Privacy Policy Last updated: 24/02/2024

We, referred to as “Us” or “Our,” are committed to protecting your Personal Data and ensuring your privacy is respected and safeguarded.

This Privacy Policy explains how we collect, store, manage, and use the information you provide while using the Invest Legacy platform (the “Website”).

We follow key principles, including:

• Transparency in Data Collection and Use:

We strive to keep you informed at every stage of data collection and use, so you can make well-informed decisions regarding your personal information on our Website or when accessing services through affiliated third-party trading platforms.

If additional details are needed, we provide clear and timely explanations. Should you have any questions, you're welcome to contact us at: [email protected].

• Purpose-Based Processing:

Your data is processed solely to deliver and enhance the services we offer, ensure legal compliance, support business operations, and improve user experience. These include providing access to the Website, connecting users with third-party trading platforms, and maintaining service quality.

• Respecting Your Data Rights:

You have the right to access, correct, delete, restrict, or transfer your Personal Data. We allocate appropriate resources to facilitate your data rights, and will process such requests in accordance with applicable data protection laws.

• Security Measures:

Although no method of transmission or storage is 100% secure, we implement robust safeguards to protect your data against unauthorized access or misuse.

Detailed Privacy Policy

1. Scope:

This policy outlines what personal data we collect, how we use it, the legal basis for processing, and how it may be shared. “Personal Data” refers to information identifying you as an individual or relating to an identifiable person.

2. When We Collect Data:

We collect your Personal Data when you visit the Website, access our services, communicate with us, or use our forms or partner tools. In some cases, this includes data shared with us by our third-party affiliates or service providers.

3. Your Consent and Choice:

You are not obligated to provide Personal Data; however, certain services may not function properly without it. For example, registration, account access, and support features may require you to provide essential information.

4. Types of Data We Collect:

  • Usage Data: IP address, browser type, device type, pages visited, timestamps, crash reports, language preferences, and geographic data. Some of this is anonymous and not always personally identifiable.
  • Directly Provided Data: Name, email, phone number, and other details submitted when interacting with forms or third-party trading platforms via our Website.

Our platform is intended for users aged 18 and above. We do not knowingly collect or store data from individuals under the age of 18. If we learn that such data was submitted, we will take appropriate steps to delete it promptly.

5. Purposes for Processing Personal Data and Legal Basis

Invest Legacy processes your Personal Data for specific, clearly defined purposes, each supported by a valid legal basis. We only handle your information when we are legally permitted to do so.

These legal bases may include:

  • Consent: You have explicitly consented to the processing of your data for defined purposes — for example, when you submit personal information via our Website to connect with third-party trading platforms.
  • Legitimate Interests: Processing is necessary for purposes such as improving service quality, maintaining security, or managing legal claims.
  • Legal Obligations: We are required to process your data to comply with applicable laws and regulatory requirements.

If you have questions about how your data supports the operational or legal interests of Invest Legacy or its partners, feel free to contact us at [email protected].

The table below outlines typical processing activities and their associated legal justifications:

Purpose Legal Basis
1 Forwarding data to third-party trading platforms
When requested by you for trading purposes.
Consent
2 Responding to inquiries or support requests Legitimate interest
3 Compliance with legal obligations or authorities Legal obligation
4 Improving our services
Including analysis of service logs or errors.
Legitimate interest
5 Preventing misuse and fraud Legitimate interest
6 Internal operations
Including planning, oversight, and strategic development.
Legitimate interest
7 Statistical and analytical insights
Used to refine service offerings.
Legitimate interest
8 Protection of legal rights
Including litigation or enforcement of terms and policies.
Legitimate interest

6. Transfer of Personal Data to Third Parties

Invest Legacy may share your Personal Data with trusted third-party service providers who support us with services such as data hosting, analytics, technical support, user experience research, and performance diagnostics.

If you request or authorize it, we may transfer certain Personal Data—such as your name, email, or phone number—to third-party trading platforms. These platforms will process your data according to their own privacy policies. We may collaborate with multiple such third parties to ensure access to a wider range of trading services.

We may also disclose Personal Data to our affiliated companies and partners who help us improve the services and resources we offer. These transfers are made with appropriate safeguards in place to protect your information.

Personal Data may be disclosed to government agencies, regulatory authorities, or law enforcement officials when such disclosure is legally required or necessary to protect our rights, users, or to comply with applicable laws and obligations.

In case of a business transaction — such as a merger, acquisition, reorganization, asset sale, or bankruptcy — we may transfer relevant Personal Data to buyers, investors, or legal successors, provided they agree to maintain comparable levels of privacy protection.

7. Cookies and Third-Party Services

We use cookies and similar technologies on our Website to enhance your browsing experience and tailor content to your preferences. Some third-party services we integrate—such as analytics providers or advertising platforms—may also use cookies. These services operate under their own privacy policies.

A cookie is a small text file stored on your device when you visit a website. Cookies help remember your activity, preferences, and enhance website functionality. They also support analytics and provide insights into user behavior.

We use two primary types of cookies:

  • Session cookies: Active only during your browser session and deleted when you close your browser.
  • Persistent cookies: Remain on your device until their set expiration date or until manually deleted.

Types of Cookies We May Use:

Cookie Type Purpose Details
Strictly Necessary Enables core website functionality such as page navigation, account access, and secure areas. May store login data or session tokens. These cookies are deleted once the session ends.
Functionality Remembers your preferences (e.g., language, location, layout). Persistent cookies that enhance your personalized experience on repeat visits.
Performance Collects anonymized data on how users interact with the Website to improve performance and content delivery. Data is aggregated and used for statistical purposes only. Cookies may vary in lifespan.

Blocking and Removing Cookies

You have the option to manage your cookie preferences through your browser settings. This includes blocking or deleting some or all cookies at any time. Below are resources for cookie management in common web browsers:

Please note that disabling cookies may impact the availability and functionality of certain features on our Website.

Online Tracking Notice

Currently, our Website does not respond to Do Not Track (DNT) signals from browsers.

8. Retention of Personal Data

We retain your Personal Data only for as long as it is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law or regulatory obligations.

Where applicable, we may retain and share your Personal Data with third-party trading platforms for a period of 12 months, with an optional extension for another 12 months upon your consent.

We regularly review stored Personal Data to ensure it is relevant, necessary, and up to date. Data that is no longer needed is securely deleted or anonymized.

9. Transfers of Personal Data to Third Countries or International Organizations

Your Personal Data may be transferred to jurisdictions outside of your country of residence. In such cases, Invest Legacy ensures that adequate safeguards are in place to maintain the privacy and security of your data in accordance with applicable data protection laws.

If you reside in the European Economic Area (EEA), we will ensure that one of the following applies:

  • The destination country is recognized by the European Commission as providing an adequate level of protection for Personal Data (per Article 45 of the GDPR).
  • The transfer is based on legally binding agreements between public authorities or organizations (per Article 46(2)(a) of the GDPR).
  • The transfer is subject to Standard Contractual Clauses approved by the European Commission (per Article 46(2)(c) of the GDPR). Details are available at this link.

For jurisdictions such as Hong Kong, your Personal Data will be handled in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) and any applicable international standards where relevant.

10. Protection of Your Personal Data

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks associated with the processing of Personal Data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

However, while we strive to safeguard your Personal Data, no system or transmission of data over the internet can be fully secure. Accordingly, we disclaim liability for any loss, misuse, unauthorized access, disclosure, or alteration of your Personal Data, unless it results from our proven negligence or willful misconduct.

In some cases, legal or regulatory obligations may require us to transfer your Personal Data to public authorities or other third parties. We will only do so when legally obligated and will seek to ensure such transfers offer adequate protection.

11. Links to Third-Party Websites

Our Website may include links to third-party websites or applications that are not operated or controlled by Invest Legacy. We are not responsible for the content, security, or privacy practices of those websites or services.

We strongly encourage you to read the privacy policies of any external websites or services you visit before submitting any Personal Data.

13. Your Rights Regarding Your Personal Data

Depending on your jurisdiction, including if you are a resident of the European Economic Area (EEA) or Hong Kong, you may have the following rights regarding your Personal Data:

  • Right of Access: You may request access to the Personal Data we hold about you and receive details about its processing.
  • Right to Rectification: You may ask us to correct any inaccurate or incomplete Personal Data we hold about you.
  • Right to Erasure ("Right to be Forgotten"): In certain cases, you may request deletion of your Personal Data.
  • Right to Restrict Processing: You may request that we limit the processing of your Personal Data under specific circumstances.
  • Right to Data Portability: You may request a copy of your Personal Data in a structured, commonly used, and machine-readable format.
  • Right to Object: You may object to the processing of your Personal Data for certain purposes, including direct marketing.
  • Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing before the withdrawal.
  • Right to Lodge a Complaint: You have the right to file a complaint with a data protection authority in your jurisdiction.

To exercise your rights, please contact us at: [email protected]. We may need to verify your identity before fulfilling your request.

Right to Lodge a Complaint

If you believe your privacy rights have been violated or your Personal Data has not been handled in accordance with applicable data protection laws, you have the right to lodge a complaint with a data protection authority.

For residents of the European Economic Area (EEA), you may file a complaint with the supervisory authority in your country of residence.

For residents of Hong Kong, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD):

Office of the Privacy Commissioner for Personal Data, Hong Kong
Address: 12/F, Sunlight Tower, 248 Queen’s Road East, Wanchai, Hong Kong
Website: https://www.pcpd.org.hk/
Tel: +852 2827 2827

Contacting Us

If you wish to exercise any of your rights, withdraw consent, or have questions regarding this Privacy Policy or how your Personal Data is handled, you may contact us at:

Invest Legacy
Email: [email protected]
(Please include your full name and the nature of your request to help us respond effectively.)

Policy Updates

We may update this Privacy Policy periodically to reflect changes in legal obligations or data processing practices. If material changes are made, we will notify you via the Website or by other appropriate means prior to the change becoming effective.

Please review this Policy regularly. Continued use of our Website or Services after updates constitutes acceptance of the revised terms.

Right to Lodge a Complaint with a Supervisory Authority

If you believe your rights regarding your Personal Data have been infringed, you have the right to lodge a complaint with a relevant supervisory authority.

For residents of the European Economic Area (EEA):
You may file a complaint with the supervisory authority of your habitual residence, place of work, or the place of the alleged infringement within the EEA.

For residents of Hong Kong:
You may contact the Office of the Privacy Commissioner for Personal Data (PCPD) to file a complaint under the Personal Data (Privacy) Ordinance (Cap. 486).

Contact details for the PCPD:
Address: 12/F, Sunlight Tower, 248 Queen’s Road East, Wanchai, Hong Kong
Tel: +852 2827 2827
Website: https://www.pcpd.org.hk/

Your rights concerning your Personal Data, as described in this section, may be limited by applicable laws in the European Union, its Member States, or under Hong Kong law, to which the Company is subject.

We aim to respond to your request regarding your data protection rights promptly and, in any case, within one (1) month of receiving your request. If the request is complex or we receive numerous requests, we may extend this period by two (2) additional months and will inform you of the delay along with its justification.

Requests made under this section are typically handled free of charge. However, if a request is clearly unfounded, repetitive, or excessive, we reserve the right to either charge a reasonable fee reflecting administrative costs or refuse to act on the request.

To ensure your data is protected, we may require you to verify your identity before processing any request. This helps us ensure your Personal Data is not disclosed to any person who has no right to receive it.

12. Updates to This Policy

We may revise this Privacy Policy from time to time. In the event of material changes, we will notify you through prominent notice on our Website, or by other means as appropriate, prior to the changes becoming effective.

All updates will be published on this page with the “Last updated” date at the top. We encourage you to review this Policy periodically to stay informed about how we are protecting your data.