Privacy Policy

1. Introduction and Service Description

AlgoTroves ("we," "us," "our," or "Company") is committed to protecting your privacy and maintaining transparency about how we handle your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our autobrokerage platform, and engage with our services.

AlgoTroves is a global multi-asset autobrokerage platform that executes automated trading strategies using proprietary algorithms across equities, forex, commodities, and cryptocurrencies. We operate on a spread-compensation model where we cover trading spreads as part of our service delivery. Your privacy is fundamental to our operations, and we comply with applicable data protection regulations in all jurisdictions where we operate.

2. Information We Collect

We collect personal information in multiple ways to provide our autobrokerage services, verify your identity, and comply with regulatory requirements. This includes:

2.1 Information You Provide Directly

• Account Registration: Legal name, email address, phone number, residential address, date of birth, nationality, tax identification number, employment information, and income/net worth details.
• Identity Verification (KYC): Government-issued ID documents, proof of address, proof of funds, beneficial ownership information, and other documents required for compliance screening.
• Financial Information: Bank account details, payment method information, funding source documentation, transaction history, portfolio holdings, and investment experience questionnaires.
• Communication: Emails, chat messages, support tickets, feedback, and any correspondence you send to us.
• Profile Information: Trading preferences, risk tolerance assessments, investment objectives, and account settings.

2.2 Information Collected Automatically

• Device Information: Device type, operating system, browser type, device identifiers, hardware model, and mobile network information.
• Usage Data: Pages accessed, time spent on the platform, features used, buttons clicked, links followed, searches performed, and interaction patterns.
• Trading and Transaction Data: Trade execution details, open/closed positions, entry/exit prices, trading timestamps, order types, and transaction amounts.
• Cookies and Similar Technologies: Session cookies, persistent cookies, web beacons, pixels, and similar tracking technologies to enhance user experience and analyze platform usage.
• IP Address and Location: IP address, approximate geographic location based on IP geolocation (not precise GPS), connection type, and ISP information.
• Performance and Analytics: Investment returns, algorithm performance metrics, portfolio composition, risk metrics, and account analytics.

2.3 Third-Party Data

• Regulatory and Compliance Data: Information from sanctions screening databases, fraud detection services, credit bureaus, and regulatory authorities.
• Data from Partners: Information provided by our payment processors, liquidity providers, custodians, and other service providers necessary for transaction processing.

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Delivery and Operations

• Creating and managing your autobrokerage account
• Processing deposits, withdrawals, and executing trades on your behalf
• Running our proprietary algorithms and executing automated trading strategies
• Calculating returns, performance metrics, and generating account statements and trade confirmations
• Providing customer support, technical assistance, and resolving account issues
• Monitoring platform security and preventing fraudulent transactions

3.2 Compliance and Regulatory Requirements

• Verifying your identity and conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance checks
• Screening against sanctions lists and performing sanctions compliance procedures
• Complying with financial reporting requirements and regulatory obligations
• Detecting and preventing money laundering, terrorism financing, fraud, and other illegal activities
• Responding to regulatory inquiries, legal process, and government requests
• Maintaining audit trails and records for regulatory examination

3.3 Business Operations and Improvement

• Analyzing platform usage patterns to improve user experience and features
• Conducting research on algorithmic trading performance and market analysis
• Testing platform functionality and optimizing system performance
• Developing new features, products, and services
• Creating aggregated and anonymized statistical reports for business intelligence
• Managing risk and maintaining business continuity

3.4 Communications and Marketing

• Sending account confirmations, transaction notifications, and service updates
• Providing important security alerts and platform announcements
• Sending educational content and market insights (if you have opted in)
• Responding to your inquiries and requests
• Sending promotional communications and offers (with your consent where required)

4. Data Sharing and Disclosure

4.1 When We Share Your Information

We may share your personal information with third parties in the following circumstances:

• Service Providers: Payment processors, liquidity providers, custodians, cloud hosting providers, analytics providers, and customer support vendors who need access to data to provide services.
• Regulatory Authorities: Financial regulators, tax authorities, law enforcement, and government agencies as required by law or legal process.
• Legal Requirements: When required by court order, subpoena, warrant, or other legal process; to comply with applicable laws; or to protect our rights and the rights of other users.
• Business Transfers: If AlgoTroves is acquired, merged, or enters bankruptcy, your information may be transferred as part of that transaction.
• Fraud Prevention: With fraud detection services, security providers, and financial institutions to prevent fraudulent activity and protect against unauthorized access.

4.2 What We Do NOT Do

• We do not sell your personal information to third parties for marketing purposes.
• We do not share your trading strategies or algorithmic preferences with other users or competitors.
• We do not disclose your account balances or transaction details to unauthorized third parties.
• We do not use your personal data for purposes not disclosed in this Privacy Policy without obtaining your prior consent.

5. Data Security and Protection

We implement comprehensive technical, administrative, and physical security measures to protect your information from unauthorized access, alteration, disclosure, or destruction:

• Encryption: Industry-standard SSL/TLS encryption for data transmitted over the internet and encrypted storage for sensitive data at rest.
• Authentication: Multi-factor authentication (MFA), strong password requirements, and secure session management for account access.
• Access Controls: Role-based access controls, employee background checks, and strict authorization procedures for staff accessing sensitive data.
• Security Audits: Regular security audits, penetration testing, vulnerability assessments, and security incident response procedures.
• Data Backup: Redundant data backup systems, disaster recovery procedures, and business continuity planning.
• Monitoring: Continuous monitoring for suspicious activity, unauthorized access attempts, and security threats.

Important: While we maintain robust security measures, no online system is completely secure. We cannot guarantee absolute security of your information. You are responsible for maintaining the confidentiality of your login credentials and notifying us immediately of any unauthorized access.

6. Your Privacy Rights and Choices

6.1 Access and Correction

You have the right to access, review, and update your personal information. You can modify most account details through your account dashboard or by contacting our support team. We will provide you with a copy of your personal data upon request within 30 days.

6.2 Data Deletion

You may request deletion of your personal information, subject to legal and regulatory retention obligations. We must retain certain information for compliance purposes (typically 7 years for financial records). Upon account closure, we will delete non-required information in accordance with our data retention schedule.

6.3 Marketing Communications

You can opt out of promotional emails and marketing communications at any time by clicking the unsubscribe link in our emails or adjusting your communication preferences in your account settings. You will continue to receive transactional and service-related communications even if you opt out of marketing.

6.4 Cookie Preferences

Most browsers allow you to refuse cookies or alert you when cookies are being set. You can control cookie preferences through your browser settings. Note that disabling cookies may affect some platform functionality.

6.5 Regulatory Rights

Depending on your jurisdiction, you may have additional rights under data protection laws (such as GDPR, CCPA, or equivalent regulations), including rights to data portability, restriction of processing, and objection to processing. Contact us to exercise these rights.

7. Data Retention

We retain your personal information only as long as necessary to provide services, comply with legal obligations, and resolve disputes:

• Account Data: Retained for the duration of your account plus 7 years for regulatory and tax compliance purposes.
• Transaction Records: Retained for at least 7 years as required by financial regulations and anti-money laundering laws.
• Trading History: Retained for 7 years to comply with financial services regulations and for dispute resolution.
• KYC/AML Documents: Retained for 7 years after account closure for regulatory compliance and audit purposes.
• Communications: Retained for 2-3 years unless longer retention is required for legal or compliance reasons.
• Cookies and Tracking Data: Most cookies expire after 12-24 months or when you clear your browser cache.
• Aggregated Data: Anonymized and aggregated data may be retained indefinitely for business intelligence and analytics.

8. Third-Party Links and Services

Our platform may contain links to third-party websites, applications, and services that are not operated by AlgoTroves. This Privacy Policy does not apply to third-party websites or services. We encourage you to review their privacy policies before providing any personal information. We are not responsible for the privacy practices of third parties.

9. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will promptly delete such information and terminate the child's account.

10. International Data Transfers

AlgoTroves operates globally, and your information may be transferred to, stored in, and processed in jurisdictions other than your country of residence. These jurisdictions may have different data protection laws. By using our Services, you consent to the transfer of your information to jurisdictions outside your country of residence, including jurisdictions that may not have equivalent data protection laws.

11. Contact Information and Data Subject Requests

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

• Privacy Team: privacy@algotroves.com
• Support: support@algotroves.com
• Data Subject Requests: dpo@algotroves.com
• Mailing Address: AlgoTroves, [Your Operating Jurisdiction]

We aim to respond to all privacy inquiries and data subject requests within 30 days. If you are unsatisfied with our response, you may have the right to lodge a complaint with your local data protection authority or financial regulator.

12. Policy Updates

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated via email to your registered account email address or by prominently posting the updated policy on our website. Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy.

13. Additional Information for Specific Jurisdictions

13.1 European Economic Area (GDPR)

If you are located in the EEA, your personal data is processed under the General Data Protection Regulation (GDPR). Our legal basis for processing includes: (i) performance of the services agreement with you; (ii) compliance with legal obligations; (iii) protection of vital interests; and (iv) legitimate business interests. You have the right to lodge a complaint with your local data protection authority.

13.2 California (CCPA)

If you are a California resident, you have the right to know what personal information we collect, delete your information, and opt out of the sale or sharing of your personal information. We do not sell personal information, but you may exercise these rights by contacting us at privacy@algotroves.com.