GDPR

I. Basic Provisions

1. The data controller is AMERRY SERVICES LTD., located at 68 BEDFORD ROAD, READING, ENGLAND RG1

2. 7HR, company number: 13464211 (hereinafter referred to as the "Administrator").

3. The contact details of the Administrator are:
1. Email: info@skip-trading.cz

4. Personal data refers to any information about an identified or identifiable individual, such as the User's first and last name, home address, date of birth, contact information (email, phone), identification number on a national ID or passport, photographs, or any other necessary data required particularly under anti-money laundering regulations (AML).

5. The Administrator has not appointed a data protection officer.

II. Reason and Purpose of Processing Personal Data

1. Personal data is processed for the purpose of using the historical market simulator of assets called SKIP Trading/training mobile application ("Application") by individual users (Users) on their mobile devices, where they download the Application. Further conditions for using the Application are defined in the General Terms and Conditions, where some capitalized terms used in this document are also defined.

2. The Administrator processes personal data provided by the User (during registration and verification in the Application) or personal data obtained by the Administrator based on the User's use of the Application.

3. The Administrator processes identification, contact data, and other data of the User necessary for fulfilling the Contract, as described above, including keeping statistics on the use of certain functionalities of the Application as well as facilitating the use of the Application.

4. The legal basis for processing personal data is

• the fulfillment of the contract between the User and the Administrator;
• consent to the processing for the purpose of providing direct marketing (particularly for sending commercial communications and newsletters).

5. The purpose of processing personal data is:

• to identify an individual interested in becoming a User and using the trading simulator (Application), which is also related to fulfilling financial obligations that may arise,
• to comply with regulations based on anti-money laundering laws (AML),
• sending commercial communications and conducting other marketing activities.

6. The Administrator engages in automated individual decision-making within the meaning of Article 22 GDPR. The User gives explicit consent to such processing.

7. All personal data obtained through the Application is processed in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals concerning the processing of personal data and on the free movement of such data (GDPR) and applicable national regulations issued under GDPR. The interest of the Administrator is to ensure the protection of the rights and freedoms of individuals providing their personal data. Providing personal data by the User is entirely voluntary; however, certain personal data is mandatory for the provision of services by the Administrator within the Application.

III. Data Retention Period

1. The Controller retains personal data

• for the period necessary to exercise rights and obligations arising from the contractual relationship between the User and the Administrator and to enforce claims from these contractual relationships (for a period of 10 years from the termination of the contractual relationship);
• until consent to the processing of personal data for marketing purposes is revoked, for a maximum of 10 years, if the personal data is processed based on consent.

2. After the retention period, the Administrator will delete the personal data.

IV. Recipients of Personal Data

1. Recipients of personal data are entities:

• involved in payment processing (payment gateway), if they do not already hold the User's personal data,
• providing marketing services, if such exist,
• state authorities, if such entitlement arises from legal regulations.

2. The Administrator does not intend to transfer personal data to a third country (to a country outside the EU). Recipients of personal data in third countries can only be providers of mailing or cloud services.

V. User Rights

1. Under the conditions set forth in the GDPR regulation, the User has the right to:

• access their personal data;
• rectify personal data, or restrict their processing in accordance with Article 18 GDPR;
• request the deletion of personal data;
• object to processing if the Administrator does not process their personal data based on legitimate interest;
• data portability to another data Administrator (in a structured, commonly used, and machine-readable format);
• withdraw consent for processing, whether for all or only certain purposes, in writing or electronically to the address or email of the Administrator provided in these Privacy Policy Terms.

2. More detailed conditions or explanations of the aforementioned rights of the User are provided in the GDPR regulation, which is freely available on the internet.

3. The User has the right to file a complaint with the Office for Personal Data Protection if they believe their right to personal data protection has been violated.

VI. Conditions for Personal Data Security

1. The Administrator declares that they have taken all appropriate technical and organizational measures to secure personal data. The form that the User fills out during registration, as well as the authorization process (login) for accessing resources in the Application, is based on a secure SSL protocol, which significantly enhances the protection of data transmission over the internet.

2. The Administrator has implemented technical measures to secure data storage and physical storage of personal data, if such exist.

3. The Administrator declares that only authorized individuals have access to personal data.

4. Depending on the mobile platform, the Administrator may access the following features in the mobile device within the Application:

• internet connection;
• access to the mobile device’s camera for taking pictures of documents and/or the user’s face during account registration, which are subsequently stored by Veriff after successful user registration in the Application. Veriff is a provider of automated verification software to reduce fraud, particularly in the area of AML, strengthen Compliance and KYC procedures to protect providers of various applications and platforms;
• photo gallery of the mobile device for sending pictures of documents and/or the user’s face during real account registration;
• advertising identifier (IDFA) for tracking the effectiveness of the Application's advertising campaigns;
• phone mode to enable the Application’s sleep mode during background activity.

5. The application permissions may be revoked depending on the mobile application through changes in the device’s system settings or by uninstalling the Application.

6. The mobile application does not store any personal data that would allow third parties to identify a specific User. The Administrator may process anonymous user activity data in mobile applications for statistical purposes.

VII. Final Provisions

1. By filling out and submitting the registration form, the User confirms that they have read these Privacy Policy Terms and agrees with them.

2. The Administrator is entitled to amend these Privacy Policy Terms. The new version will be published on their website and at the same time, the User will be sent the new version to the last known email address provided to the Administrator.

3. These Privacy Policy Terms come into effect on [TO BE COMPLETED].