Avanty Markets Group Ltd. ("Avanty Markets", "we", "us" or "our"), a company incorporated in the Republic of the Marshall Islands under registration number [REGISTRATION NUMBER], with its registered office at [REGISTERED ADDRESS], is committed to protecting your privacy. This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and the rights you have in relation to it.
This Policy applies to our website, Client Portal, Trading Platform, Help Center, live chat and any other service we provide (together, the "Services"). By using the Services you acknowledge that you have read and understood this Policy.
1. Data Controller
Avanty Markets Group Ltd. is the data controller responsible for your personal data. For any privacy-related question or request, contact us at [SUPPORT EMAIL].
2. Personal Data We Collect
Depending on how you interact with us, we may collect:
a) Identity and contact data – full name, date of birth, nationality, residential address, email address, telephone number, gender.
b) Verification (KYC) data – copies of government-issued identity documents (passport, national ID, driving licence), proof of address, selfie or liveness check, tax identification number, and, where required, source of funds and source of wealth documentation.
c) Financial data – bank account details, card details (tokenised or partially masked), e-wallet or crypto wallet addresses, deposit and withdrawal history, trading history, account balances and transaction records.
d) Profile and suitability data – employment status, income range, trading experience and knowledge, investment objectives, collected to assess appropriateness of our products.
e) Technical and usage data – IP address, device identifiers, browser type, operating system, time zone, pages visited, referral source, login records, session data and platform interactions.
f) Communications data – emails, live chat conversations, support tickets, call recordings and any correspondence with our support, sales or compliance teams.
g) Marketing data – your preferences in receiving marketing from us and your interactions with our campaigns.
We collect this data directly from you (registration, verification, support), automatically through your use of the Services (cookies and similar technologies – see our Cookies Policy), and from third parties such as identity-verification providers, payment processors, sanctions and PEP screening databases, and publicly available sources.
3. How We Use Your Personal Data
We process your personal data for the following purposes:
Providing the Services – opening and managing your Account, executing and settling trades, processing deposits and withdrawals, providing customer support.
Legal and regulatory compliance – identity verification, anti-money-laundering (AML), counter-terrorist-financing (CTF), sanctions screening, fraud prevention, tax reporting and responding to lawful requests from authorities.
Risk management and security – monitoring trading activity, detecting abuse or unauthorised access, protecting our systems and clients.
Communications – sending service messages, account notifications, security alerts and responses to your enquiries.
Marketing – informing you about products, promotions, webinars and educational content, where you have consented or where permitted by law. You can opt out at any time.
Improvement and analytics – analysing usage to improve our website, platform, products and support.
Legal claims – establishing, exercising or defending legal claims.
We rely on one or more of the following grounds: performance of our contract with you, compliance with legal obligations, our legitimate interests (which do not override your rights and freedoms), and your consent where required.
4. Who We Share Your Data With
We may share your personal data with:
Service providers acting on our behalf, including identity-verification and KYC vendors, payment service providers and banks, cloud hosting and IT providers, customer support and live-chat platforms (such as Intercom), email and communication tools, and analytics providers.
Trading platform and liquidity providers to the extent necessary to open, maintain and execute trades on your Account.
Affiliates and introducing brokers, where you were referred to us, limited to what is necessary to manage the referral relationship.
Professional advisers – auditors, lawyers, accountants and consultants.
Regulators, law-enforcement and government authorities where required by law, regulation, court order or to protect our rights.
Prospective purchasers or investors in the event of a merger, acquisition, restructuring or sale of assets, subject to confidentiality obligations.
We do not sell your personal data.
5. International Transfers
Because we operate globally and use service providers in different countries, your personal data may be transferred to and processed in jurisdictions outside your country of residence. Where we do so, we take reasonable steps to ensure that appropriate safeguards are in place, such as contractual protections, to keep your data secure and treated in accordance with this Policy.
6. Data Retention
We retain your personal data for as long as your Account is active and thereafter for as long as necessary to comply with our legal, regulatory and record-keeping obligations. In line with AML requirements, identity, transaction and communication records are typically retained for a minimum of five (5) years after the end of the client relationship or the date of the relevant transaction, unless a longer period is required by law. Data that is no longer needed is securely deleted or anonymised.
7. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse or alteration, including encryption in transit, access controls, two-factor authentication, secure hosting and staff confidentiality obligations. No system is completely secure; you should also protect your credentials and notify us immediately of any suspected compromise.
8. Cookies and Tracking Technologies
We use cookies, pixels and similar technologies on our website and platform to operate the Services, remember your preferences, analyse traffic and measure the effectiveness of our marketing. For details and how to manage them, please see our Cookies Policy.
9. Your Rights
Subject to applicable law, you may have the right to:
Access the personal data we hold about you;
Rectify inaccurate or incomplete data;
Erase your data, where there is no legal or regulatory reason to retain it;
Restrict or object to certain processing, including direct marketing;
Data portability – receive certain data in a structured, machine-readable format;
Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal;
Lodge a complaint with a supervisory authority in your country of residence.
To exercise any of these rights, contact [SUPPORT EMAIL]. We may need to verify your identity before responding. Please note that certain data (for example, KYC and transaction records) cannot be deleted while we are legally required to retain it.
10. Marketing Communications
Where you have opted in, we may send you marketing by email, SMS, messaging apps or in-platform notifications. You can unsubscribe at any time via the link in our emails, by adjusting your notification settings in the Client Portal, or by contacting support. Service and regulatory communications will continue to be sent as they are necessary to operate your Account.
11. Third-Party Links
Our website and communications may contain links to third-party websites, apps or services (including the Trading Platform provider and payment gateways). We are not responsible for the privacy practices of those third parties, and we encourage you to read their privacy policies.
12. Children
The Services are not directed at, and we do not knowingly collect personal data from, anyone under the age of 18. If we become aware that we have collected such data, we will delete it and close any related account.
13. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will always be available on our website and Help Center with the "Last updated" date. Where changes are material, we will notify you by email or through the Client Portal.
14. Contact Us
Avanty Markets Group Ltd. Registration No. [REGISTRATION NUMBER] Registered Office: [REGISTERED ADDRESS], Republic of the Marshall Islands Email: [SUPPORT EMAIL] Website: [WEBSITE URL]