Privacy Policy

Primora Trading – Effective May 9, 2025

Introduction

This Privacy Policy outlines how Primora Trading (“we”, “us”, “our”) collects, uses, stores, shares, and protects your personal information following applicable international and local data protection laws, including but not limited to the General Data Protection Regulation (GDPR), Data Protection Act, and other regulatory frameworks. It is designed to give you transparent insight into your rights, our practices, and how we ensure your data is handled securely and lawfully.

We are committed to safeguarding the personal data of all individuals who interact with our services, whether clients, website visitors, or app users. Your privacy is important to us, and this policy serves as a critical element of our compliance structure.

Please read this policy carefully. It explains:

• Who we are

• What data do we collect and why

• Your rights over your personal information

• How to contact us or regulatory authorities if you have a complaint

Who We Are

Primora Trading is a regulated global provider of online trading services, offering access to financial instruments including Forex, CFDs, Indices, Commodities, and Cryptocurrencies. When you engage with our platforms, submit information through our website or mobile apps, or access our services in any form, we are the entity responsible for the collection and processing of your personal data, and we act as a Data Controller under relevant data protection laws.

Regardless of your country of residence, Primora Trading determines the purposes and means of processing your personal data, and we are accountable for ensuring its lawful use.

Do You Need to Provide Your Data?

Yes. In most cases, providing your personal information is necessary for:

• Opening and operating a trading account

• Fulfilling legal and regulatory obligations (e.g., AML, KYC)

• Delivering our services and support

We will always inform you at the point of collection whether the provision of certain information is required or optional.

What Information Do We Collect?

We only collect data that is necessary for the purposes outlined in this policy. Data may be collected directly from you, indirectly through your use of our services, or from authorized third parties.

1. Personal Identification Information:
   • Full name, gender, date of birth

• Nationality and country of residence

• Proof of identification (e.g., passport, driver’s license)

• Address verification documents (e.g., utility bill, bank statement)

2. Contact Details:
   • Email address

• Mobile/landline phone numbers

3. Regulatory Information:
   • National Identification Number, Social Security Number, or other government-issued IDs

• Political exposure and sanctions-related data

4. Financial & Employment Data:
   • Employment status and occupation

• Annual income and net worth

• Source of funds and expected trading volume

• Trading history and experience

5. Technical and Website Usage Data:
   • IP address and geolocation

• Device ID and browser information

• Operating system and connection type

• Website traffic data, activity logs, cookies, and interaction metrics

6. Communication Records:
   • Email and phone correspondence

• Live chat transcripts

• Call recordings for training and compliance

Why We Collect Your Data

We collect and process your personal information for the following purposes:

Legal Obligations              To respond to legal requests and protect the rights of Primora Trading and its users

How We Notify You of Changes

This Privacy Policy is regularly reviewed and may be updated to reflect changes in regulatory requirements, technology, or business practices. If we make material changes, we will notify you via email and/or by publishing an updated version on our website.

Data Sharing, Processors, Security & Transfers

Who We Share Your Information With

We do not rent, sell, or commercially distribute your personal information to third parties for their own marketing purposes. However, to deliver our services effectively and comply with regulatory requirements, we may share your data with the following categories of trusted entities:

1. Affiliated Companies and Service Providers

We may disclose your data to:

• Affiliated companies within the Primora Trading group

• Authorized service providers who help operate our platform, including those offering:

○ Cloud hosting and storage

○ Client onboarding and KYC verification

○ Payment processing and banking infrastructure

○ Marketing support, analytics, and communication services

○ Technical development and cybersecurity

These parties are contractually obligated to process your information only under our instructions, maintain confidentiality, and implement appropriate data protection safeguards.

2. Regulatory and Legal Authorities

We may share your information with:

• Financial regulators and supervisory bodies

• Anti-fraud and anti-money laundering authorities

• Courts or legal enforcement agencies

We only do so when required to comply with applicable laws or to fulfill a lawful request (such as subpoenas or court orders).

3. Business Transfers

In the event of a business sale, merger, acquisition, or restructuring, your personal data may be transferred to the new entity as part of that transaction. The successor entity will be bound by this Privacy Policy or an equivalent data protection standard.

Data Security

We are committed to ensuring that your personal information is stored and processed securely.

Security Measures Include:

• Data encryption during transmission (TLS/SSL protocols)

• Two-factor authentication (2FA) for sensitive account actions

• Continuous threat detection and intrusion prevention systems

• Regular security audits and penetration testing

• Only authorized personnel have access to personal data

• Data anonymization and masking where applicable

All staff and third-party contractors undergo mandatory privacy and security training to ensure strict adherence to our confidentiality obligations.

Incident Response

In the unlikely event of a data breach or unauthorized access, we will:

• Notify affected users as required by law

• Report the incident to data protection regulators

• Take immediate corrective action to limit and investigate the breach

International Data Transfers

Due to the global nature of our services, your data may be processed or stored in countries outside your country of residence or the jurisdiction where the data was originally collected. This includes processing by service providers or affiliated entities in countries with varying data protection standards.

Our Safeguards Include:

• Using countries that are recognized by authorities as having adequate data protection standards

• Implementing Standard Contractual Clauses (SCCs) approved by regulators

• Enforcing data transfer agreements with service providers

• Obtaining explicit user consent where required

We take additional technical and contractual precautions to ensure that cross-border data transfers meet modern security and compliance standards.

Your Rights, Data Retention, Cookies & Contact

Your Rights as a Data Subject

We are committed to protecting your personal data and ensuring transparency and accountability in how it is processed. Under global data protection laws, including the GDPR and related legislation, you are entitled to the following rights:

1. Right to Access

You have the right to request a copy of the personal data we hold about you, along with details of how and why it is being used.

2. Right to Rectification

If your personal data is inaccurate or incomplete, you may request correction or supplementation of that information.

3. Right to Erasure (“Right to be Forgotten”)

You may request that we delete your personal data when:

• It is no longer needed for the purposes it was collected

• You withdraw your consent (where processing is based on consent)

• You object to processing, and there are no overriding legitimate grounds

• Processing was unlawful

Note: We may retain certain information to comply with legal obligations or defend against legal claims.

4. Right to Restrict Processing

You may request that we temporarily limit the use of your personal data under certain conditions, such as pending a correction or in the case of a legal dispute.

5. Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and request that it be transferred to another service provider (where technically feasible).

6. Right to Object

You may object to the processing of your data for:

• Direct marketing purposes

• Processing based on legitimate interest or public interest (unless we have compelling lawful grounds)

7. Right to Withdraw Consent

If we rely on your consent for processing any part of your data, you may withdraw it at any time without affecting the lawfulness of processing carried out before your withdrawal.

8. Right Not to be Subject to Automated Decisions

You have the right not to be subject to decisions based solely on automated processing, including profiling, that significantly affects your legal rights or interests—unless you have given explicit consent or it is necessary for entering a contract.

How to Exercise Your Rights

You may exercise any of the above rights by contacting our Data Protection Officer via:

📧 Email: privacy@primoratrading.com 

📝 Please include:

• Your full name and contact details

• Your account number or client ID (if applicable)

• A clear description of your request

We may request verification documents to confirm your identity before fulfilling your request. Most requests will be processed free of charge within 30 days.

Data Retention

We retain your personal information for only as long as necessary to:

• Fulfill the purposes outlined in this Privacy Policy

• Comply with applicable laws and regulatory obligations (e.g., AML, tax, financial regulations)

• Defend or establish legal claims

• Maintain accurate business and transaction records

Retention Periods:

• Active clients: Data retained for the life of the account + up to 5 years after closure

• Inactive or demo accounts: Up to 2 years after inactivity

• Marketing and analytics data: Retained only as long as necessary or until you opt out

Data may be retained beyond these periods where required by law or with your express consent.

Cookies and Tracking Technologies

When you visit our website or use our platforms, we use cookies and similar technologies to:

• Identify your browser/device

• Customize your experience

• Analyze traffic and usage patterns

• Secure our services and prevent abuse

Types of Cookies We Use:

• Essential Cookies: Necessary for core site functionality

• Analytical Cookies: Help us understand user interaction and improve the platform

• Marketing Cookies: Used for delivering relevant ads and measuring their effectiveness

• Preference Cookies: Store your preferred settings and languages

You can manage your cookie preferences through your browser settings or through the Cookie Consent Tool on our website.

For more information, refer to our full Cookie Policy (link placeholder).

Legal Basis for Processing Your Data

We rely on one or more of the following legal grounds to process your personal information:

• Contractual Necessity – To fulfill our agreement with you and provide services

• Legal Obligation – To meet regulatory and legal requirements

• Legitimate Interests – To maintain and improve our services, prevent fraud, and enhance security

• Consent – For specific cases like marketing communications or certain cookies

We ensure that our legitimate interests do not override your fundamental rights and freedoms.

Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes in:

• Legal and regulatory obligations

• Our data processing practices

• Technologies or business models

We will notify users of any material changes via email or on our website. The latest version will always be available on our website, with the “Last Updated” date clearly stated.

How to Contact Us

If you have any questions about this Privacy Policy or would like to file a complaint, you may contact us at:

📧 Email: privacy@primoratrading.com

 📍 Head Office: The Panama City, North Village, UK

 🕒 Support Hours: 24/5 (Monday to Friday)

If you are unsatisfied with our response, you also have the right to file a complaint with your local Data Protection Authority.