1. Who We Are
This Privacy Policy explains how IMWC, operating the IMWC brand ("IMWC", "we", "us" or "our"), collects, uses, stores, shares and protects personal data.
IMWC is the data controller for the personal data described in this Privacy Policy unless otherwise stated.
This Privacy Policy applies to personal data processed in connection with:
- imwc.com and pages operated under that domain;
- IMWC software;
- Free trials and software licences;
- our licensing and activation systems;
- email communications;
- customer support;
- advertising and advertising measurement;
- communications through third-party platforms where we process information about you; and
- other interactions you have with IMWC.
2. Data Protection Framework
IMWC is established in Gibraltar. Our processing is therefore principally subject to the Gibraltar General Data Protection Regulation ("Gibraltar GDPR"), the Data Protection Act 2004, and the Communications (Personal Data and Privacy) Regulations 2006, where applicable.
The Communications regulations operate alongside Gibraltar data-protection legislation and include rules relating to cookies, similar tracking technologies and electronic communications.
The Gibraltar Regulatory Authority ("GRA"), acting as Information Commissioner, is Gibraltar's supervisory authority for data protection.
Where we offer services to or monitor individuals in other jurisdictions, additional data-protection or electronic-communications laws may also apply, including the EU GDPR or UK data-protection and privacy rules where their territorial requirements are met.
3. What This Privacy Policy Covers
This Privacy Policy explains:
- what personal data we collect;
- where we obtain it;
- why we process it;
- the lawful bases on which we rely;
- how our software communicates with our servers;
- how we use cookies and advertising technologies;
- how we use email-service providers and email engagement measurement;
- who may receive personal data;
- international transfers;
- how long information may be retained;
- your data-protection rights; and
- how to contact us or make a complaint.
A privacy policy is intended to explain our processing practices. Merely visiting our website does not constitute consent to optional processing for which consent is legally required. Where consent is required, we request it separately.
4. Categories of Personal Data We Collect
The information we process depends upon how you interact with us.
4.1 Contact Information
This may include:
- your name;
- your email address;
- information contained in communications with us; and
- other contact information you voluntarily provide.
4.2 Trial and Registration Information
When you request a free trial or another product or service, we may process:
- your email address;
- the date and time of registration;
- the page, campaign or source associated with the registration where available;
- your trial status;
- information relating to trial activation; and
- records relating to the provision and administration of the trial.
4.3 Website and Device Information
When you access our website, our servers or technical providers may process information such as:
- IP address;
- browser type and version;
- device type;
- operating system;
- requested URL or page;
- referring URL;
- date and time of access;
- server request information;
- error or diagnostic information;
- security information; and
- other standard technical information transmitted when a browser communicates with a web server.
Some of this information may constitute personal data even where it does not identify you by name.
5. Software Data
Our software communicates with IMWC systems for purposes related to operating, administering, validating, protecting and supporting the software and its licensing system.
5.1 Information Our Software Currently Transmits
The current implementation of our software may transmit the following information to IMWC servers:
- Product name;
- Product version;
- Licence key;
- MetaTrader account number;
- MetaTrader account name;
- Account type — live or demo;
- Account leverage;
- Account balance;
- Account currency;
- Broker name;
- Broker server name;
- Server time offset;
- Computer name; and
- Computer ID.
Some of this information may directly or indirectly relate to an identifiable individual and is therefore treated as personal data where applicable. In particular, an account name, account number, computer identifier and associated technical information may identify or distinguish a particular user, account or installation.
6. Why Our Software Sends Information to Us
We process our software and account information for purposes including:
- activating our software products;
- validating trials and licences;
- determining whether a licence or trial remains valid;
- associating a licence with an authorised installation or account;
- administering trial periods;
- distinguishing live and demonstration environments where required;
- enforcing applicable trial and licence conditions;
- protecting the licensing system;
- detecting or preventing unauthorised, duplicated, fraudulent or abusive licence use;
- maintaining software and licensing-system security;
- diagnosing compatibility or technical problems;
- providing customer support;
- investigating errors;
- understanding the technical/account environment in which our software is operating;
- maintaining appropriate operational records; and
- protecting IMWC's software, systems and intellectual property.
We do not use the website cookie-consent decision to determine whether our software may perform processing that is necessary to provide, administer or secure software you have requested.
Rejecting advertising cookies on imwc.com does not disable our software licence validation.
7. Lawful Basis for Processing
Where processing is objectively necessary to provide the software, trial or licence you requested, we may rely on performance of a contract or steps taken at your request before entering into a contract.
Where processing is necessary to protect our software, prevent licence abuse, protect our systems, investigate misuse, maintain security, or maintain reasonable operational records, we may rely on our legitimate interests, provided those interests are not overridden by your rights and interests.
Where a future use of data requires consent under applicable law, we will obtain consent before relying upon that processing.
8. Changes to Our Software Data Collection
The list in Section 5 describes the current information transmitted by our software. If we materially change our software so that it begins collecting additional categories of personal data or begins using existing information for a materially different purpose, we will update this Privacy Policy.
Where required by law, we will also provide additional notice or obtain appropriate consent before beginning the new processing.
9. Trial Registration
When you request a product trial, we process information necessary to:
- register your request;
- provide access to the trial;
- provide download or setup information;
- administer the trial;
- communicate important information relating to the trial;
- validate activation;
- provide technical assistance;
- prevent misuse; and
- maintain records relating to the trial.
Processing necessary to provide the requested trial may be based upon taking steps at your request before entering into a contract or performing a contract.
You are not required to consent to unrelated advertising tracking or marketing merely to receive the software trial.
10. Customer Support
If you contact us for assistance, we may process information including:
- your name;
- email address;
- licence information;
- account information relevant to your request;
- your message;
- previous correspondence;
- screenshots you provide;
- technical or diagnostic information you provide; and
- other information reasonably necessary to investigate your request.
We use this information to respond to you, identify the relevant account or licence, diagnose problems, provide technical assistance, investigate software behaviour, maintain support records, improve our documentation and support processes, and protect our systems and legal rights.
Please avoid sending information that is not necessary to resolve your request.
12. Optional Advertising & Measurement Technologies
Optional Advertising & Measurement technologies are disabled unless you positively choose to allow them.
You may:
- Accept All;
- Reject All;
- Manage Preferences; or
- ignore the banner and continue using the website without enabling optional advertising technology.
Simply using, scrolling or interacting with the website is not treated by IMWC as consent to optional advertising technologies.
If you do not make a choice, optional advertising technology remains disabled. You may change a previous decision through Cookie Settings in the website footer.
13. Meta Pixel
If you consent to Advertising & Measurement, we may activate the Meta Pixel, technology provided by Meta.
We use the Meta Pixel to help measure the effectiveness of our advertising and understand actions resulting from our advertising campaigns.
Depending on Meta's technology, your device, browser and interaction with the site, information processed may include:
- IP address;
- browser information;
- device information;
- the page visited;
- date and time;
- referring or campaign information;
- website events or actions;
- Meta-related identifiers; and
- information used to attribute website activity to advertising.
Meta may use cookies or similar identifiers where permitted and may process information under its own terms and privacy policies.
IMWC does not intentionally load our Meta Pixel through the website consent system before Advertising & Measurement permission has been provided.
You may withdraw your permission through Cookie Settings. Withdrawal does not affect processing that lawfully occurred before withdrawal.
14. Email Communications
14.1 Trial and Service Communications
If you request a product trial or use one of our products, we may send messages necessary to provide or administer that service. These may include:
- trial-access information;
- download links;
- installation information;
- activation information;
- licence notices;
- important service information;
- security communications;
- technical notices; and
- responses to support enquiries.
Such communications may be necessary to provide the service you requested and are not necessarily marketing.
14.2 Marketing Communications
Where permitted by applicable law, we may send emails concerning:
- IMWC software;
- product developments;
- trading-system updates;
- educational material;
- offers;
- promotions; and
- related IMWC products or services.
Where consent is required, we will seek consent before sending such communications. You may unsubscribe from marketing at any time.
Unsubscribing from marketing does not necessarily prevent us from sending communications that are strictly necessary to administer an active licence, trial, request or customer-support matter.
15. AWeber
We use AWeber Systems, Inc. as an email-service and marketing-automation provider.
AWeber may process subscriber information on our behalf, which may include:
- email address;
- signup date;
- subscription status;
- list membership;
- unsubscribe status;
- delivery information;
- bounce information;
- IP or technical information associated with interaction with the service;
- email engagement information; and
- related records necessary to provide the email service.
AWeber may process this information as our service provider under its contractual and data protection obligations. AWeber may also process certain information for its own lawful purposes under its own privacy terms.
16. Email Open and Click Measurement
Where enabled and where applicable consent requirements have been satisfied, emails sent through AWeber may contain technologies that allow us to measure email engagement.
Open Measurement
AWeber may use a small tracking image or similar technology that records information when an email is loaded. Information may include whether an email was loaded, date and time, certain device or technical information, and other engagement information generated by the email service.
Click Measurement
Links in our emails may be converted into tracking links. When you click such a link, the request may first pass through AWeber's tracking system so that the click can be recorded before you are redirected to the intended destination.
These measurements help us understand whether communications are being read and which material is useful or relevant to subscribers.
Where applicable law requires consent for these technologies, we rely on consent. You may withdraw marketing consent or unsubscribe using the mechanism contained in our messages.
17. Marketing Consent Records
Where you consent to marketing or email-engagement measurement, we may maintain records showing:
- that consent was provided;
- when it was provided;
- the wording presented at the time;
- the method through which consent was obtained; and
- subsequent withdrawal or unsubscribe information.
We maintain these records to respect your preferences and demonstrate compliance with applicable law.
18. Marketing Suppression Lists
If you unsubscribe or object to direct marketing, we may retain limited information such as your email address on a suppression list.
Keeping a suppression record does not mean that we continue marketing to you. Its purpose is to ensure that we do not inadvertently add you back to marketing communications.
Suppression records may therefore be retained for as long as reasonably necessary to honour your objection.
19. Sources of Personal Data
We may obtain personal data:
- directly from you;
- from forms you submit;
- automatically from your browser or device;
- from our software when it communicates with our servers;
- from our server and security systems;
- through customer-support communications;
- from AWeber when you interact with our emails;
- from Meta where advertising measurement has been enabled;
- through referral or campaign information; and
- from third-party platforms when you choose to interact with us through those platforms.
20. How We Use Personal Data
Depending on the circumstances, we may use personal data to:
- operate imwc.com;
- provide requested website functionality;
- provide our software;
- administer trials;
- activate and validate licences;
- secure our products;
- prevent fraud and abuse;
- provide customer support;
- communicate with you;
- diagnose software or technical issues;
- maintain system security;
- maintain appropriate business records;
- measure advertising with consent;
- send permitted marketing communications;
- measure permitted email engagement;
- comply with legal obligations;
- establish or defend legal rights;
- investigate suspected misuse; and
- improve our services and operational processes.
21. Summary of Lawful Bases
| Processing activity | Typical lawful basis |
|---|---|
| Providing website functionality | Legitimate interests / requested service |
| Website security | Legitimate interests |
| Necessary consent-preference cookie | Legitimate interests / legal compliance |
| Meta Pixel | Consent |
| Trial registration | Contract / steps requested before contract |
| Product activation | Contract |
| Licence validation | Contract |
| Licence protection and abuse prevention | Legitimate interests |
| Technical support | Contract / legitimate interests |
| Responding to enquiries | Legitimate interests / steps requested by you |
| Necessary product/service email | Contract / legitimate interests |
| Marketing email where consent is required | Consent |
| Email open/click measurement where consent is required | Consent |
| Maintaining consent records | Legal obligation / legitimate interests |
| Marketing suppression records | Legal obligation / legitimate interests |
| Legal and regulatory compliance | Legal obligation |
| Legal claims | Legitimate interests / applicable legal provisions |
The precise lawful basis depends upon the circumstances and applicable law.
22. Legitimate Interests
Where we rely upon legitimate interests, those interests may include:
- operating our business;
- operating our website;
- maintaining reliable software;
- securing our systems;
- protecting our licensing infrastructure;
- preventing fraud and abuse;
- protecting intellectual property;
- providing customer support;
- troubleshooting technical problems;
- maintaining appropriate records;
- understanding operational issues;
- enforcing contractual rights; and
- establishing or defending legal claims.
We consider whether those interests are overridden by the interests, rights or freedoms of affected individuals before relying on this basis.
24. Service Providers and Processors
Where another organisation processes personal data on our behalf, we take reasonable steps to use providers appropriate to the processing involved.
Where required, we enter into contractual arrangements governing processing, confidentiality, security and permitted use.
A provider may also act as an independent controller for particular processing it conducts for its own purposes. In that case, its own privacy terms apply to that processing.
25. International Transfers
IMWC is established in Gibraltar, while some service providers we use operate internationally. Personal data may therefore be processed in or transferred to countries outside Gibraltar or the jurisdiction in which you live.
For example, AWeber Systems, Inc. is located in the United States.
Where applicable law requires safeguards for an international transfer, we use or rely upon an appropriate mechanism, which may include:
- an adequacy decision;
- an approved data-transfer framework;
- standard contractual clauses;
- an applicable UK or Gibraltar transfer mechanism;
- contractual safeguards;
- another legally recognised transfer mechanism; or
- a statutory exception where legally appropriate.
You may contact us for additional information about safeguards applicable to a specific transfer.
26. Data Retention
We keep personal data only for as long as reasonably necessary for the purposes for which it is processed.
Retention periods depend on factors including:
- why the information was collected;
- whether you continue to use a product;
- whether a licence remains active;
- security requirements;
- fraud and abuse prevention;
- support requirements;
- legal obligations;
- limitation periods;
- regulatory obligations;
- disputes; and
- the need to demonstrate compliance.
Website Logs
Website and server logs are retained for a period reasonably necessary for operation, troubleshooting and security. Information may be kept longer where required to investigate a security incident, misuse or legal issue.
Product Trial and Licence Information
Product activation and licensing information may be retained for the duration of the relevant trial or licence and afterward for a reasonable period where necessary to administer licensing records, prevent repeated trial or licence abuse, maintain software security, resolve support issues, maintain business records, or establish or defend legal claims.
Support Communications
Support communications may be retained for as long as reasonably necessary to resolve the issue and maintain appropriate support and business records.
Email Subscriber Information
Subscriber information may be retained while you remain subscribed or while we otherwise have a lawful reason to retain it.
Engagement Information
Email engagement records may be retained in AWeber in accordance with our use of the service and applicable retention requirements.
Unsubscribe Information
Suppression records may be retained after unsubscribing so that your preference continues to be respected.
Consent Records
Records demonstrating consent or withdrawal may be retained for an appropriate period in order to demonstrate compliance.
Cookie Preference
The current IMWC website consent preference is stored for approximately 180 days.
Legal Records
Information may be retained where necessary to comply with legal, regulatory, accounting or evidential requirements or to establish, exercise or defend legal claims.
When information is no longer required, we may delete, destroy or anonymise it as appropriate.
27. Anonymous and Aggregated Information
We may create aggregated statistics or information that has been genuinely anonymised so that it no longer relates to an identifiable individual.
Properly anonymised information is not personal data. We may use such information for statistical analysis, system analysis, product development, business planning and other legitimate business purposes.
28. Security
We take reasonable technical and organisational measures intended to protect personal data against unauthorised access, unlawful processing, accidental loss, destruction, misuse, alteration and unauthorised disclosure.
Measures may include, where appropriate:
- access restrictions;
- authentication controls;
- system security;
- server protections;
- software controls;
- confidentiality requirements;
- monitoring; and
- organisational procedures.
No internet service, network, software system or method of electronic storage can be guaranteed to be completely secure.
29. Personal Data Breaches
If we become aware of a personal-data breach, we will assess the nature of the breach, the information involved, the likelihood of harm, the potential impact on individuals and applicable notification requirements.
Where required by law, we will notify the relevant supervisory authority and/or affected individuals within the applicable legal timeframe.
30. Your Data Protection Rights
Depending upon applicable law and the circumstances, you may have rights including the following.
Right to Be Informed
You have the right to information concerning how your personal data is processed. This Privacy Policy is intended to provide that information.
Right of Access
You may request confirmation of whether we process your personal data and request access to personal data we hold about you.
Right to Rectification
You may request correction of inaccurate information and completion of incomplete information.
Right to Erasure
In certain circumstances, you may request deletion of personal data. The right to erasure is not absolute. We may continue retaining information where processing is necessary or permitted for legal obligations, security, fraud prevention, suppression of unwanted marketing, contractual records or legal claims.
Right to Restriction
You may have the right to request restriction of processing in circumstances provided by law.
Right to Data Portability
Where applicable, you may have the right to receive certain information in a structured, commonly used and machine-readable format and to transmit it to another controller.
Right to Object
Where we rely upon legitimate interests, you may have the right to object to processing based upon your particular circumstances.
Absolute Right to Object to Direct Marketing
You may object to processing of your personal data for direct marketing at any time. If you do so, we will stop using your personal data for direct marketing.
Right to Withdraw Consent
Where processing is based upon consent, you may withdraw that consent at any time. For website Advertising & Measurement, use Cookie Settings. For marketing email, use the unsubscribe facility contained in our messages or contact us.
Withdrawal of consent does not affect processing lawfully undertaken before withdrawal.
Rights Relating to Automated Decision-Making
Where applicable, you may have rights in relation to decisions based solely on automated processing that produce legal effects or similarly significant effects.
31. Automated Decision-Making and Profiling
IMWC does not currently make decisions about customers based solely on automated processing that produce legal effects or similarly significant effects upon them.
Third-party advertising platforms such as Meta may independently undertake profiling, advertising personalisation or automated processing under their own systems and privacy terms.
Where our Meta Pixel is involved, IMWC only enables the optional website technology after the relevant website consent has been provided.
32. Exercising Your Rights
Requests concerning your personal data may be sent to:
Please tell us:
- who you are;
- what right you wish to exercise; and
- enough information to locate the relevant records.
We may request reasonable evidence of identity where necessary to prevent information from being disclosed, changed or deleted at the request of an unauthorised person.
We will respond within the period required by applicable law. Under the Gibraltar GDPR, data-subject requests are generally subject to a one-month response period, with permitted extensions in certain circumstances.
33. Marketing Preferences
You can stop receiving marketing emails at any time. Use the unsubscribe link provided in the email or contact contact@imwc.com.
Your request will not be used against you and there is no charge for unsubscribing. We may keep the minimum information necessary to remember that you asked not to receive marketing.
34. Special Categories of Personal Data
IMWC does not ordinarily require information concerning racial or ethnic origin, political opinions, religious beliefs, trade-union membership, genetic information, biometric identification, health, sexual orientation or sex life in order to provide our software or operate the IMWC website.
Please do not send such information unless it is genuinely necessary.
Where we intentionally process special-category personal data, we will do so only where an appropriate legal basis and additional legal condition are available.
35. Children
IMWC's trading-related products are intended for adults. They are not designed or marketed as services for children.
We do not knowingly seek to collect personal data from children through our software products. If you believe that a child has provided personal data to us inappropriately, please contact us.
36. Third-Party Websites and Services
The IMWC website and our communications may contain links to third-party services, including services relating to MetaTrader, brokers, FxBlue, Telegram, social media, email providers and other external websites or platforms.
Following such a link may cause the third party to process information independently from IMWC. We do not control the privacy practices of independent third parties.
You should review the relevant third party's privacy information before providing personal data to them.
37. Communications Through Third-Party Platforms
If you communicate with IMWC through Telegram, social media or another third-party platform, we may receive information made available through that platform, such as:
- username;
- display name;
- profile information made visible to us;
- messages;
- replies; and
- other information you choose to provide.
The platform itself separately processes information under its own privacy terms.
38. Legal Requirements and Protection of Rights
We may process or disclose personal data where reasonably necessary to:
- comply with applicable law;
- respond to a binding legal request;
- comply with a court order;
- cooperate with a regulator;
- investigate fraud;
- investigate security incidents;
- enforce agreements;
- protect our software;
- protect our legal rights;
- protect users or third parties; or
- establish, exercise or defend legal claims.
39. Changes to Our Services
IMWC products may change over time. New functionality may require different processing.
If a change materially affects the information collected, the purpose of processing, the lawful basis, recipients of information or individuals' reasonable privacy expectations, we will update this Privacy Policy and take any additional steps required by applicable law.
40. Changes to This Privacy Policy
We may revise this Privacy Policy from time to time. Reasons may include:
- product changes;
- changes to our website;
- changes to service providers;
- new technologies;
- changes to data practices;
- changes in law;
- regulatory guidance; or
- operational changes.
The current version will be published on this page. The Last Updated date at the top identifies the latest revision.
Where required by law, material changes may also be communicated through additional notices.
41. Complaints
If you believe we have handled your personal data incorrectly, please contact us first so that we can investigate.
Email: contact@imwc.com
You also have the right, where applicable, to lodge a complaint with a data-protection supervisory authority.
Gibraltar Regulatory Authority
Information Commissioner
2nd Floor, Eurotowers 4
1 Europort Road
Gibraltar
GX11 1AA
Depending upon where you live and the circumstances of the processing, you may also have rights to contact another competent supervisory authority.
42. Contact Us
For questions about this Privacy Policy, our processing of personal data, or the exercise of a data-protection right: