Privacy Policy

This Privacy Policy is prepared by FX-EDGE V Ltd, based in 1276, Govant Building, Kumul Highway, Port Vila, Vanuatu, company no. 700604 (“Data Controller”), as fulfillment of the obligation specified in Art. 13 Section 1 and 2 of Regulation (EU) 2016/679 (the “GDPR”) and other applicable data protection law. Verified Trader Capital, Inc. is a branding partner of FX-EDGE V Ltd and is not the Data Controller of your personal data — see “Recipients and transfer of data” below.

PART A — For All Website Visitors

1. Who is responsible for your personal data?

The Data Controller of your personal data is FX-EDGE V Ltd, based in 1276, Govant Building, Kumul Highway, Port Vila, Vanuatu, company no. 700604.

2. How to contact the Data Controller

A Data Protection Officer has been appointed by the Data Controller. In matters regarding the processing of personal data by the Data Controller, you can contact the Data Protection Officer via the following e-mail address: kteofilski@fx-edge.com.

3. Data security

In connection with the conducted business activity, the Data Controller collects and processes personal data in accordance with the relevant provisions, including in particular the GDPR, the POPIA, the DPB, and the principles of data processing contained therein.

The Data Controller ensures transparency of data processing, informs users about data processing, and ensures that data is collected only to the extent necessary for the purpose indicated and processed only for the period in which it is necessary.

In order to ensure data integrity and confidentiality, the Data Controller has implemented procedures enabling access to personal data only to authorized people and only to the extent necessary for their tasks.

The Data Controller takes all necessary actions so that its subcontractors and other cooperating entities guarantee the use of appropriate security measures whenever they process personal data at the request of the Data Controller.

4. Use of the website

When you use the Data Controller’s website, standard information is collected, such as the IP address, type of browser, language, access time, and the address of the page from which you were redirected. This data can be collected by cookies and analytical tools.

In the event of contact via telephone, e-mail, or the complaint form, data related to the means of communication chosen by you and data provided during communication are also processed, where necessary to resolve the reported matter.

5. What are “cookies”?

Personalization and efficiency of the services provided require saving and storing information about how you use the website. The Data Controller does this by using small text files called “cookies.” Cookies contain limited information and are saved on your device by the server operating the website, and are sent back to the website each time you use it, allowing the server to remember your preferences.

Disabling cookies in your browser may cause difficulties with, or prevent, some functions of the website.

Two types of cookies are generally used on the website:

• Session cookies — temporary files stored on your device until you log out, leave the website, or close your browser.
• Permanent cookies — files stored on your device for the time specified in the cookie’s parameters, or until deleted by you.

Cookies are also divided into three functional groups:

• Necessary — files of key importance enabling navigation and core functions, including secure areas and security.
• Performance — files collecting anonymous information about how you use the website, to help improve its functioning.
• Functional — files recording choices you have made, such as text size or font preferences.

6. Purposes and basis for data processing

Cookies are used to:

• Adapt the content of the website to your preferences and optimize its use, including recognizing your device and displaying the website tailored to your needs.
• Create statistics that help understand how the website is used, in order to improve its structure and content.
• Maintain your session after logging in, so you do not have to re-enter your login credentials.
• Enable interaction with social networks (e.g., publishing posts directly from the website).

The legal basis for this processing is the Data Controller’s legitimate interest in ensuring a higher quality of service.

Contact via e-mail or traditional mail: personal data contained in correspondence not related to an existing agreement is processed solely for the purpose of communication and resolving the matter to which the correspondence relates, on the basis of the Data Controller’s legitimate interest in conducting correspondence in connection with its business operations. Only data relevant to the case is processed, and all correspondence is stored securely and disclosed only to authorized persons.

Telephone contact: in matters not related to an existing agreement, the Data Controller may request personal data only where necessary to handle the matter, on the basis of its legitimate interest in resolving the reported case.

Business contacts: the Data Controller may also collect personal data in the course of business meetings or by exchanging business cards, for the purpose of initiating and maintaining business contacts, on the basis of its legitimate interest in building a business network. Such data is processed only for the purpose for which it was collected, with appropriate protection.

7. Providing data

The website uses cookies in accordance with your individual browser settings. Using the website without changing your browser’s cookie settings means you have read this Privacy Policy and accept cookies.

If you do not accept cookies, you may change your settings or disable cookies at any time in your browser. Changing your browser configuration to prevent or limit cookies, or deleting cookies, may limit the functionality of the services provided.

Instructions for managing cookies in popular browsers are available directly from each browser’s support pages (Firefox, Opera, Internet Explorer, Chrome, Safari). Because of the range of available browsers and devices, it is not possible to provide precise guidance covering every configuration.

8. Your rights

In connection with the processing of your personal data, you have the following rights:

• The right to information about the processing of your personal data, including the purposes and legal grounds for processing, the scope of data held, the entities to which it is disclosed, and the planned retention period.
• The right to obtain a copy of your data.
• The right to rectification of any incomplete or inaccurate data.
• The right to request deletion of data that is no longer necessary for the purposes for which it was collected.
• The right to request that processing be limited, pending resolution of a dispute over the data.
• The right to data portability, to the extent your data is processed in an automated manner in connection with an agreement or consent.
• The right to object to processing for marketing purposes, without needing to give a reason.
• The right to object, on grounds relating to your particular situation, to processing based on the Data Controller’s legitimate interest (e.g., for analytical or statistical purposes).
• The right to withdraw consent at any time, where processing is based on consent (without affecting the lawfulness of prior processing).
• The right to lodge a complaint with the supervisory authority competent for your habitual residence, place of work, or the place of the alleged violation.

9. Data processing period

The period of data processing depends on the type of service provided and the purpose of processing, and may also result from applicable law. Where processing is based on the Data Controller’s legitimate interest, data is processed for as long as necessary to implement that interest, or until you object. Where processing is based on consent, data is processed until consent is withdrawn. Where processing is necessary to perform an agreement, data is processed until the agreement terminates. Retention may be extended where necessary to establish, assert, or defend legal claims. After the applicable period, data is irreversibly deleted or anonymized.

10. Recipients and transfer of data outside the country

In connection with its operations, personal data may be disclosed to external entities, including suppliers responsible for IT systems and analytical tools, accounting service providers, postal operators, marketing agencies, and legal advisers.

Personal data may also be disclosed to Verified Trader Capital, Inc. and other prop brands — partners under whose brand the services available through this website are provided. If cooperation between the Data Controller and such a partner ends, personal data of users and prospective clients may be transferred to that partner, acting as an independent data controller, to ensure continuity of service.

The Data Controller reserves the right to disclose selected information to competent authorities or third parties who submit a request based on an appropriate legal basis and in accordance with applicable law.

The Data Controller transfers personal data outside the country only when necessary and with an adequate level of protection.

11. Automated decision-making

The Data Controller will not apply a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.

PART B — For Clients (Registered Traders)

This Part B applies specifically if you register an account, purchase a challenge, or otherwise become a client of the Data Controller through this website.

12. Purpose of processing

Your personal data will be processed for the purpose of concluding and performing the agreement executed with the Data Controller, and to fulfill the Data Controller’s obligations as an entity providing services subject to anti-money laundering and counter-terrorism financing law. Your data will also be processed to implement the Data Controller’s legitimate interests, such as making necessary settlements, pursuing claims arising from the agreement, security, counteracting fraud, and direct marketing.

Data processing for other purposes may take place based on additional consent, applicable law, or where consistent with the purpose for which the data was originally collected.

13. Legal basis for processing

• Where processing is necessary to perform the agreement, and to take steps before its conclusion.
• Where processing is necessary for the Data Controller to fulfill its legal obligations, including informing financial supervision and financial information authorities about services and transactions, verifying and identifying your identity, and ongoing monitoring of the business relationship.
• Where processing is necessary to achieve purposes arising from the Data Controller’s legitimate interests, such as settlements, pursuing claims, security, counteracting fraud, and direct marketing.

14. Your rights

You have the right to access your personal data, the right to rectify and delete it, and the right to limit its processing. To the extent processing is necessary to perform an agreement to which you are a party, or to take steps at your request before concluding it, you also have the right to data portability. If you believe your data is processed contrary to legal requirements, you may lodge a complaint with the competent supervisory authority.

15. Providing your data

Providing personal data is voluntary but necessary to conclude the agreement and use the Data Controller’s services. Failure to provide the required personal data will result in refusal to conclude the agreement.

16. Recipients of your data

Your personal data may be transferred to the following categories of recipients: banks, payment institutions, virtual asset service providers, companies within the Data Controller’s corporate group, Verified Trader Capital, Inc. and other prop brands under whose brand you use the services, postal operators, supervisory authorities, financial information authorities, suppliers of tools and platform software used to handle transactions and financial operations, providers used to send commercial communications by electronic means, legal advisors, and providers of servers and data storage.

If cooperation between the Data Controller and the prop brand under whose brand you use the services ends, your personal data may be transferred to that prop brand, which will act as an independent data controller, in order to ensure continuity of the services provided to you. You will be informed of any such transfer in advance.

17. International data transfers

Where personal data is transferred to third countries, the Data Controller uses mechanisms in accordance with applicable law to ensure an adequate level of protection.

18. Data retention period

Your personal data will be stored for the duration of the agreement, and after its termination, for a period of five (5) years counting from the first day of the year following the year in which the relationship ended, or until the limitation period for related claims expires. Data included in the results of assessments of the business relationship will be processed for five (5) years from the first day of the year following the year in which they were produced. These retention periods may be extended if required by a relevant supervisory authority. Where processing is based on the Data Controller’s legitimate interest, data will be processed for as long as necessary to implement that interest (in particular until the applicable limitation period expires), unless you successfully object sooner; where the legitimate interest is direct marketing, data will be processed until you object.

19. Right to object

Where personal data is processed for the Data Controller’s direct marketing purposes, you have the right to object without needing to give a reason. Where processing is based on other legitimate interests, exercising your right to object requires justification related to your particular situation.

20. Automated decision-making

You will not be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.