Information on the Processing of Personal Data
Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR)
Data controller
Togo Infinity Limited is the data controller within the meaning of Article 4(7) of Regulation (EU) 2016/679 (GDPR). Pursuant to Articles 13 and 14 of the GDPR, we inform you that the data you provide to us will be processed in the manner and for the purposes described below.
Data Protection Officer (DPO)
Togo Infinity Limited has appointed a Data Protection Officer in accordance with Article 37 of the GDPR. For any question relating to the processing of personal data, you may contact the Data Protection Officer at:
Personal data processed and collection methods
3.1 Data provided directly by the data subject
Through contact forms, information requests, newsletter sign-up or access to the site's services, The Real Money collects:
- Personal and contact data: first name, last name, email address, telephone number.
- Professional and financial data: sector of activity, type of interest, assets available for investment, where relevant to the purposes of the service requested.
- Content of communications: the text of messages, questions and any attachments sent.
3.2 Third-party data
The Real Money does not intentionally collect personal data of third parties through the website. If the data subject provides data relating to third parties, they must inform them of the processing beforehand.
Purpose of the processing and legal basis
| Purpose | Legal basis (Art. 6 GDPR) | Retention |
|---|---|---|
| Responding to contact and information requests | Pre-contractual measures at the request of the data subject (Art. 6(1)(b)) | 12 months from the reply, unless the relationship is established |
| Provision of digital, financial and asset advisory services | Performance of the contract (Art. 6(1)(b)) and, where applicable, legal obligation (Art. 6(1)(c)) | 10 years after the end of the relationship |
| Tax, accounting and regulatory compliance | Legal obligation (Art. 6(1)(c)) — applicable Irish and EU legislation | 10 years |
| Sending newsletters and commercial communications (with prior consent) | Consent of the data subject (Art. 6(1)(a)) | Until consent is withdrawn |
| Aggregate analysis of browsing statistics | Legitimate interest of the controller (Art. 6(1)(f)) — website optimization | 26 months |
| Fraud prevention, cybersecurity and protection of rights | Legitimate interest of the controller (Art. 6(1)(f)) | 12 months, save for ongoing disputes or security incidents |
Once the retention periods have elapsed, the data will be securely and irreversibly deleted or permanently anonymized, unless it needs to be retained for the establishment, exercise or defense of legal claims (Article 17(3)(e) of the GDPR).
Recipients and disclosure of data
Personal data is not sold or transferred to third parties for commercial purposes. Data may be disclosed or made accessible to the following categories of parties, strictly to the extent necessary:
5.1 Processors (Art. 28 GDPR)
- Cloud infrastructure and hosting service providers (web servers, databases)
- CRM and email marketing platform providers
- Web analytics companies (browsing statistics)
- IT support and website maintenance service providers
All external processors are bound by specific agreements pursuant to Article 28 of the GDPR and are required to implement appropriate security measures.
5.2 Independent controllers
- Irish and European tax, judicial and supervisory authorities, where required by law
- Legal and accounting advisers, within the limits of their professional mandate
- Banking and payment institutions, for the execution of transactions
5.3 Transfers to third countries
Where service providers process data outside the European Economic Area (EEA), The Real Money ensures that such transfers take place on the basis of one of the following:
- An adequacy decision of the European Commission (Article 45 of the GDPR)
- Standard contractual clauses adopted by the European Commission (Article 46 of the GDPR)
- Other appropriate safeguards in accordance with Chapter V of the GDPR
An up-to-date list of countries and of the security measures adopted is available on request at privacy@therealmoney.com.
Rights of the data subject
Pursuant to Articles 15 to 22 of the GDPR, the data subject has the following rights:
| Access (Art. 15) | To obtain confirmation as to whether personal data concerning them is being processed and, if so, to access that data and the information relating to the processing. |
| Rectification (Art. 16) | To obtain the correction of inaccurate personal data or the completion of incomplete data. |
| Erasure (Art. 17) | To obtain the erasure of personal data (the "right to be forgotten"), in the cases provided for by law, including withdrawal of consent or the data no longer being necessary for the processing. |
| Restriction (Art. 18) | To obtain the restriction of processing in the cases provided for, for example when contesting the accuracy of the data or objecting to the processing. |
| Portability (Art. 20) | To receive the personal data provided in a structured, commonly used and machine-readable format, and to transmit that data to another controller, where the processing is based on consent or on a contract. |
| Objection (Art. 21) | To object at any time to the processing of data based on the legitimate interest of the controller, including processing for direct marketing purposes. |
| Automated decisions (Art. 22) | Not to be subject to decisions based solely on automated processing, including profiling, which produce significant legal effects. This does not apply to processing necessary for legal obligations (for example, anti-money laundering / KYC). |
| Withdrawal of consent | To withdraw consent at any time, without affecting the lawfulness of the processing carried out before the withdrawal. |
| Complaint (Art. 77) | To lodge a complaint with the competent supervisory authority. The lead supervisory authority for The Real Money is the Irish Data Protection Commission (DPC): www.dataprotection.ie. |
The data subject may exercise their rights at any time by contacting the data controller:
The Real Money will respond within 30 days of receipt of the request (Article 12(3) GDPR). For particularly complex requests, this period may be extended by a further 60 days, subject to a reasoned notice to the data subject within the first month.
For complaints involving supervisory authorities in several EU Member States, the cooperation and consistency mechanism provided for in Articles 56 to 76 of the GDPR applies, supplemented by Regulation (EU) 2025/2518 on cross-border procedures.
Data security
Togo Infinity Limited adopts appropriate technical and organizational measures to ensure a level of security appropriate to the risk, in accordance with Article 32 of the GDPR. These measures include:
- Encryption of personal data in transit and, where appropriate, at rest
- Authentication and access control systems based on the principle of least privilege
- Monitoring of information systems and protection against unauthorized access
- Backup, business continuity and data recovery procedures
- Pseudonymization and data minimization techniques where applicable
Security measures are reviewed and updated periodically in line with the evolution of risks, technologies and industry best practice.
Children's data
The services offered by The Real Money are aimed exclusively at adults (over 18 years of age). The Real Money does not intentionally collect personal data of minors under 18. If data relating to a minor is obtained unintentionally, it will be deleted immediately once this comes to our knowledge. For any query, write to privacy@therealmoney.com.
Updates to this notice
The Real Money reserves the right to amend this policy at any time in order to adapt it to regulatory, technological or operational changes. The updated version will be published on the website, indicating the date of revision. In the event of substantial changes affecting the rights of data subjects, they will be notified with due notice.
The previous version remains available on request at privacy@therealmoney.com.
Consent statement for the processing of personal data
Save as provided for in Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR).
