Investment Trading Group (ITG) – Privacy Policy

1. Introduction

Investment Trading Group (ITG) is a privately owned investment firm headquartered in Spain. We manage and grow our internal shareholders’ capital exclusively, and do not accept or solicit external investors. This Privacy Policy outlines how we collect, use, store, and protect your personal data when you interact with ITG—particularly as a partner or authorized representative of a partner.

2. Scope

This Privacy Policy applies to:

• All ITG websites, partner portals, and online services (collectively, the “Services”).

• Authorized internal partners/shareholders accessing the Services.

• Authorized ITG employees, consultants, or contractors involved in data processing.

It does not apply to external individuals seeking to invest, as ITG does not accept public or external investments.

3. Data We Collect

We may collect and process the following categories of personal data:

1. Identity Information: Name, username, title, and shareholder ID (if applicable).

2. Contact Information: Address, email address, telephone number.

3. Financial Information: Banking details, internal portfolio holdings, transaction history, and capital contributions.

4. Technical Information: IP address, browser type, device information, and log data collected when you access our Services.

5. Communications: Records of correspondence with ITG (emails, support tickets, partner meetings).

4. How We Use Your Data

ITG processes personal data for:

• Fulfilling Internal Shareholder Obligations: Managing partner contributions, withdrawals, and allocation.

• Regulatory Compliance: Adhering to Spanish, EU, and other applicable financial regulations (e.g., anti-money laundering requirements).

• Account Administration: Providing secure access to the Partner Portal, verifying identity, and maintaining login credentials.

• Service Improvements: Analyzing usage patterns to enhance the user experience, security, and functionality of our systems.

• Communications: Sending important updates, performance reports, and shareholder notices.

5. Legal Basis for Processing

Under GDPR, our primary legal bases for processing personal data are:

1. Contractual Necessity: We process partner data to fulfill our obligations under shareholder agreements.

2. Legitimate Interests: We protect our internal capital, ensure secure operations, and maintain our proprietary AI-driven strategies.

3. Legal Requirements: Compliance with financial regulations, tax laws, and obligations under Spanish or EU directives.

6. How We Share Your Data

• Within ITG: Authorized employees, consultants, or contractors may access partner data to manage accounts, conduct audits, or maintain systems.

• Regulatory Authorities: We may disclose data to comply with legal or regulatory requests.

• Service Providers: Third-party vendors or cloud hosting providers may process data on our behalf (e.g., secure hosting, analytics)—only under strict confidentiality and data protection agreements.

ITG does not sell or rent partner data to external parties.

7. International Data Transfers

Where data must be transferred outside the European Economic Area (EEA), we use appropriate safeguards such as Standard Contractual Clauses (SCCs), ensuring GDPR compliance and data security.

8. Data Retention

ITG retains personal data for as long as necessary to:

• Fulfill the purposes outlined in this Policy.

• Comply with legal, tax, or regulatory requirements.

• Resolve disputes and enforce agreements.

We securely destroy or anonymize data when it is no longer needed.

9. Data Security Measures

To protect partner data, we employ:

• Encryption: Securing data at rest and in transit (e.g., SSL/TLS).

• Access Controls: Role-based permissions for employees and consultants.

• Regular Audits: Routine security assessments and penetration testing.

• Secure Infrastructure: Trusted cloud providers and physical safeguards for on-premises hardware.

10. Partner Rights Under GDPR

If you are based in the EU/EEA, you have the right to:

• Access your personal data.

• Request Correction of inaccurate data.

• Request Erasure (“right to be forgotten”) if data is no longer necessary.

• Object to or Restrict Processing under specific circumstances.

• Data Portability to receive your data in a structured format.

To exercise these rights, or for more information, please contact us at [email protected]

11. Cookies & Tracking

ITG’s websites may use cookies or similar tracking tools for authentication, performance analysis, or user experience improvements. We do not use third-party advertising cookies because we do not solicit public investments. For more details, refer to our Cookie Policy (if applicable).

12. Children’s Privacy

Our Services are intended for adult shareholders and business entities. We do not knowingly collect personal data from children under [18]. If you believe we have inadvertently done so, please contact us to remove that data.

13. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our operations, legal obligations, or technology. Updates are effective as of the Last Updated date shown at the top. We encourage partners to review this Policy regularly.

14. Contact Information

For questions or concerns about this Privacy Policy or ITG’s data practices, please contact:

Investment Trading Group (ITG)
World Trade Center South Building, 227
Barcelona, Spain
Phone: +34 627 775 151
Email: [email protected]