Privacy Policy

Last updated: January 2025

1. Introduction

Paladium Strategy (“we,” “us,” or “our”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, and share your personal information when you use our trading platform and services, in compliance with the UK General Data Protection Regulation (UK-GDPR) and other applicable UK data protection laws.

By using our services, you consent to the collection and use of your information as described in this Privacy Policy.

2. Information We Collect

2.1 Personal Information

We collect the following types of personal information:

Identity Data: First name, last name, date of birth, nationality
Contact Data: Email address, phone number, postal address
Financial Data: Bank account details, payment card information, trading history
Identity Verification: Passport, driving license, utility bills for KYC compliance
Professional Data: Employment information, income details, trading experience

2.2 Technical Information

IP address, browser type and version, device information
Platform usage data, trading activities, session information
Cookies and similar tracking technologies
Communication records (emails, chat logs, phone calls)

3. How We Use Your Information

3.1 Lawful Basis for Processing

We process your personal data based on the following lawful bases:

Contract Performance: To provide trading services and fulfill our obligations to you
Legal Compliance: To comply with UK financial regulations, KYC, and AML requirements
Legitimate Interests: To improve our services, prevent fraud, and ensure platform security
Consent: For marketing communications and non-essential cookies

3.2 Specific Uses

Account registration and identity verification
Processing trading transactions and managing your account
Providing customer support and responding to inquiries
Sending important account notifications and platform updates
Compliance with regulatory reporting requirements
Risk management and fraud prevention
Platform improvement and analytics

4. Data Sharing and Third Parties

4.1 Licensed Trading Providers

Important: By using our services, you consent to us sharing your personal data with licensed third-party trading
providers and brokers who facilitate your trading activities. This sharing is essential for:

Account setup and management with trading platforms
Trade execution and settlement
Compliance with regulatory requirements
Customer support and account servicing

4.2 Other Third-Party Services

We may also share your data with:

Payment Processors: For deposit and withdrawal processing
Identity Verification Services: For KYC and AML compliance
Technology Providers: For platform hosting and maintenance
Legal and Professional Advisors: When required for compliance or legal matters
Regulatory Authorities: When legally required or requested

5. Cookies and Tracking

5.1 Types of Cookies

Essential Cookies: Required for platform functionality and security
Performance Cookies: Help us understand how visitors use our site
Functional Cookies: Remember your preferences and settings
Marketing Cookies: Used to deliver relevant advertisements (with consent)

5.2 Google Analytics

We use Google Analytics to analyze website usage and improve our services. Google Analytics collects information about your interaction with our site, including pages visited, time spent, and user behavior patterns.

You can control cookie preferences through our cookie consent banner or by adjusting your browser settings.

6. Data Security and Retention

6.1 Security Measures

We implement appropriate technical and organizational measures to protect your data:

256-bit SSL encryption for data transmission
Secure data centers with restricted access controls
Regular security audits and penetration testing
Employee training on data protection and privacy
Multi-factor authentication for account access

6.2 Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations:

Account Data: 7 years after account closure (regulatory requirement)
Transaction Records: 7 years from transaction date
Communication Records: 7 years from last contact
Marketing Data: Until consent is withdrawn

7. Your Rights Under UK-GDPR

As a UK resident, you have the following rights regarding your personal data:

Right of Access: Request a copy of your personal data
Right to Rectification: Correct inaccurate or incomplete data
Right to Erasure: Request deletion of your data (subject to legal obligations)
Right to Restrict Processing: Limit how we process your data
Right to Data Portability: Receive your data in a portable format
Right to Object: Object to processing based on legitimate interests
Right to Withdraw Consent: Withdraw consent for marketing or cookies

To exercise any of these rights, please contact us at privacy@paladiumstrategy.com or use the contact details provided below.

8. International Data Transfers

Some of our service providers may be located outside the UK. When we transfer your data internationally, we ensure appropriate safeguards are in place, such as:

Adequacy decisions by the UK government
Standard Contractual Clauses approved by UK authorities
Binding Corporate Rules for multinational organizations
Certification schemes recognized under UK-GDPR

9. Marketing Communications

With your consent, we may send you marketing communications about our services, trading opportunities, and platform updates. You can opt out at any time by:

Clicking the unsubscribe link in marketing emails
Updating your preferences in your account settings
Contacting our support team directly

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of significant changes by email or through our platform. Your continued use of our services after such changes constitutes acceptance of the updated policy.

11. Contact Information

If you have any questions about this Privacy Policy or our data processing practices, please contact us:

Data Protection Officer

Email: privacy@paladiumstrategy.com

Phone: +44 20 7946 0958

Address: 25 Canada Square, Canary Wharf, London E14 5LQ, UK

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s data protection authority, if you believe we have not handled your personal data properly.