Privacy Policy

2.1 Identity Data

• Full Name — As it appears on your government-issued identification.
• Date of Birth — To verify your age and identity.
• Government-issued Identification — Passport, national ID card, driver's licence, or other official ID. This is collected as part of our Know-Your-Customer (KYC) process.
• Photographic Verification — A live selfie or photo for identity verification purposes.
• Gender — Optional, used for anonymised demographic analysis.

2.2 Contact Data

• Email Address — Primary communication channel for account notifications, security alerts, and updates.
• Phone Number — For account security (two-factor authentication) and urgent communication.
• Residential Address — For verification and regulatory compliance.

2.3 Financial Data

• Bank Account Details — For processing payouts and verifying funding sources.
• Payment Information — Transaction history, funding sources, and payout records.
• Investment Profile — Membership tier, investment amounts, and portfolio performance.
• Source of Funds — Information about the origin of funds deposited into your account, as required by anti-money laundering regulations.

2.4 Technical Data

• IP Address — Used for security, fraud prevention, and geolocation.
• Browser Type and Version — To ensure compatibility and optimise performance.
• Operating System — To support your device and troubleshoot issues.
• Device Information — Type, model, and unique device identifiers.
• Referral Source — The website or link that directed you to our Platform.

2.5 Usage Data

• Pages Visited — Which pages and features you access on our Platform.
• Session Duration — How long you spend on our Platform.
• Login Activity — Times and dates of logins, including failed login attempts.
• Interaction Data — Clicks, scrolling behaviour, and interactions with specific features.
• Referral Activity — Information about referrals you have made and commissions earned.

2.6 Special Category Data

We do not collect special category data (sensitive personal information) such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data for identification purposes, health data, or data concerning sexual orientation. We do not intentionally collect or process any such information.

3.1 To Provide and Manage Your Account

• Creating and maintaining your account profile.
• Processing your membership tier activation and upgrades.
• Managing your referrals and calculating commissions.
• Personalising your dashboard and platform experience.
• Providing customer support and responding to your inquiries.

Legal basis: Performance of a contract (our Terms & Conditions).

3.2 To Verify Your Identity and Prevent Fraud

• Conducting KYC verification as required by law.
• Detecting and preventing fraud, money laundering, and unauthorised access.
• Verifying the source of funds to comply with anti-money laundering regulations.
• Monitoring account activity for suspicious transactions.
• Enforcing compliance with our AML Policy and legal obligations.

Legal basis: Legal obligation and legitimate interest (fraud prevention).

3.3 To Process Transactions

• Processing funding transactions to credit your account.
• Processing payout requests to disburse funds to your designated wallet.
• Calculating and applying referral bonuses and other rewards.
• Maintaining transaction records for audit and reconciliation.
• Resolving transaction disputes and investigating errors.

Legal basis: Performance of a contract and legal obligation.

3.4 To Communicate With You

• Sending account notifications — such as login alerts, KYC updates, and transaction confirmations.
• Providing security alerts — such as suspicious activity notifications.
• Sending policy updates — such as changes to our Terms, Privacy Policy, or AML Policy.
• Sending marketing communications — such as program updates and market insights (only with your consent).
• Responding to your inquiries and support requests.

Legal basis: Performance of a contract (account notifications), legitimate interest (security alerts, policy updates), and consent (marketing communications).

3.5 To Improve Our Services

• Analysing usage patterns to understand how users interact with our Platform.
• Identifying and fixing bugs to improve performance and reliability.
• Developing new features based on user feedback and behaviour.
• Conducting research and analysis to inform our strategic decisions.
• Measuring the effectiveness of our marketing and outreach efforts.

Legal basis: Legitimate interest (improving our services). We anonymise data wherever possible for these purposes.

3.6 To Comply With Legal and Regulatory Obligations

• Maintaining records as required by financial services regulations.
• Responding to lawful requests from government authorities and regulators.
• Reporting suspicious activity to relevant authorities as required by anti-money laundering legislation.
• Complying with court orders and legal processes.
• Meeting tax reporting obligations as applicable.

Legal basis: Legal obligation.

4.1 Service Providers

• Identity verification providers — To verify your identity during KYC.
• Payment processors — To process funding and payout transactions.
• Hosting and infrastructure providers — To operate and maintain our Platform.
• Email delivery providers — To send you notifications and communications.
• Analytics providers — To help us understand how users interact with our Platform.
• Customer support providers — To assist in responding to your inquiries.

All service providers are contractually obligated to protect your information and use it only for the specific purposes we specify. They are prohibited from using your data for any other purpose or sharing it with third parties without our explicit authorisation.

4.2 Regulatory and Government Authorities

• Financial services regulators — Where required by law or regulation.
• Law enforcement agencies — In response to a valid legal request, such as a court order or warrant.
• Anti-money laundering authorities — For reporting suspicious activity.
• Tax authorities — Where required for tax reporting purposes.

We will only disclose information to regulatory and government authorities when we are legally compelled to do so or when we believe in good faith that disclosure is necessary to prevent harm, fraud, or illegal activity.

4.3 Professional Advisers

• Legal counsel — To obtain legal advice and protect our rights.
• Auditors — For financial and compliance audits.
• Accountants — For financial reporting and tax compliance.

Our professional advisers are bound by professional obligations of confidentiality.

4.4 Business Transfers

In the event of a merger, acquisition, sale of assets, or other business transfer, your personal information may be transferred to the new entity. We will notify you of such a transfer and provide you with the opportunity to review the new entity's privacy practices before your data is transferred.

4.5 With Your Consent

We may disclose your information to other third parties where you have provided your explicit consent. For example, if you choose to share your referral link publicly or participate in a promotional campaign, certain information may be visible to other users.

7.1 Right to Access

You have the right to request a copy of the personal information we hold about you. This is called a Subject Access Request. We will provide you with a copy of your data in a structured, commonly used, and machine-readable format, free of charge, unless the request is manifestly unfounded or excessive.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. We will promptly update your data upon verification of the correct information.

7.3 Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal information where:

• The data is no longer necessary for the purpose for which it was collected.
• You withdraw your consent and no other legal basis applies.
• You object to processing and there are no overriding legitimate interests.
• The data has been unlawfully processed.
• Deletion is required by law.

Important: We may not be able to delete certain data where it is necessary to comply with legal obligations (such as AML record-keeping) or to establish, exercise, or defend legal claims.

7.4 Right to Restrict Processing

You have the right to restrict our processing of your data where:

• You contest the accuracy of the data.
• The processing is unlawful but you oppose deletion.
• We no longer need the data but you require it for legal claims.
• You object to processing and we are verifying our legitimate interests.

7.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another data controller without hindrance, where technically feasible.

7.6 Right to Object

You have the right to object to our processing of your data where we rely on legitimate interests as the legal basis. If you object, we will stop processing your data unless we can demonstrate compelling legitimate grounds that override your rights and interests.

7.7 Right to Withdraw Consent

Where we rely on your consent to process data (such as for marketing communications), you have the right to withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

7.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the relevant data protection authority if you believe your rights have been infringed. In the United Kingdom, this is the Information Commissioner's Office (ICO). In Nigeria, this is the Nigeria Data Protection Commission (NDPC).

AlphaEdge Partners Limited
Suite 1416, 61 Bridge Street, Kington, HR5 3DJ, United Kingdom
Email: privacy@alphaedgepartners.com
Phone: +44 7886 904315
Data Protection Officer: dpo@alphaedgepartners.com