Privacy policy

Mach D Trading Ltd Privacy Policy

Mach D Trading Ltd ("we," "us," "our") is committed to protecting the privacy of users who engage with our services. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information. Regarding the terms used in this Privacy Notice, such as “Processing” or “Controller”, we refer to the definitions of the UK GDPR.

1. Data Collection

We process the personal data that we receive from you within the scope of the business relationship and your usage of our Website. The party responsible for data processing on this website and related sites is:

Mach D Trading Ltd

Represented by Managing Director: Gerald Lee

For questions regarding the handling of your personal data, you can contact our User Support at support@machdtrading.com.

1.1. How we collect data

Your data is collected by communicating it to us by means of:

  • Creating a user account

  • Participating in user surveys

  • Contacting our user support

  • Interacting with our social media channels

1.2. Type of data we collect

We may collect personal information, including but not limited to:

  • Contact and general account creation data: when creating a new user account or communicating with Mach D Trading Ltd, we might process for example: name, address, telephone number, email, date of birth, photo for the account, etc.;

  • Investment Preferences and Behaviours: Information related to your investment experience, trading behaviours, and preferences.

  • Personal data provided by you in requests to our Support or other employees;

  • Research data: if you, inter alia, participate in any surveys, user tests, panels, etc. provided by Mach D Trading Ltd or take part in one of our research initiatives and provide data via forms (which you might receive separate information about if you voluntarily agree to participate);

  • Marketing data: if you visit our website or social media sites or during the usage of the Website App, we might process statistical and marketing data for example: the number of visitors, frequency, clicks, time, places, target groups, data from cookies and similar technologies, consumer’s behaviour, interests and preferences, data about market research and target groups surveys, etc.

  • Log data on the website: e.g.: IP address, transaction data, deposit and withdrawal address, computer or mobile device information, frequency, time, operating system, browser type, device type, unique device identification number, identification cookies, optionally form data, crash reports, performance data, third-party cookies, etc.;

  • Demographic Information: Age, gender, education level, occupation.

1.3. Automated Data Collection

Other data is collected automatically when accessing our website for technical reasons by our IT systems. These are mainly technical data (e.g., IP address, Internet browser, operating system, or time of the page call). This data is collected automatically as soon as you enter our website, anonymised and stored separately from other data that you may transmit to us for only 90 days.

In this case, the processing takes place on the basis of our predominantly legitimate interests mentioned above (Art. 6 Para. 1 lit.f UK GDPR).

1.4. Purpose and legal basis for collecting and processing personal data

All processing is performed in accordance with applicable data protection legislation. This includes, inter alia, the UK General Data Protection Regulation (UK GDPR), the E-Privacy Directive and the national implementing acts (UK GDPR). We process your personal data:

For the performance of contractual obligations (Art 6 para 1 lit b UK GDPR): Processing of personal data might be necessary for the performance of the contract with you or in order to take steps at your request prior to entering into a contract. The following data processing operations, for example, are covered by such contractual obligations:

  • General performance of our services, all tasks necessary for the operation, performance and administration of Mach D Trading Ltd and its platform;

  • Account management (e.g. continuous updating of Client data);

  • Client service and support request;

To protect legitimate interests (Art 6 para 1 lit f UK GDPR):

Where necessary, data processing might take place beyond the performance of the contract in order to maintain the legitimate interests of Mach D Trading Ltd or a third party. The following data processing operations are covered by such a legitimate interest:

  • Prevention of fraud, misuse (e.g. for illegal purposes), money laundering and terrorist financing;

  • Processing inquiries from authorities, lawyers, and collection agencies in the course of legal prosecution and enforcement of legal claims in the context of legal proceedings;

  • Risk management and risk minimisation;

  • Account management and handling general Client requests and inquiries;

  • Testing and optimisation of procedures and models for analysing requirements, business management, product development and direct customer engagement;

  • Process and quality management measures;

  • Analysis and improvement of the platform's quality and the general user experience (e.g. performance tracking on the platform);

  • Market research, business management and continuing development of services and products;

  • Processing statistical data, performance data and market research data via the website or social media platforms;

  • Identification and examination of potentially defective or suspicious business cases and accesses to our websites (e.g. website analysis);

  • Data security and IT security on our website and safeguarding our network (e.g. prevention of identity theft and defective or suspicious accesses to our websites).

  • For compliance with legal obligations (Art 6 para 1 lit c GDPR): Processing of personal data might also be necessary for complying with various legal obligations (e.g. AMLD). The following data processing operations, for example, are covered by such legal obligations:

  • Contract management, accounting and invoicing;

  • Compliance and risk management;

  • Monitoring for prevention of fraud, misuse (e.g. for illegal purposes), money laundering and terrorist financing;

  • Providing information to fiscal criminal authorities in the context of fiscal criminal proceedings or to prosecution in accordance with official orders;

Based on your consent (Art 6 para 1 lit a GDPR): If you have given us your consent to process your personal data, processing will only take place in accordance with the defined purposes and to the extent agreed in the declaration of consent. Given consent may be withdrawn at any time without giving reasons and with future effect, if you no longer agree to the processing. For example, with your consent we are processing data for the following purposes:

  • For the use of all functions of the website

  • Direct marketing and advertising (e.g. Client satisfaction surveys, newsletters, sweepstakes and other advertising communications);

  • Website analysis and tracking for advertising purposes

Please note that the withdrawal of the consent does not affect the lawfulness of processing based on consent before its withdrawal.

1.5. How We Share Your Information

We never sell or share your personal information with third parties without your explicit consent, and with your consent, we limit the recipients to:

  • Data transfer to processors: To a limited extent, we also transmit personal information to Processors. Such include, inter alia, service providers for video authentication services, IT services, Client support, improvement of our website, monitoring of defective business cases, and application management. Processors may only use or disclose this data to the extent necessary to perform services for us or to comply with legal requirements. We contractually oblige these Processors to ensure the confidentiality and security of your personal data that they process on our behalf.

  • Data transfer to public bodies and institutions: We might also transfer your personal data might be disclosed to public bodies and institutions (i) if we are required to do so by law or in the context of legal proceedings, (ii) if we believe that disclosure is necessary to prevent damages or financial loss, or (iii) in connection with an investigation into suspected or actual fraudulent or illegal activities.

We may share aggregated or anonymised data with trusted partners for research and analysis.

2. Retention period

If no special storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies, between 3 to 4 years. If you make a subject request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (for example, retention periods under tax or commercial law); in the latter case, the deletion takes place after these reasons have ceased.

Personal data would include, but not limited to, the following:

  • Email address

  • Age

  • Occupation

  • Name

3. Minors

The products and services of Mach D Trading Ltd are not directed to people under the age of 18 years. Only persons of legal age are permitted to use the services of Mach D Trading Ltd and register for an account. Therefore, we are not knowingly collecting personal data from minors. So, if you are under the age of 18 years, please do not use Mach D Trading Ltd's platform and do not provide us with any personal data.

4. Web hosting
Our platform is hosted on Hostinger, a globally recognized web hosting service. Hostinger provides us with the online platform that allows us to collect your responses. All data you provide may be stored through Hostinger's data storage, databases, and general Hostinger applications. They ensure that all information stored on their platform is treated as strictly confidential and is stored securely.

Hostinger is committed to data privacy and has implemented robust measures to protect your personal information. They offer HTTPS secure access to most areas on their services and have implemented security measures designed to protect the personal information shared with them, including physical, electronic, and procedural measures. For a comprehensive understanding of how Hostinger handles and protects your data, we recommend reviewing their Privacy Policy.

The use of Hostinger is based on Article 6, paragraph 1 lit. f GDPR. We have a legitimate interest in ensuring the most reliable presentation of our website. If a corresponding consent has been requested, the processing takes place exclusively on the basis of Article 6 Paragraph 1 lit. a GDPR; the consent is revocable at any time.

5. International data transfers:

Mach D Trading Ltd will process your personal data in general within the European Economic Area. In some circumstances, it might be the case that it is processed also outside the European Economic Area. If this is the case, we will rely on appropriate data transfer mechanisms according to Art 44 et seq GDPR. This might be, inter alia:

  • an adequacy decision by the European Commission;

  • standard contractual clauses as published by the European Commission;

  • binding corporate rules.

Regardless of where your personal data is processed, it will be processed in accordance with the provisions in the Privacy Notice.

6. Rights of data subjects

6.1. Right to information

As a Data Subject, you have the right to request information from us at any time about the personal data processed by us in the scope and under the conditions of Art. 15 GDPR. To do this, you can submit your request to support@machdtrading.com.

6.2. Revocation of consent to data processing

Many data processing operations are only possible with your express consent. You can revoke your consent at any time. The legality of the data processing carried out before the revocation remains unaffected by the revocation.

6.3. Right to rectification and erasure

As a Data Subject, you have the right to request Mach D Trading Ltd for the immediate correction of your personal data if it is incorrect. You also have the right to request the erasure of your data in the scope and under the conditions of Art. 17 UK GDPR.

6.4. Right to object (Article 21 UK GDPR)

Suppose the data processing is based on Article 6 para 1 lit. e or f UK GDPR, you have the right at any time to object to the processing of your personal data for reasons arising from your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process your personal data unless we can demonstrate compelling, legitimate reasons for the processing that are your interests, Rights and freedoms predominate or the processing serves to assert, exercise or defend legal claims (objection pursuant to Article 21 paragraph 1 UK GDPR).

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling, as far as it is connected with such direct advertising.

If you object, your personal data will no longer be used for direct marketing purposes (objection pursuant to Article 21 paragraph 2 UK GDPR).

6.5. Right to lodge complaints

In the event of violations of the UK GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right of appeal is without prejudice to other administrative or judicial remedies.

6.6. Right to data portability

You have the right to have data that we process on the basis of your consent or in fulfilment of a contract automatically handed over to you or to a third party in a commonly used, machine-readable format. If you require the direct transfer of the data to another person responsible, this will only be done as far as it is technically feasible.

6.7. Right to restriction of processing

You have the right to request the restriction of the processing of your personal data by contacting us at any time. The right to restriction of processing exists in the following cases:

  • If you contest the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the examination, you have the right to request the restriction of the processing of your personal data;

  • If the processing of your personal data was/is unlawful, you could request the restriction of data processing instead of deletion;

  • If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion, and

  • If you have filed an objection under Article 21 Paragraph 1 UK GDPR, a balance must be made between you and our interests. As long as it still needs to be made clear whose interests prevail, you have the right to demand the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be used with your consent or for asserting, the exercise or defence of legal claims or the protection of the rights of another natural or legal person or on the grounds of an important public interest of the European Union or of a Member State.

Last update: 19th October 2023