Privacy Policy

1. Introduction

This Privacy Policy (“Policy”) applies to Ultimate Traders Evaluation Ltd (“we”, “our” or the “Company”). This Policy outlines how the Company collects, maintains, uses and discloses personal information about our customers (“you”, “your” or the “Customer”). This Policy applies to existing and potential clients as well as to any visitors of the Company website. We are data controllers for purposes of the data protection legislation.

The Company is committed to protecting the privacy of all Personal Data (as defined herein) which it obtains from you, including information obtained during your visits to this website.

This Policy shall be considered and read in conjunction with our Terms & Conditions, uploaded on the website at www.ultimatetraders.com (“Website”) and any other agreement which we may have provided.

2. What Personal Data do we collect and how?

The Company will collect and hold Personal Data about you when you complete an online application for a live or demo account or after you have successfully participated in any challenge offered on our Website.

The Company collects certain Personal Data in order that it may meet the needs of its customers through the efficient provision of services. By collecting certain Personal Data, the Company is able to monitor and improve the services which it offers to its existing and potential customers.

By “personal data”, we mean any personal information which you may provide to us directly, and/or we may collect by providing our services to you and/or through your use of our Website. The Company will only use your Personal Data in accordance with worldwide data protection practices. Personal data which we collect includes but is not limited to:

Any data you provide to us, including personal details such as name, address, date of birth, telephone number, e-mail address, identity verification documents such as passport and ID, utility bills, and/or bank statements or your company incorporation certificates/details, financial details such as estimated annual income and net worth, trading experience and investment knowledge.

Any data we automatically collect when you use our services, including IP addresses, device type, operating system, country visiting the Website, login and logout information, account settings, challenges selected or customized, currency, types of transactions conducted, communications either electronic or by telephone.
Any data we automatically collect about your simulated transactions, including type of selected or customized challenge, type of financial instrument, time of opening or closing positions, amount of investment, profit and loss;
Any data we automatically collect when you visit our Website, including site areas visited, pages viewed, frequency and duration of visits, websites which may have referred you or to which you link.

3. Why do we use your Personal Data?

The Company may use your information for any one or more of the following purposes:

To confirm your identity;
To maintain your personal profile;
To assess your suitability to the products and services we provide;
To provide the services to you that you have requested including processing transactions;
To provide you with transaction and post transaction related services;
To inform you of products and/or services that may be of interest to you;
To keep you updated on the issues that are relevant to your business relationship with us;
To tailor the website to your needs and interests;
To analyze impersonalized statistical data to enable us to provide you with better products and/or services.
To administer your account and monitor its conduct and assess and analyse any credit limit, including, the interest rate, fees and other charges to be applied to the Client’s Account;
To pass your Personal Data to third parties for marketing purposes;

4. What is the lawful basis for processing your Personal Data?

To perform our services to you.

We process Personal Data in order to provide our services and products to you, including to perform our contractual obligations and meet your expectations. We need to use your personal information so we comply with our legal obligations and fulfil “Know Your Customer” and “Customer Due Diligence” regulatory requirements.

To comply with our legal obligations.

We need to adhere to number of relevant laws and regulations which relate to anti-money laundering laws, terrorist financing laws, financial services laws, data protections laws and several others. Any obligations arising from the laws which we are subject to, require us to follow certain personal data processing activities. These activities, include but is not limited to, payment processing, compliance with competent authorities and/or court orders, or other reporting obligations and anti-money laundering controls.

To safeguard our legitimate interests.

We process Personal Data to protect our legitimate interests pursued by us or by third parties. A legitimate interest arises when we have a business reason to use your data. This will include instances where there is a client relationship, a litigation procedure or legal claim, for direct marketing purposes to prevent fraud or to ensure the network and information security.

You have provided your consent.
To offer you our products and services, or any information you may ask.

It is in our legitimate interests to ensure that we are providing the best possible products and services. In order to monitor the quality of our products and services, we regularly review your needs, questions to ensure that you remain satisfied with us and our services.

To improve our products and services.

In order to ensure that our products and services are up to the highest standards, we will use your Personal Data in this way to improve and resolve any issues which may arise with your experience with us.

5. How long do we keep your Personal Data?

Personal Data are processed to the extent necessary to perform the services and for the period of years required by law. We, specifically, keep Personal Data for a period of at least seven (7) years, calculated after the execution of the latest transaction or the termination of the business relationship, whichever is the latest.

6. Where and why we will disclose your Personal Data?

The Company shall not disclose any confidential information belonging to you, to a third party, unless:

We are required to do so pursuant to any applicable laws, rules and/or regulations;
If our legitimate business interests require disclosure, including to any payment service providers and/or banking institutions;
If we receive a request from competent authorities and/ or regulatory authorities and/or government bodies, or
You have given us your consent to do so.

If we disclose your personal information to business parties, such as card processing companies or banks, in order to perform the services you require us to do, such business parties may store your information to comply with their regulatory obligations.

Further to the above, the Company will disclose your Personal Data when is necessary to:

protect our rights and/or comply with any court order or judicial proceedings;
avoid any potential fraud;
conform to the edicts of the law or comply with a legal process served on the Company or on the Company’s website;
protect and defend the rights or property of the Company (and companies which belong to the same group as the Company or affiliated companies) websites, and,
act in urgent circumstances to protect the personal safety of users of the Company, its websites, or the public.

The Company may also disclose your Personal Data to:

The Company’s third party processors who process data on behalf of the Company and who may only use it for the same purposes as the Company, subject to Clauses 6.1 and 6.2 below.
Vendors which the Company hires to provide limited services on our behalf, including packaging, mailing and delivering purchases, postal mail, etc. The Company will ensure that none of your Personal Data will be disseminated to those vendors. Such vendors will only be subject to the information they need to deliver the service, and they are prohibited from using the information for any other purpose.

Financial institutions and other similar organizations that it deals with in the course of its corporate activities, or those that are nominated by you;
External service providers and professional advisers (which may be located overseas) that provide services to the Company;
Any organisation at your request or any persons acting on your behalf, including your financial adviser, broker, solicitor or accountant;
Any third parties where this is necessary to process a transaction or provide services which you have requested; or
Any authority to whom the Company is required to disclose such information by law.
Any business partner which we may provide for statistical purposes. In no circumstances will you be able to be identified from this statistical data; you will remain anonymous.

7. Processors

The Processors shall ensure that:

(a) the Processor’s employees are informed of the confidential nature of the Personal Data; and

(b) it will process the Personal Data in compliance with all applicable laws, enactments, regulations, orders, standards and other similar instruments.

The Processors agree to indemnify and keep indemnified at its own expense the Company against all costs, claims, damages or expenses incurred by the Company or for which the Company may become liable due to any failure by the Processor or its employees to comply with any of its obligations under this Privacy Policy.

8. We may transfer your data outside of the European Economic Area (“EEA”)

The Company reserves its right to transfer your personal information inside or outside the EEA to service providers and Processors. In case your data is transferred outside of EEA, we will make sure that the transfer is lawful and that Processors in third countries comply with the European data protections laws or their applicable laws relating to data protection.

The Company will take all steps reasonably necessary to ensure that your data is transferred securely and in accordance with this Privacy Policy.

9. What are your rights?

You are not obligated to provide any of your Personal Data to the Company. In the event you do not, the Company may not be able to verify your account or provide the services and products you may be permitted.

Under the applicable data protection legislation, you have (subject to certain exceptions) the right to request any Personal Data the Company holds about you and to inform the Company of any perceived inaccuracy. We may charge a fee to cover the associated administrative costs in case the request is manifestly unfounded or excessive.

You may inform the Company at any time that your personal details have changed or request to delete your Personal Data by emailing us at support@ultimatetraders.com. The Company will change or delete your Personal Data in accordance with your instructions, except to the extent that we are required to hold your Personal Data for regulatory or legal purposes or for any other reason we hold legitimate business interest.

If you have any questions, complaints or requests, please write to the Company, verifying your identity and setting out in full what information you require. If a complaint is not resolved by the Company to your satisfaction, you may complain to the Information Commissioner.

10. Consent

By accessing this website, you consent to the Company collecting, maintaining, using and disclosing Personal Data about you and provided by you or by another person as in accordance with this Privacy Policy.

11. Links

When you use this website, you may be able to link to other websites. This Privacy Policy does not apply to those other sites. The Company encourages you to read and understand the privacy policies on these other sites.

12. We use cookies

The Company uses cookies to gather information about your access to our website and other services we provide to you. Please note that this description is not comprehensive and the Company’s Cookie Policy contains additional information.

Cookies are small pieces of information which use a unique identification tag and are stored on your device as a result of you using this website or other services we provide to you.

Most internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to have your computer notify you each time a cookie is sent to it, and thereby give yourself the choice whether to accept it or not. However, it is strongly recommended that you allow cookies on our website to ensure you have the best possible experience. Turning off cookies may result in reduced performance of our website and trading platform and may also impair the quality of the services that we provide to you in relation to your account.

13. We apply strong security measures

The Company adopts strong measures to protect the security of your Personal Data and to ensure it is not accessed by unauthorised persons. Access to Personal Data is restricted to employees and authorized service providers who need it to perform their work. You must not share or disclose your log in details with any third party.

The Company takes strong precautions to protect your Personal Data from loss, theft, copying, misuse, unauthorised access or disclosure, alteration, or destruction. Measures include encryption during data transmission, strong authentication mechanisms and separation of machines and data to provide secure areas.

14. We will amend this policy

The Company reserves the right to make changes to this Privacy Policy from time to time for any reason and you should visit our Website in order to read our most updated version. You are responsible for regularly reviewing this Privacy Policy and if you use this website after any such changes are published, such use shall constitute your agreement to such changes.

21^st June 2023 – v.2023/001