsible for any posts and interactions with social networks and that you are obliged to address any questions or exercise your rights to the respective social network.

To make it easier for you to access the information, we provide links to the privacy policies of each social network:

8. Final provisions

We may change this Privacy Policy at any time. The latest version of the policy will always be available to you at Privacy Policy