This Policy explains how the Data Controller — operating the Prime Prop Trading brand — collects, uses, shares and protects your personal data when you use our website, evaluation programs, funded accounts, community channels and related services (the "Services").
Contents
- Who is responsible for your personal data
- How to contact the Data Controller
- Data security
- Use of the website
- What are "cookies"?
- Purposes and legal basis for processing
- Data we collect from clients
- Recipients of personal data
- International transfers
- Data retention
- Your rights
- Automated decision-making
- Changes to this Policy
- Contact
1. Who is responsible for your personal data
The Data Controller of your personal data is FX-EDGE V Ltd based at 1276, Govant Building, Kumul Highway, Port Vila, Vanuatu, company no. 700604.
The Data Controller operates the Services under the trade brand Prime Prop Trading. Where reference is made in this Policy to "Prime Prop Trading", such reference is to the commercial brand under which FX-EDGE V Ltd offers its evaluation and funded account programs.
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 our Data Protection Officer via email at kteofilski@fx-edge.com.
For all other privacy-related questions or for requests in connection with the Services, you may also contact us at support@primeproptrading.com.
3. Data security
In connection with the conducted business activity, the Data Controller collects and processes personal data in accordance with relevant provisions, including in particular the GDPR, POPIA, the DPB and the data processing principles contained therein.
The Data Controller ensures transparency of data processing, informs you about data processing, and ensures that data is collected only to the extent necessary for the purpose indicated and is processed only for the period in which it is necessary.
To ensure data integrity and confidentiality, the Data Controller has implemented procedures enabling access to personal data only by authorised people and only to the extent necessary for their tasks. The Data Controller takes all necessary actions to ensure 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 IP address, type of search engine, language, access time, and the address of the page from which you were redirected. This data may be collected by cookies and analytical tools.
If you contact us via telephone, email or our complaint form, data related to the means of communication chosen by you and data provided during communication are also processed, to the extent necessary to resolve the reported matter.
5. What are "cookies"?
Personalisation and efficiency of services provided by the Data Controller requires saving and storing information on how you use the website. The Data Controller does this by using small text files called "cookies". Cookies contain little information and are saved on your computer or other terminal device by the server operating the website. Disabling cookies in the browser may cause difficulties or inaction of some functions of the website.
The Data Controller generally uses two types of cookies:
- Session cookies — temporary files stored on your end device until you log out, leave the website or turn off the web browser;
- Permanent cookies — files stored on your end device for the time specified in the cookie file parameters or until they are deleted by you.
By functionality, the Data Controller divides cookies into three groups:
- Necessary — files of key importance enabling you to navigate the website and use its functions, such as access to secure areas and to ensure security;
- Performance — files collecting information about how you use the website, which parts of the website you visit most often, and whether you receive error messages. Data collected by these cookies is anonymous and only serves to improve the functioning of the website;
- Functional — files recording the choices made by you; these files can also be used to remember changes made, such as changes in text size or font.
6. Purposes and legal basis for processing
Cookies are used to:
- Adapt the content of the website to your preferences and optimise its use;
- Create statistics that help understand how users use the website, allowing improvements to structure and content;
- Maintain your session after logging in, so you do not have to re-enter login credentials;
- Enable interaction with social networks (e.g. publishing posts directly from the website).
The legal basis for processing in this case is the Data Controller's legitimate interest in ensuring a higher quality of services.
Contact via email or post
In the case of correspondence not related to an agreement concluded with the Data Controller, personal data contained in such correspondence are processed solely for the purpose of communication and resolution of the matter to which the correspondence relates. The legal basis is the Data Controller's legitimate interest in conducting correspondence in connection with business operations. All correspondence is stored in a manner that ensures the security of personal data and disclosed only to authorised persons.
Telephone contact
In the event of contact by phone in matters not related to a concluded agreement, the Data Controller may request personal data only if necessary to handle the case. The legal basis is the Data Controller's legitimate interest in resolving the reported case.
Business contacts
In connection with the conducted activity, the Data Controller collects personal data also in other cases (e.g. business meetings, exchanging business cards) for purposes related to initiating and maintaining business contacts. The legal basis is the legitimate interest of the Data Controller in creating a network of contacts. Personal data collected in such cases are processed only for the purpose for which they were collected.
7. Data we collect from clients
Where you participate in the Services as a client (i.e. registering for a challenge, evaluation or funded account), your personal data will be processed for the purpose of concluding and performing the agreement executed with the Data Controller, as well as fulfilling the Data Controller's legal and regulatory obligations.
The legal basis for processing your personal data in this context is:
- To the extent that processing is necessary to perform the agreement and to take actions before its conclusion;
- To the extent that processing is necessary for the Data Controller to fulfil its legal obligations, including informing financial supervision and financial information authorities about services and transactions, verification and identification of the client's identity, and ongoing monitoring of economic relations;
- To the extent that processing is necessary to achieve the legitimate interests of the Data Controller, such as making necessary settlements and pursuing claims arising from the concluded agreement, security, counteracting fraud, or direct marketing of the Data Controller.
Providing personal data is voluntary, but necessary to conclude the agreement and use the Data Controller's services. Failure to provide the personal data will result in refusal to conclude the agreement.
8. Recipients of personal data
In connection with our business activities, your personal data may be disclosed to external entities, including in particular:
- Suppliers responsible for operating IT systems and analytical tools;
- The trading platform provider — Match-Trade Technologies LLC (operator of the Match-Trader platform);
- Banks, payment institutions and authorised payment service providers (including Odeonpay ALE S.R.L. ("Paysagi"), acting as Merchant of Record);
- Virtual asset service providers;
- Companies from the capital group to which the Data Controller belongs;
- Postal operators;
- Supervisory authorities and financial information authorities;
- Suppliers of tools and platform software used to handle transactions and financial operations;
- Marketing agencies, accounting providers and legal advisers;
- Entities providing servers and storing data.
The Data Controller reserves the right to disclose selected information about you to competent authorities or third parties who submit a request for such information, based on an appropriate legal basis and in accordance with applicable law.
9. International transfers
The Data Controller transfers personal data outside the country only when necessary and with an adequate level of protection. Where personal data is transferred to third countries, the Data Controller transfers it using mechanisms in accordance with applicable law (including, where applicable, Standard Contractual Clauses).
10. Data retention
The period of data processing by the Data Controller depends on the type of service provided and the purpose of processing. The period may also result from legal provisions when they constitute the basis for processing.
- Where processing is based on the Data Controller's legitimate interest, data is processed for a period enabling implementation of this interest or until you object effectively;
- Where processing is based on consent, data is processed until consent is withdrawn;
- Where processing is necessary to conclude and perform an agreement, data is processed until its termination;
- For clients of the Services, personal data will be stored for the duration of the agreement and for a period of five (5) years following termination, counting from the first day of the year following the year in which the economic relationship ended, or until the limitation period for claims arising from legal provisions expires. Data included in results of assessments of economic relations will be processed for five (5) years;
- The above storage periods may be extended if required by the relevant supervisory authority.
After the end of the processing period, the data is irreversibly deleted or anonymised.
11. Your rights
The Data Controller informs that, in connection with the processing of personal data, you have the following rights:
- Right to information about the processing of personal data — the Data Controller will provide information on data processing, including purposes and legal grounds, the scope of data held, entities to which it is disclosed, and the planned date of data deletion;
- Right to obtain a copy of the data — the Data Controller will provide a copy of the data processed upon request;
- Right to rectification — the Data Controller is obliged to remove any incompatibilities or errors of personal data being processed and supplement them if they are incomplete;
- Right to delete data — you may request deletion of data the processing of which is no longer necessary to achieve any of the purposes for which it was collected;
- Right to limit processing — in the event of such a request, the Data Controller ceases to perform operations on personal data until the reasons for restriction cease;
- Right to transfer data — to the extent that the data is processed in an automated manner in connection with an agreement or consent, the Data Controller issues the data provided in a format that allows it to be read by a computer. It is also possible to request that the data be sent to another entity, provided there are technical possibilities;
- Right to object to processing for marketing purposes — without giving any reason;
- Right to object to other purposes of data processing — at any time, for reasons related to your particular situation, you may object to processing based on the Data Controller's legitimate interest;
- Right to withdraw consent — if data are processed on the basis of consent, you have the right to withdraw it at any time, which does not affect the lawfulness of processing carried out before its withdrawal;
- Right to complain — if you find that the processing of personal data violates applicable law, you may submit a complaint to the supervisory authority competent for your habitual residence, place of work or place of the alleged violation.
To exercise any of these rights, email kteofilski@fx-edge.com or support@primeproptrading.com. We may need to verify your identity before responding.
12. Automated decision-making
The Data Controller will not apply a decision that is based solely on automated processing, including profiling, and produces legal effects concerning you or similarly significantly affects you.
13. Changes to this Policy
We may update this Policy from time to time. Material changes will be communicated by email or by a prominent notice on the website. The "Last updated" date at the top reflects the current version.
14. Contact
For any questions, requests, or concerns regarding this Privacy Policy or our handling of your personal data:
Data Protection Officer: kteofilski@fx-edge.com
General enquiries: support@primeproptrading.com
Data Controller: FX-EDGE V Ltd, 1276, Govant Building, Kumul Highway, Port Vila, Vanuatu (company no. 700604)
Trade brand: Prime Prop Trading