Privacy Policy
1. Introduction
aiTrate Fintech Ltd. (“aiTrate”, “we”, “us”, or “our”) is committed to protecting the privacy and security of personal data. This Privacy Policy explains how we collect, use, store, and protect information when you access our website, platforms, and digital services (collectively, the “Services”).
Our Services are directed exclusively at institutional market participants and qualified professional counterparties. We do not knowingly collect personal data from retail investors or the general public in a commercial capacity.
2. Data Controller
The data controller responsible for the processing of your personal data is:
aiTrate Fintech Ltd.
Commerce House, Wickhams Cay 1, PO Box 2283
Road Town, Tortola VG 1110, British Virgin Islands
3. Information We Collect
3.1 Information Collected Automatically
When you access our Services, we may automatically collect certain technical and usage data, including but not limited to: IP address and approximate geolocation; browser type, version, and language settings; operating system and device information; date, time, and duration of access; pages visited, navigation paths, and interaction patterns; referring URL and exit pages; and connection speed and network information.
3.2 Information You Provide
We may collect information that you voluntarily provide to us, including but not limited to: name, email address, and professional contact details submitted through contact forms or correspondence; organizational affiliation and professional role; information contained in communications you send to us; and any other information you choose to provide in connection with your use of our Services.
3.3 Cookies and Tracking Technologies
Our Services may use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your browsing behavior and preferences. These technologies serve operational, analytical, and security purposes. You may control cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of our Services.
We categorize cookies as follows: (a) strictly necessary cookies, which are essential for the operation of our Services; (b) analytical cookies, which help us understand how visitors interact with our Services; and (c) functional cookies, which enable enhanced functionality and personalization.
4. How We Use Your Information
We process personal data for the following purposes:
Operational purposes: to operate, maintain, and improve our Services, ensure technical functionality, and manage our infrastructure.
Security purposes: to detect, prevent, and respond to fraud, unauthorized access, security incidents, and other potentially harmful activities.
Analytical purposes: to analyze usage patterns, measure performance, and generate aggregated, non-identifiable statistical insights to improve our Services.
Communication purposes: to respond to inquiries, provide information you have requested, and manage professional correspondence.
Legal and compliance purposes: to comply with applicable laws, regulations, legal processes, and enforceable governmental requests, and to establish, exercise, or defend legal claims.
We do not use personal data for marketing, advertising, profiling for commercial purposes, or any form of automated decision-making that produces legal effects concerning individuals.
5. Legal Basis for Processing
Where applicable data protection laws require a legal basis for processing personal data, we rely on the following:
Legitimate interests: processing is necessary for our legitimate interests in operating and securing our Services, analyzing usage for improvement, and maintaining professional communications, provided such interests are not overridden by your fundamental rights and freedoms.
Legal obligation: processing is necessary to comply with a legal obligation to which we are subject, including regulatory requirements and law enforcement requests.
Consent: where required by applicable law, we process personal data based on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
Contractual necessity: processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
6. Data Sharing and Disclosure
We do not sell, rent, trade, or otherwise commercially distribute your personal data to third parties.
We may share personal data in the following limited circumstances:
Service providers: we may engage trusted third-party service providers who perform functions on our behalf, such as hosting, data analytics, security monitoring, and IT maintenance. These providers are contractually obligated to process personal data only as instructed by us and to maintain appropriate security measures.
Legal requirements: we may disclose personal data if required to do so by law, regulation, legal process, or enforceable governmental request, or where disclosure is necessary to protect our rights, property, or safety, or that of others.
Corporate transactions: in the event of a merger, acquisition, reorganization, or sale of assets, personal data may be transferred as part of such transaction, subject to appropriate confidentiality obligations.
Professional advisors: we may share personal data with our legal, financial, and other professional advisors as necessary for the provision of their services to us.
7. International Data Transfers
aiTrate is incorporated in the British Virgin Islands and our Services may be accessed from various jurisdictions worldwide. Your personal data may be transferred to, stored in, and processed in jurisdictions other than your country of residence, including jurisdictions that may not provide the same level of data protection as your home jurisdiction.
Where we transfer personal data internationally, we implement appropriate safeguards to ensure that your data is protected in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include standard contractual clauses, data processing agreements, or other legally recognized transfer mechanisms.
8. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements.
The retention period for personal data is determined based on the nature of the data, the purposes for which it is processed, applicable legal requirements, and our legitimate operational needs. Automatically collected technical data is typically retained for a period of twelve (12) months, after which it is aggregated or anonymized.
When personal data is no longer required, we will securely delete or anonymize it in accordance with our data retention policies and applicable legal obligations.
9. Data Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, loss, or destruction. These measures include, but are not limited to: encryption of data in transit and at rest; access controls and authentication mechanisms; regular security assessments and monitoring; secure infrastructure and network architecture; and employee training on data protection and security practices.
While we take reasonable steps to protect personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your data and accept no liability for any unauthorized access or breach that occurs despite our reasonable security measures.
10. Your Rights
Depending on your jurisdiction and applicable data protection laws, you may have certain rights regarding your personal data, which may include:
Right of access: the right to request confirmation of whether we process your personal data and to obtain a copy of such data.
Right to rectification: the right to request correction of inaccurate or incomplete personal data.
Right to erasure: the right to request deletion of your personal data, subject to applicable legal exceptions.
Right to restriction: the right to request restriction of processing of your personal data under certain circumstances.
Right to data portability: the right to receive your personal data in a structured, commonly used, and machine-readable format.
Right to object: the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
Right to withdraw consent: where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us using the details provided in Section 14 of this Privacy Policy. We will respond to your request within the timeframe required by applicable law. We may request additional information to verify your identity before processing your request.
11. Third-Party Links and Services
Our Services may contain links to third-party websites, platforms, or services. This Privacy Policy does not apply to any third-party services. We are not responsible for the privacy practices, content, or data processing activities of any third party. We encourage you to review the privacy policies of any third-party services before providing personal data or accessing such services.
12. Children’s Privacy
Our Services are not directed at individuals under the age of eighteen (18), and we do not knowingly collect personal data from children or minors. If we become aware that we have inadvertently collected personal data from a child, we will take reasonable steps to delete such data promptly. If you believe that we may have collected personal data from a child, please contact us immediately using the details provided in Section 14.
13. Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time at our sole discretion. Any changes will become effective immediately upon posting the revised Privacy Policy on our website. The “Effective Date” at the top of this policy will be updated accordingly.
We encourage you to review this Privacy Policy periodically. Your continued use of our Services after any modifications constitutes your acceptance of the revised Privacy Policy.
14. Contact Information
For any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us at:
aiTrate Fintech Ltd.
Commerce House, Wickhams Cay 1, PO Box 2283
Road Town, Tortola VG 1110, British Virgin Islands
15. Supervisory Authority
If you believe that our processing of your personal data infringes applicable data protection laws, you may have the right to lodge a complaint with a competent supervisory authority in your jurisdiction. We encourage you to contact us first so that we can address your concerns directly