Privacy Policy

Updated November 24, 2022

Please read this privacy policy (the “Privacy Policy”) carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information, and on how to contact us or supervisory authorities if you have a complaint.

This Privacy Policy sets forth the policy of Fintelligentia Trading, LLC and its affiliates (collectively, the “Company”) with respect to personal information that the Company may collect through this website (including any mobile application or version of the website, collectively, the “Site”). This Privacy Policy may be changed at any time. This Privacy Policy applies to the personally identifiable information of individuals as well as the confidential information and trade secrets of businesses (collectively, the “Personal Information”). If you have a separate written non-disclosure agreement with the Company (the “NDA”), the NDA will supersede any conflicting or inconsistent language in this Privacy Policy unless the parties agree otherwise in writing.

Who we are

Fintelligentia Trading, LLC and its related companies do business around the world. The Company collects, uses, and is responsible for certain personal information about you. In the United Kingdom and European Union, those activities are regulated under the UK Data Protection Act 2018 and the EU General Data Protection Regulation, respectively, and we are responsible as the ‘controller’ of your personal information for the purposes of those laws.

The personal information we collect and use Information you provide voluntarily

In the course of using our website, submitting documents to us (including AML/KYC materials), consulting with our support teams, sending us an email, or communicating with us in any way, you are voluntarily giving us information that we collect. That information may include either your name, email address, IP address, phone number, postal address, gender, location, occupation, business information, or other information of a demographic nature. In supplying this information, you consent to this information being collected, used, disclosed, transferred to our related companies, and stored by us, as described in our Terms and this Privacy Policy.

Information we automatically collect

When you browse our websites, use our onboarding platforms or interact with our electronic communications, we may collect information about your web browsing and use of the site or communication. This may include details of your operating system, location, IP address, browser ID, browsing activity, and other information about how you interacted with our services or devices. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. We use this information to help improve the website or monitor the performance of our campaigns.

The Company and our third-party partners may use assorted technologies to collect and store information when you use our digital tools or interact with our electronic communications. This may include using cookies and similar tracking technologies (e.g. pixels and web beacons) to analyze behavior, track movements around the website, provide targeted advertisements, and gather demographic information. We may partner with third parties to display advertising on our website or to manage and supply our advertising on other sites. These partners may use cookies or other tracking methods in order to provide you content or advertisements based upon your browsing activities and interests. You are able to control the use of cookies at an individual browser level.

The Company does not disclose any Personal Information to anyone other than its affiliates and related companies, except as required by applicable law. The Company may also disclose Personal Information to its professional advisors and regulators and to certain service providers, such as the third party that hosts this Site.

This Site may use “cookies,” which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from the Company’s web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this Site. Cookies also help the Company diagnose problems with the Company’s server.

The Company seeks to carefully safeguard your Private Information and, to that end, restrict access to nonpublic Personal Information to those employees and certain other persons, including service providers such as the third party that hosts this Site, who need to know such information.

If you have any questions or comments about this Privacy Policy, please feel free to contact the Company at legal@fintelligentia.com.

Information from elsewhere

The Company may obtain information about you or your end-users from third parties, such as public databases, social media platforms, third-party data providers, and our marketing partners. Examples of the information we may receive from other sources include device information (e.g. IP address and browser), location, behavioral data, and demographic information. We may use this information, alone or in combination with other information described above, to develop or provide more relevant platform features or services (e.g. social media data of end-users allowing you to send more relevant content) or provide more relevant marketing and content to you.

How we use personal information

We use and disclose personal information to supply, improve and support the user experience. This allows the Company to monitor your use of our website, products, and services, and to track our relationship so that we can improve our products and services. We may also use these third-party services for communications, either through email or through messages within our products and services. These third-party services may collect publicly available contact and social information related to you, such as your name, email address, gender, company, job title, photos, website URLs, social network handles, and physical addresses, to enhance your user experience.

Third parties

We may disclose personal information to advertising partners, networks, and exchanges to display advertising on our website or to manage and serve our advertising on other sites and we may share personal information with them for this purpose. All third parties with which we share this information are required to use your Personal Information in a manner that is consistent with this policy. This may include using cookies and similar tracking technologies (e.g. pixels and web beacons) to analyze behavior, track movements around the website, provide targeted advertisements, and gather demographic information. We partner with third parties to display advertising on our website or to manage and supply our advertising on other sites. These partners may use cookies or other tracking methods in order to provide you content or advertisements based upon your browsing activities and interests. Please refer to our Cookie Policy for more information.

How long your personal information will be kept

We will hold your Personal Information for any reasonable period, subject to applicable law. We may maintain your Personal Information after the termination of our relationship with you for record-keeping and enforcement purposes.

Transfer of your information out of the UK or the EEA

Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our service or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. Please note that our entities may operate under Standard Contractual Clauses and applicable measures of the GDPR providing protections and safeguards for cross-border transfers. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Your GDPR rights

Residents of the United Kingdom or the European Union have important rights under the General Data Protection Regulation (“GDPR”), including rights to:

fair processing of information and transparency over how we use your use personal information
access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address
require us to correct any mistakes in your information which we hold
require the erasure of personal information concerning you in certain situations
receive the personal information concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal information concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal information
otherwise, restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email, call or write to our Data Protection Officer
let us have enough information to identify you,
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
let us know the information to which your request relates, including any account or reference numbers, if you have them

If you would like to unsubscribe from any email newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email. It may take some time for this to take effect.

Your CCPA Rights

In addition to the general rights set out under this Privacy Policy, California law provides additional rights to California residents, including rights to:

request information, including a list of the categories of Personal Information (e.g. name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties direct marketing purposes, from businesses with whom you have an established business relationship, and the names and addresses of such third parties
portability of such information and receive the personal information concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations
require the erasure of personal information concerning you in certain situations.

We will not sell your Personal Information to third parties.

Keeping your personal information secure

We make commercially reasonable efforts to prevent personal information from being accidentally lost, used, or accessed without authorization. We will seek to limit access to your Personal Information to those who have a legitimate need to know. Those processing your information are authorized and subject to a duty of confidentiality. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a data security breach when required by applicable law.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

For individuals in the UK or EU, the General Data Protection Regulation gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. For UK individuals, the supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone at 0303 123 1113 or other channels as updated at https://ico.org.uk/global/contact-us.

For individuals in the Netherlands, the supervisory authority is the Dutch Data Protection Authority who may be contacted at https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us.

How to contact us

If you have any questions or concerns about the way in which we handle any privacy matter or your Personal Information, please contact us at legal@fintelligentia.com.

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