1. Introduction

SKAINET SYSTEMS, a licensed brand of Cermak LLC, ("the Platform") manages personal data of customers, suppliers, employees, workers, and other third parties ("Data Subjects"). This Privacy Policy explains how we act as the data controller for all personal data used in our business for commercial purposes.

1.1. This Privacy policy covers all personal data processed by the Company, regardless of its format or whether it pertains to past or present employees, workers, customers, clients, suppliers, shareholders, website users, or any other Data Subject.

1.2. This policy applies to all employees, workers, contractors, agency workers, consultants, directors, members, and others.

1.3. You must understand and comply with this Privacy policy when handling personal data on behalf of the Company and attend relevant training. Non-compliance may result in disciplinary action.

1.4. This Privacy policy is internal and must not be shared with third parties, clients, or regulators without prior authorization from the Compliance Manager.

1.5. This Privacy policy is not part of any employment contract and may be amended at any time without notice.

1.6. This Notice does not override any national data privacy laws and regulations in countries where the Company operates.

2. Scope

2.1. Proper and lawful treatment of personal data is critical to maintaining organizational confidence and successful business operations. We are committed to protecting the confidentiality and integrity of personal data.

2.2. Management at all levels is responsible for ensuring compliance with this Privacy policy and must implement appropriate practices, processes, controls, and training.

2.3. For any questions about this Privacy policy, data protection regulations, or concerns about compliance, contact the Compliance Manager at [email protected].

3. Personal data protection principles

3.1. We must demonstrate compliance with the following principles:

3.2. Lawfulness, Fairness, Transparency

3.2.1. Personal data must be processed lawfully, fairly, and transparently. Collect, process, and share data only for specified purposes.

3.3. Consent

3.3.1. Personal data processing requires one or more lawful bases, including consent.

3.3.2. Data Subjects must clearly indicate their consent through affirmative action. Consent must be distinct from other matters in any document.

3.3.3. Data Subjects can withdraw consent at any time, and withdrawal must be honored promptly. Consent may need to be refreshed if processing changes.

3.3.4. Explicit consent is often required for sensitive data, automated decision-making, and cross-border transfers. Record all consents for compliance.

3.4. Transparency

3.4.1. Provide concise, transparent, intelligible, and easily accessible Privacy policys in clear language to Data Subjects.

3.4.2. Inform Data Subjects when collecting personal data directly, including for HR or employment purposes.

3.4.3. When collecting data indirectly, inform Data Subjects appropriately.

4. Purpose limitation

4.1. Collect personal data only for specified, explicit, and legitimate purposes. Do not process data in ways incompatible with these purposes.

4.2. Inform Data Subjects of any new purposes and obtain consent if necessary.

5. Security, Integrity and Confidentiality

5.1. Protecting personal data

5.1.1. Secure personal data with appropriate technical and organizational measures against unauthorized processing, loss, destruction, or damage.

5.1.2. Implement and maintain safeguards suitable to the Company’s size, scope, and resources, and regularly evaluate their effectiveness. You must protect personal data and follow procedures to maintain its security from collection to destruction.

5.1.3. Transfer personal data only to third-party service providers who comply with required policies and procedures and implement adequate measures.

5.1.4. Ensure data security by protecting confidentiality (access by authorized personnel only), integrity (accuracy and suitability for purpose), and availability (accessible to authorized users).

6. Data subject’s rights and requests

6.1. Data Subjects have rights regarding their personal data, including:

• 6.1.1. Remove consent at any time.
• 6.1.2. Receive information about processing activities.
• 6.1.3. Access their personal data.
• 6.1.4. Prevent data use for direct marketing.
• 6.1.5. Request data erasure or correction.
• 6.1.6. Restrict processing in specific circumstances.
• 6.1.7. Challenge processing based on legitimate interests or public interest.
• 6.1.8. Object to automated decision-making.
• 6.1.9. Prevent processing likely to cause harm.
• 6.1.10. Be notified of high-risk data breaches.
• 6.1.11. Complain to the supervisory authority.
• 6.1.12. Receive or transfer their data to a third party in a structured format.

6.2. Verify the identity of individuals requesting data and do not disclose personal data without proper authorization.

6.3. Forward any Data Subject requests to the Compliance Manager immediately.

7. Accountability

7.1. The data controller must ensure compliance with data protection principles and demonstrate this compliance.

7.2. Maintain records, provide training, and conduct audits as necessary.

8. Bad Practices

8.1. Unauthorized promotions or events on behalf of the Company are prohibited.

8.2. The Company can block accounts for unauthorized promotions, false accusations, unethical behavior, or publishing false information.

9. SKAINET SYSTEMS Policies

9.1. Participation in SKAINET SYSTEMS services is at your own risk.

9.2. You are in good health and capable of binding agreements.

9.3. SKAINET SYSTEMS provides advisory services and does not guarantee results due to uncontrollable external factors.

9.4. Investing in financial markets carries risks proportional to potential profits.

9.5. You assume all risks associated with your investment.

9.6. SKAINET SYSTEMS is authorized to handle investment money; all income is from advice and product activation fees.

9.7. You have the right to be informed about investment portfolios and account statuses.

9.8. SKAINET SYSTEMS will keep agreements updated to comply with contracts.

9.9. You accept all risks and release SKAINET SYSTEMS from liability by participating.

10. SKAINET SYSTEMS Terms and Conditions

10.1. By agreeing to these terms, you access SKAINET SYSTEMS's services.

10.2. You accept capital management decisions and resulting gains or losses.

10.2.1. SKAINET SYSTEMS is not responsible for broker actions regarding fund retention, deposits, or withdrawals.

10.3. SKAINET SYSTEMS access your funds; understand brokerage operations before participating.

10.4. Do not hold SKAINET SYSTEMS liable for external company processes; this document protects all employees.

10.5. SKAINET SYSTEMS can justify any service-related decision and terminate client relations without obligation to explain.

10.6. Clients must refrain from negative comments about SKAINET SYSTEMS. Breaching this clause results in a fine.

10.7. Investments can result in losses; past results do not guarantee future performance.

10.7.1. To make rev-share payments, you must sign an LPOA authorizing broker payment on net profits only.

10.7.1.1. Systems can fail; SKAINET SYSTEMS may incur losses (lose of all assets).

10.7.1.2. Trading involves risks, especially during high-impact news; read Broker's terms and conditions.

10.7.1.3. SKAINET SYSTEMS does not guarantee daily profits; market behavior varies.

10.7.1.4. Negative results may be recovered in subsequent periods; SKAINET SYSTEMS will not charge for recovery if Free Margin allows.

10.7.1.5. By signing the LPOA, you authorize SKAINET SYSTEMS to manage your trading account.

10.7.1.6. LPOA copy-trading allows SKAINET SYSTEMS to replicate trades on your account, following the strategies of chosen traders or systems.

10.7.1.7. While copy-trading aims to mirror successful trades, it does not eliminate the inherent risks of trading, and past performance is not indicative of future results.

10.7.1.8. It is essential to understand and agree to the terms of the LPOA and the associated risks of copy-trading before proceeding.

10.8. Withdrawals via BackOffice may take up to 24 hours.

10.9. Deposits and licenses are valid after 24 hours.

10.10. By accepting this Disclaimer, you acknowledge the risks and release SKAINET SYSTEMS from liability.

11. Data collected, used and stored

11.1. SKAINET SYSTEMS may use, store, process, and share data for the following purposes: providing services, improving functionalities, legal compliance, fraud investigation, court orders, and market analysis.

11.2. We collect two types of data:

11.3. User Provided Data

This includes all information Users provide to SKAINET SYSTEMS actively and voluntarily.

11.4. Personal Data

Information that personally identifies the User, such as name, address, ID, phone number, or email address.

11.5. SKAINET SYSTEMS may periodically request additional data from Users, who can choose whether to provide it.

11.6. Other important information

11.7. SKAINET SYSTEMS has a duty of confidentiality regarding your data, but Users must keep their login and password secure.

11.8. If you suspect your login and password have been compromised, notify SKAINET SYSTEMS immediately at [email protected] and change your password.

11.9. By clicking “READ AND ACCEPT”, you consent to the practices outlined in this privacy policy.

11.10. If you have questions or need clarification about this privacy policy, contact SKAINET SYSTEMS at [email protected] before accepting.