This statement acknowledges that IMBA wishes to act in accordance with our obligation to inform persons of when their data is collected, as required under the General Data Protection Regulation (GDPR).¹
- The Purpose of Collecting Personal Data
We may collect personally identifiable information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, place an order, and in connection with other activities, services, features, or resources we make available on our Site. Users may be asked for (as appropriate) name, email address, mailing address, and phone number. Users may, however, visit our Site anonymously. When interacting with us on the Site, Users can always refuse to supply personal data to us, except that it may prevent them from engaging in certain Site-related activities or transactions.
- What Information Do We Collect?
- Information you provide to us at registration
When you create a IMBA Account, you provide us with personal information that includes your contact information (email address, name, and password). You can also choose to add a phone number for SMS or a Google Authenticator account to be used for 2FA verification for improved security.
- Information we collect when authenticating user identity/using our services
To comply with global industry regulatory standards including Anti-Money Laundering (AML), Know-Your-Customer (KYC), and Counter Terrorist Financing (CTF), IMBA requires user accounts to undergo user identity authentication for both Personal and Enterprise-level accounts. This entails collecting formal identification.
Personal data which we may collect includes:
- Your name, address, and primary location of residence
- Your email address(es)
- Your contact telephone number
- A photocopy of your ID
- A photograph of yourself; and
- Your corporate information (if applicable)
- Transactional information
- Identification number
- Bank account number
- Service usage information
Through your use of the IMBA platform, we also monitor and collect tracking information related to usage, such as access date & time, device identification, operating system, browser type, and IP address. This information may be directly obtained by IMBA or through third-party services. This service usage data helps our systems to ensure that our interface is accessible for users across all platforms, and can aid during criminal investigations.
The IMBA website also utilises cookies from Google Analytics to obtain reports and follow user behaviour and general trends in order to improve website functionality. If Google has a legal obligation to do so, this information may be provided to third-party services. They may also submit data to a third party if that entity processes the data for them. By accessing the IMBA website, you agree to the processing of information by Google, in-line with the practices listed above.
More information on how cookies work, and how to block and/or delete them can be found on the website of the Dutch Authority for Consumers & Markets (Autoriteit Consument en Markt) in Dutch: https://www.consuwijzer.nl/telecom-post/internet/privacy/uitleg-cookies.
- Transaction information
For all Personal and Enterprise user accounts, we collect transaction information including deposit snapshots, account balances, trade history, withdrawals, order activity, and distribution history. This transaction data is monitored for suspicious trading activity, for user fraud protection, and legal case resolution.
- Why Does IMBA Collect This Information?
- To provide and maintain our services
We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and provide our services. Given our legal obligations and system requirements, we cannot provide you with services without proper identification, contact information, and transaction-related information.
Services include, but are not limited to:
Registering you as a customer of IMBA and/or to deal with, process, and/or administer the account that you may open with us, whether a membership account or otherwise, including to facilitate your transactions or activities on the Site or your transactions or activities with us;
Administering, facilitating, processing, and/or dealing with your relationship with us, any transactions or activities carried out by you on the Site or with us. This includes processing your application, orders, and payment transactions, implementing transactions and the supply of products and/or services to you that you have requested;
Assessing and processing your request for the purchase of and/or subscription to our products and/or services.
- To protect our users
We use the information collected to protect our platform, users’ accounts, and archives.
We use IP addresses and cookie data to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (DDoS) attacks.
We analyse trading activity with the goal of detecting suspicious behaviour early to prevent potential fraud and loss of funds to bad actors.
- To comply with legal and regulatory requirements
Respect for the privacy and security of data you store with IMBA informs our approach to complying with regulations, governmental requests, and user-generated inquiries. We will not disclose or provide any personal information to third-party sources without review from our legal case team and/or prior consent from the user.
- To communicate with you
We use personal information collected, such as an email address, to interact with users directly when providing customer support on a ticket or to keep you informed on logins, transactions, and security. Without processing your personal information for confirming each communication, we will not be able to respond to your submitted requests, questions, and inquiries. All direct communications are kept confidential and reviewed internally for accuracy.
For marketing purposes in this regard, we would provide you with marketing, advertising, and promotional information, materials, and/or documents relating to products, contests, services, and/or events (including those of third-party organisations with which IMBA may collaborate with) that IMBA (including its affiliates/related corporations) or such third-party organisations may be selling, marketing, offering, organising, involved in, or promoting, whether such products, services, and/or events exist now or are created in the future.
- Storage and Security of Personal Data
We will keep your personal data no longer than is necessary. This is in accordance with any legal requirements and/or the purposes stated above.
All personal data is kept on secure servers. Where you are given a password to access the IMBA site, you are responsible for keeping the relevant passwords secure.
Data transmitting across the internet is not always secure. While we will do our best to ensure any personal data is kept secure, we cannot guarantee the security of data transmitted to our website in order to download the Services. IMBA will ensure strict security measures are in place when collecting and storing data. However, any data transmitted to us remains at your own risk.
- Rights of the Data Subjects
You have the right to ask us for copies of your personal information, to rectify any inaccurate details, and the right to ask us to complete partial or missing information. You also have the right to request we stop using your personal information.
You have the right to ask us not to use your personal data for marketing purposes.
Exemptions to these rights do apply. Under specific circumstances, we may not be able to (fully) complete your request. This can occur for a number of reasons, including a legal obligation that IMBA may be or is subject to.
- Amendments to This Privacy Statement
- Questions & Contact Information
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), to be found at the following website: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L:2016:119:FULL&from=EN