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Legal Documentation

Privacy Policy Your Data Protection

Understanding how we collect, use, and protect your personal information

1

Our Commitment

RoyaHarborTrust is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

We understand the importance of maintaining the confidentiality and security of your personal information. By accessing and using our website and services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy.

This policy applies to all personal data collected through our website, trading platforms, mobile applications, and any other channels through which you interact with us.

2

Data We Collect

We may collect and process the following categories of personal data:

Identity & Contact Information

  • Full name, date of birth, nationality, and country of residence
  • Email address, telephone number, and postal address
  • Government-issued identification documents (passport, national ID, driver's licence)
  • Proof of address documentation (utility bills, bank statements)

Financial Information

  • Bank account details and payment information
  • Source of funds and wealth declarations
  • Trading history, account balances, and transaction records
  • Employment status and annual income information

Technical & Usage Data

  • IP address, browser type and version, operating system
  • Pages visited, time spent on our website, and navigation patterns
  • Device identifiers and login credentials
  • Communication records (emails, support tickets, chat logs)
3

Use of Personal Data

We use the personal data we collect for the following purposes:

  • Account Management: To create, maintain, and manage your trading account, verify your identity, and process your applications
  • Service Delivery: To provide you with our trading services, execute transactions, and process deposits and withdrawals
  • Regulatory Compliance: To comply with our legal and regulatory obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements
  • Risk Management: To assess and manage financial risk, monitor trading activity, and detect potentially fraudulent or suspicious transactions
  • Communications: To send you important account notifications, service updates, regulatory disclosures, and marketing communications (where consented)
  • Platform Improvement: To improve our website, trading platforms, and services based on usage analysis and feedback
  • Customer Support: To respond to your enquiries, resolve complaints, and provide technical assistance
4

Data Sharing & Disclosure

We do not sell your personal data to third parties. We may share your data only in the following circumstances:

  • Regulatory Authorities: Where required by law, regulation, or court order, we may disclose personal data to regulatory bodies, law enforcement agencies, or other governmental authorities
  • Service Providers: We may share data with trusted third-party service providers who assist us in operating our platform, such as payment processors, identity verification providers, and IT service providers
  • Affiliated Companies: We may share data within our group of affiliated companies for the purposes outlined in this policy
  • Professional Advisors: We may share data with our auditors, legal counsel, or other professional advisors as necessary

All third parties with whom we share data are contractually obligated to protect the confidentiality and security of your personal information.

5

Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse website traffic, and understand where our visitors are coming from.

Essential Cookies

Required for the basic functionality of our website and trading platform. These cannot be disabled.

Analytical Cookies

Help us understand how visitors interact with our website by collecting and reporting information anonymously.

Functional Cookies

Enable enhanced functionality and personalisation, such as remembering your preferences and settings.

Marketing Cookies

Used to track visitors across websites to display relevant advertisements. You may opt out of these at any time.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

6

Security & Protection

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction, in compliance with applicable laws and regulations for the protection of personal data.

Our security measures include:

  • SSL/TLS encryption for all data transmitted between your browser and our servers
  • Multi-factor authentication for account access
  • Regular security audits and vulnerability assessments
  • Strict access controls and employee training on data protection
  • Segregated client data storage with encryption at rest

While we strive to use commercially acceptable means to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7

Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements.

In determining the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process it, and applicable legal requirements. As a regulated financial services provider, we are required to retain certain records for a minimum of five (5) years following the termination of the business relationship.

When your personal data is no longer required, we will securely delete or anonymise it in accordance with our data retention procedures.

8

Your Rights

In compliance with applicable data protection laws and regulations, you have the following rights regarding your personal data:

Right of Access

Request a copy of the personal data we hold about you

Right to Rectification

Request correction of inaccurate or incomplete personal data

Right to Erasure

Request deletion of your personal data, subject to legal obligations

Right to Restrict Processing

Request limitation of processing of your personal data

Right to Data Portability

Request transfer of your data in a structured, machine-readable format

Right to Object

Object to processing of your data, including direct marketing

To exercise any of these rights, please contact our compliance team at compliance@royalharbortrust.com. We will respond to your request within 30 days.

10

Changes to This Policy

We reserve the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically to stay informed about how we protect your personal data.

Material changes to this policy will be communicated to you via email or through a prominent notice on our website prior to the changes taking effect.

11

Contact & Queries

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way we handle your personal data, please contact our Compliance Department:

152 Franklin Roosevelt Avenue, Limassol 3045, Cyprus

We will investigate and attempt to resolve all complaints and disputes regarding the use of personal data in accordance with this Privacy Policy.