Privacy Policy

Last updated: November 2025

When you use our services, we process personal data about you ("you", "your", or the "Customer"). This Privacy Policy (the "Policy") explains how and why we process your data, as well as the rights you have.

In this Policy, you will find information about:

  1. Who is the data controller and how to contact us
  2. What information we collect about you and how we obtain it
  3. How and on what legal basis we use your personal data
  4. How we store and secure your data
  5. How long we retain your data
  6. With whom we share your data and international transfers
  7. Your rights under Swiss law and GDPR
  8. Changes to this Policy

1. Data Controller and Contact Details

The data controller for your personal data is:

Swiss Trade Funding
Based in Switzerland ("Swiss Trade Funding", "we", "our", or "us").

We determine the purposes and means of processing your personal data in connection with:

For any questions regarding this Policy or to exercise your data protection rights, you can contact us at:

📧 contact@swisstradefunding.com

2. Data We Collect and How We Obtain It

We collect only personal data that is necessary and proportionate to the purposes described below.

2.1 Data You Provide Directly

When you:

  • create an account on our Site,
  • purchase an evaluation/challenge,
  • participate in our programs,
  • contact our support,
  • request a profit sharing payment,

we may process the following:

  • Identification data: first name, last name, date of birth, nationality, country of residence;
  • Contact data: email address, telephone number, postal address;
  • Account data: username, password, account settings, preferred language;
  • Payment and payout data: billing information, partial credit card information (via payment processors), bank details or wallet addresses for payouts (IBAN, wallet address or other payment method), transaction identifiers;
  • Verification data (KYC/AML): copy of ID document, proof of address, verification selfie or video, any additional documents reasonably required to comply with our anti-money laundering and counter-terrorism financing obligations;
  • Communication data: messages sent via email, chat, ticket, social media, as well as notes necessary to process your requests.

The provision of certain data is mandatory to enter into or perform a contract with us (e.g., to create an account, purchase a service, or receive a payment). Otherwise, we may not be able to provide the requested Service.

2.2 Data Collected Automatically

When you access our Site or Services, we may automatically collect:

  • Technical and device data: IP address, device type, operating system, browser type and version, approximate location (country/region), language settings, time zone, internet service provider;
  • Site usage data: date and time of visits, pages viewed, clicks, time spent on pages, interactions with forms and buttons, referring URL;
  • Login and activity data: timestamps of logins and logouts, account settings changes, password reset requests.

This information is collected through:

  • server logs,
  • cookies and similar technologies (see our Cookie Policy),
  • analytics tools.

2.3 Data Received from Third Parties

We may receive data about you from:

  • Trading platform providers (e.g., MetaTrader, cTrader, or other third-party platforms you connect): data related to your simulated trades and performance, such as instrument, opening/closing time, position size, profit/loss, balance and equity, risk indicators, etc.;
  • Payment service providers and financial institutions: payment confirmation, partial card information, transaction status, anti-fraud checks;
  • Identity verification (KYC) and fraud prevention providers: verification status, check results, risk assessment elements;
  • Marketing and analytics partners, if you have consented (e.g., campaign or traffic source information);
  • Social networks, if you choose to connect your account (e.g., limited profile data: name, email, profile photo, social ID).

These third parties act either:

  • as processors (they process data on our behalf), or
  • as separate controllers (when they use data for their own purposes – in which case, their own privacy policies apply).

3. How and On What Legal Basis We Use Your Data

We process your personal data only when we have a legal basis under:

  • Swiss data protection law (FADP), and
  • where applicable, the General Data Protection Regulation (GDPR).

3.1 Registration and User Account Management

Purpose:

  • create and manage your user account,
  • allow you to log in, access your programs, and manage your profile.

Data: Identification data, contact data, account data.

Legal basis:

  • Contract performance (Art. 6(1)(b) GDPR) / pre-contractual measures at your request.

3.2 Provision of Services (Evaluations, Challenges, Simulated Accounts)

Purpose:

  • provide you with access to our evaluation programs and simulated trading environment,
  • process your (simulated only) trading data,
  • track your progress and determine if you meet evaluation criteria,
  • manage the contractual relationship (support, dashboard, notifications).

Data: Identification and contact data, account data, simulated trading data, usage data, payment/payout data (if applicable).

Legal basis:

  • Contract performance and
  • legitimate interest (Art. 6(1)(f) GDPR) in operating, monitoring, and improving our Services, and verifying compliance with our Terms and Conditions and trading rules.

3.3 Payments, Payouts, and Accounting Obligations

Purpose:

  • process evaluation fees,
  • process profit sharing payments (if applicable),
  • maintain accounting and tax records required by law.

Data: Identification and contact data, payment and payout data, transaction history.

Legal basis:

  • Contract performance,
  • legal obligation under Swiss and, where applicable, foreign (accounting, tax, financial) regulations.

3.4 Identity Verification, AML/CTF, and Fraud Prevention

Purpose:

  • verify your identity (KYC),
  • prevent fraud, abuse, multi-accounting, and prohibited behavior,
  • comply with anti-money laundering and counter-terrorism financing obligations, and sanctions regimes,
  • enforce our Terms and Conditions and protect our business and users.

Data: Identification data, verification documents, device/usage data, transaction history, simulated trading patterns, data from verification and fraud prevention providers.

Legal basis:

  • Legal obligation (where AML/CTF or sanctions rules apply),
  • legitimate interest in ensuring the security and integrity of our platform and protecting our rights.

3.5 Customer Support and Communication

Purpose:

  • respond to your requests, questions, or complaints,
  • provide technical assistance,
  • inform you about your account, programs, payments, violations, security incidents, and important updates.

Data: Identification and contact data, communication data, relevant account/trading data.

Legal basis:

  • Contract performance and
  • legitimate interest in ensuring customer satisfaction and quality of our Services.

3.6 Marketing and Newsletters

Purpose:

  • send you information about our services, new features, promotions, webinars, or events.

Data: Identification and contact data, limited usage data for potential segmentation.

Legal basis:

  • Legitimate interest (for existing customers, in compliance with e-privacy rules) and/or
  • Consent, where required by law or when you voluntarily subscribe.

You can unsubscribe at any time:

3.7 Analytics, Service Improvement, and Security

Purpose:

  • analyze Site and Services usage,
  • detect bugs, monitor performance and security,
  • develop and improve features, user experience, and risk management models.

Data: Device data, usage data, aggregated simulated trading data, cookie/analytics data.

Legal basis:

  • Legitimate interest in improving and securing our Services.

Where possible, we use aggregated or anonymized data that does not directly identify you.

4. Data Storage and Security

We store your personal data in secure systems and databases, located primarily in Switzerland or the EU/EEA, or with providers offering an adequate level of protection.

We implement appropriate technical and organizational measures, including:

  • encryption of data in transit (TLS/HTTPS) and, where necessary, at rest,
  • access controls and role-based permissions,
  • strong password policies and, where appropriate, two-factor authentication,
  • secure development and logging procedures,
  • regular security reviews and monitoring of suspicious activity,
  • contracts with our processors requiring them to ensure an appropriate level of security.

No system is completely invulnerable, but we strive to maintain a level of security consistent with industry best practices.

5. Data Retention Period

We retain your personal data only for as long as necessary for the purposes described above or as required by law.

As a guideline:

  • Account and contractual data: during the contractual relationship, then generally up to 10 years after the end of the last contract, to comply with our accounting, tax obligations and to defend our rights in court.
  • Payment and payout data: for the period required by tax and financial regulations (generally 5 to 10 years).
  • KYC/AML data: for the period required by applicable anti-money laundering laws (often 5 to 10 years after the end of the business relationship).
  • Support data: for the time necessary to process your request then a few years to protect our rights.
  • Marketing data: until you withdraw your consent or object to this processing and, in any case, no longer than necessary (e.g., 3 to 5 years after your last interaction).
  • Analytics and logs: generally between 6 and 24 months, then aggregated or anonymized.

When data is no longer necessary, we securely delete it or irreversibly anonymize it.

6. Data Sharing and International Transfers

6.1 Processors and Recipients

We may share your personal data with third parties who help us provide and operate the Services, including:

  • Trading platform providers (for simulated trading only);
  • Hosting and cloud infrastructure providers;
  • Payment service providers and financial institutions;
  • Identity verification (KYC) and fraud prevention providers;
  • Customer support and communication tools;
  • Email and marketing providers (for transactional emails and newsletters);
  • Analytics and monitoring providers;
  • Professional advisors (lawyers, auditors), when necessary.

These entities act primarily as processors and are contractually obligated to:

  • process data only on our instructions,
  • implement appropriate security measures,
  • respect confidentiality and applicable legislation.

We may also disclose data:

  • when required by law, regulation, or decision of a competent authority,
  • to enforce our Terms and Conditions, protect our rights, property, or the safety of our users,
  • in connection with a reorganization, merger, or sale of our business (with adequate safeguards and prior notice).

We do not sell your personal data.

6.2 International Transfers

Some processors or recipients may be located outside Switzerland or the EU/EEA ("third countries").

In this case, we ensure that:

  • the country offers a recognized adequate level of protection, or
  • appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, accompanied, if necessary, by additional technical and contractual measures.

You can obtain more information about these transfers and the safeguards implemented by contacting us at contact@swisstradefunding.com.

7. Your Rights

Subject to applicable law (FADP, GDPR), you have the following rights regarding your personal data:

7.1 Right of Access

You can request:

  • confirmation whether or not we process your data, and
  • a copy of it, along with information about the processing.

7.2 Right of Rectification

You can ask us to correct inaccurate or incomplete personal data. You can also update certain information directly in your account settings.

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

You can request the deletion of your personal data particularly when:

  • the data is no longer necessary for the purposes for which it was collected,
  • you withdraw your consent (where processing is based on consent),
  • you object to processing and there are no overriding legitimate grounds,
  • the data has been unlawfully processed.

However, we cannot delete your data when its retention is required by law (e.g., accounting, AML) or necessary for the establishment, exercise, or defense of legal claims.

7.4 Right to Restriction of Processing

In certain cases (e.g., when you contest the accuracy of data, object to processing, or consider processing unlawful), you can request temporary restriction of processing of your data.

7.5 Right to Data Portability

Where processing is based on your consent or contract performance and carried out by automated means, you can request:

  • to receive your data in a structured, commonly used, and machine-readable format, and
  • to have this data transmitted to another controller, where technically feasible.

7.6 Right to Object

You can object at any time:

  • to processing based on our legitimate interest, for reasons relating to your particular situation;
  • to processing of your data for direct marketing purposes – in which case we will cease this processing without delay.

7.7 Right to Withdraw Consent

Where we rely on your consent, you can withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.

7.8 Right Not to be Subject to Automated Individual Decision-Making

As a general rule, we do not make decisions producing legal effects concerning you or significantly affecting you based solely on automated processing, including profiling. If such processes were to be introduced, we would inform you and respect the safeguards provided by law.

7.9 Right to Lodge a Complaint

If you believe that we process your data in violation of applicable laws, you have the right to lodge a complaint with:

  • the Federal Data Protection and Information Commissioner (FDPIC) in Switzerland, and/or
  • if you reside in the EU/EEA, with your local supervisory authority.

How to Exercise Your Rights?

You can exercise your rights by contacting us at:

📧 contact@swisstradefunding.com

Please provide sufficient information to identify you (and, if necessary, allow us to verify your identity) and specify the right you wish to exercise. We will respond in accordance with applicable law, generally within one month.

8. Cookies and Similar Technologies

We use cookies and similar technologies to:

  • ensure proper functioning of the Site,
  • remember your preferences,
  • perform analytics and improve our Services,
  • in some cases, for marketing purposes.

Details about the types of cookies used and how to manage your preferences are set out in our Cookie Policy, which forms an integral part of this Policy.

9. Children's Data

Our Services are not intended for persons under 18 years of age. We do not knowingly collect personal data from persons under 18. If we learn that a minor has provided us with data, we will take necessary steps to delete this data and, if applicable, close the associated account.

10. Changes to This Policy

We may update this Policy from time to time, for example:

  • due to legislative changes,
  • in case of changes to our Services or internal processes.

We will publish the new version on our Site and update the "Last updated" date at the top of the document. In case of significant changes, we may also inform you by email or through your account.

Your continued use of the Services after the new Policy comes into effect will constitute acceptance of these changes.

11. Contact

For any questions, concerns, or requests regarding this Privacy Policy or our processing of your personal data, please contact:

Swiss Trade Funding – Data Protection Officer / Privacy Contact
📧 contact@swisstradefunding.com