In this privacy policy we, ICMMO.COM LIMITED, registered under number Hong Kong (“ICMMO.COM”), wish to explain how we handle personal data of our Users when they visit our website and use our services.

All the terms used in ICMMO.COM Terms & Conditions have the same meaning as in this Privacy Policy. When you first visit ICMMO.COM site, you will be asked to consent to our use of cookies in accordance with these terms.

We incorporate such privacy controls, that will provide you with controls on deciding how we will process your personal data. Use privacy controls, with which you can specify whether you would like to receive direct marketing communications from ICMMO.COM.

Please let us know if the personal information that we hold about you needs to be corrected or updated.

If you wish to exercise any of your rights provided in this Privacy Policy or contact us regarding all privacy-related issues, you may submit or request by email: [email protected].

I How is our site using your data and how long are we storing them?

We process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. We obtain such data through the use of cookies and similar technologies.

We process usage data to have a better understanding of how you use our website and services. The legal basis for this processing is our legitimate interest, namely monitoring and improving our website and services and accommodating the services for individual interests of every User.

We process your account data (“account data”). The account data may include your name and email address, phone number and other data that you provide while registering as well as your purchase history. We obtain such data directly from you.

We process account data for the purposes of operating our website, providing our services, ensuring the security of our website and services and communicating with you as our User. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract as well as our legitimate interest, namely monitoring and improving our website and services.

We process information relating to provision of services by us to you in our website (“transaction data”). The transaction data may include your contact details, bank account details and the transaction details. The transaction data is processed to supply purchases goods and provide services and keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you, other Users and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
We process information related to anti-money laundering prevention measures (“AML data”). AML data may additionally include address or residence, ID documentation, including your photo, documents regarding your source of wealth, utility bill and others. We are required by the law to request such information to carry out “know your client” obligations.

We may process information that you provide to us for the purpose of subscribing to our email messages and newsletters (“messaging data”). The messaging data is processed to send you relevant messages and newsletters. The legal basis for this processing is your consent. Also, if you are a User and you do not object, we may also process messaging data on the basis of our legitimate interest, namely seeking to maintain and improve customer relations.

We may process information relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. In case of communication through our website, the website will generate the metadata associated with communications made using the website contact forms. The correspondence data is processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, ensuring uniform and high-quality consultation practice and investigating disputes between you and our employees.

We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

We may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
 

II How long are we storing your data?

Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In any case it shall be kept for no longer than:
usage data will be retained for as much as will be necessary for the relevant processing purposes.
Account data will be retained for no longer than 5 (five) years following your last update on the account;
Aransaction data will be retained for no longer than 10 (ten) years following the end of the provision of services;
AML data will be retained as long as it is necessary to comply with the related legal requirements;
Messaging data will be retained for as long as your account is active unless you withdraw your consent earlier;
Correspondence data will be retained for no longer than 6 (six) months following the end of such communication.
Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
 

III When will we provide your data to others?

We may disclose your personal data to other Users you purchased Products from od our Platform, only to the extent necessary for the purposes of providing invoices on your request.

We may disclose your personal data to any member of our group of companies, including our subsidiaries, our ultimate holding company and all its subsidiaries, insofar as reasonably necessary for the purposes set out in this notice. Such may include internal administration purposes as well as provision/sharing of IT services or data centers in our group.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose your personal data to our anti-fraud, risks and compliance providers insofar as reasonably necessary for the purposes of protecting your personal data and fulfilling our legal obligations.
We may disclose your personal data to our payment service providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, transferring funds and dealing with complaints and queries relating to such payments and transfers.

We may disclose your personal data to another service providers insofar as it is reasonably necessary to provide specific services (including, providers of servers and maintenance thereof, email service providers). We take all the necessary measures to ensure that such subcontractors would implement proper measures to ensure security and privacy of your personal data.

In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Persons, indicated in this Section may be established outside the Republic of Malta, European Union and European Economic Area. In case we will transfer your personal data to such persons, we will take all the necessary and in the legal acts indicated measures to ensure that your privacy will remain properly secured, including where appropriate, signing standard contractual clauses for transfer of data.
 

IV What is our marketing policy?

In case your consent, we will be allowed to send you marketing messages via email and/or leave a notification in an Account to inform you on what we are up to.
Also, if we already have provided services to you and you do not object we will inform you about our other products that might interest you including other information related to such.
You may opt-out of receiving marketing messages at any time, by: choosing the relevant link in any of our marketing messages; contacting us via email [email protected]
Please be informed that as our business activities consist of a network of closely related services, it may take a few days until all the systems are updated, thus you may continue to receive marketing messages while we are still processing your request.
The opt-out of the marketing messages will not stop you from receiving messages directly related to the provision of services set in the Terms & Conditions.
 

V What are your rights related to personal data?

Your principal rights under data protection law are as follows in the Sections ahead.

The right to access data - you have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information.

The right to rectification - you have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. Please notice that you may exercise most of this right by logging into your account and changing the data.

The right to the erasure of your personal data – this applies in some circumstances only. Those circumstances include when: (I) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing and there are no other legal basis to process data; (iii) you object to the processing under certain rules of applicable data protection laws; (iv) the processing is for direct marketing purposes; or (v) the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. Such exclusions include when processing is necessary: (i) for exercising the right of freedom of expression and information; (ii) for compliance with our legal obligation; or (iii) for the establishment, exercise or defense of legal claims.

In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are when: (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data, however, we will only further process such data in any other way: (i) with your consent; (ii) for the establishment, exercise or defense of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the purposes of the legitimate interests pursued by us or by a third party.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes).

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.