Introduction

This Policy aligns with Article 24 of the GDPR (EU) 2016/679, considering the nature, scope, context, and purposes of processing, as well as the risks to the rights and freedoms of individuals. Monte Edge Capital has implemented appropriate technical and organizational measures to ensure compliance with the General Data Protection Regulation (GDPR). This policy is the cornerstone of Monte Edge Capital’s GDPR compliance and is reviewed and updated regularly.

This Policy provides data subjects with information on how Monte Edge Capital collects, uses, and shares personal data. This privacy notice is drafted in compliance with the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679, and the Information Commissioner’s Code of Practice on “Privacy notices, transparency and control,” as well as the Article 29 European Commission Guidelines on transparency under the GDPR.

Please read this privacy notice carefully. Your privacy on the internet is crucial to us. This notice contains important information about who we are, how and why we collect, store, use, and share personal information, your rights concerning your personal information, and how to contact us and supervisory authorities if you have a complaint.

Who We Are

Monte Edge Capital (“us,” “our,” or “we”) collects, uses, and is responsible for certain personal information about you. When we do so, we are regulated under the General Data Protection Regulation, which applies across the European Union, and we are responsible as the “controller” of that personal information for the purposes of those laws.

Data Controllers and Contracting Parties

Regardless of whether you reside inside or outside the “Designated Countries,” Monte Edge Capital will be the controller of your personal data provided to, collected by, or processed in connection with our services and regulated activities.

Whether Information Has to Be Provided by You, and If So, Why

The provision of “Your Data” is required to enable us to provide our services. We will inform you at the point of collecting information whether you are required to provide the information to us.

Information Collected by Us

During your registration as a client, signing up for a demo or live account with Monte Edge Capital, filling in any form on our website, subscribing to our services, news or offers, marketing communications, or posting material, the following information about you (“Your Data”) will be collected and stored for administrative, service-related, and/or legal purposes.

We will limit the collection of personal information to what is necessary to administer our business and carry out our regulated activities to provide you with superior service.

Information That You Provide to Us Directly:

Personal Information: such as names, addresses, personal registration numbers, national identification numbers, passport numbers, and email addresses.

Financial Information: trading experience and employment information for appropriateness assessment.

However, the meaning of data “provided to” Monte Edge Capital is not limited to this. It also includes personal data resulting from observation of your activities (i.e., where using a device or service).

This may include:

• History of website usage or search activities, details of your visits to our Website including, communication data;

• Traffic and location data;

• Website traffic pattern information, including IP address, operating system, and browser type, for system administration and to report aggregate information to our advertisers. This kind of information is only used in masked or aggregated form, meaning that the individual user will not be recognizable. These data do not identify any individual.

• Communications between you and Monte Edge Capital via Live Chat, email, or telephone call.

Your e-mail address may be used by Monte Edge Capital in relation to its products and services (including any marketing campaigns related to these products or services). If you do not wish to receive such marketing material and communications, you can opt-out at any time by clicking on “unsubscribe” or by sending an email stating so to askme@monteedge.com.

The Type of Data Collected and Purpose of Collection

The type of data we collect along with the purpose for collection is listed below:

1. Personal information such as gender, name, date of birth, and address: To meet our anti-money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. To verify your identity using our verification processes.

2. Contact information (email address and phone number): In order to send you correspondence in relation to the services provided and to fulfill our regulatory and compliance obligations.

3. Employment information, and financial information: In order to comply with KYC obligations and to meet our regulatory obligations relating to assessing the appropriateness of our products and services.

4. Ethnicity, citizenship, and social security numbers or national identity and passport: In order to comply with KYC and regulatory trade reporting and other AML obligations.

5. Proof of photo ID, and address verification: In order to comply with KYC and regulatory trade reporting and other AML obligations.

6. Unique device number (IP address) and device information including version of web browser you use: When you visit our website, navigate through the pages, or fill in any forms, we may collect your unique device number or IP address to set up your profile.

7. Financial sanctions and credit header information: In order to perform our electronic AML screening checks and to comply with other fraud detection policies. This may generate further information on your credit history, criminal convictions, or political interests, leading to us making decisions based on the results of these checks.

How We Use Your Personal Information

We use information held about you in the following ways:

• To ensure that the content on our website is presented to you in the most effective manner and to improve the content of our website.

• To communicate with you and contact you, and to provide you with products and services that you request from us or, where you have consented, for products and services that we feel may be of interest to you.

• Managing and administering the products and services provided to you.

• Keeping you updated as a client in relation to changes to our services and relevant matters.

• Providing, improving, testing, and monitoring the effectiveness of our services.

• Developing and testing new products and features.

• Monitoring metrics such as total number of visitors, traffic, and demographic patterns.

• Diagnosing or fixing technology problems.

• To carry out our obligations arising from any contracts entered between you and us.

• We may also use your data, or permit selected third parties and our processors to use your data, to provide you with information about goods and services that may be of interest to you, and we or they may contact you about these by email.

• To notify you about updates to the website.

• To send out newsletters or information about other opportunities that we believe will be of interest to you. We will only send this to you if you have indicated that you wish to receive such information and we will respect your wish not to do so if you communicate such a wish to us. You can opt-out of receiving marketing communications at any time by clicking on “unsubscribe” or by sending an email request to askme@monteedge.com

• To promote safety and security. We use the information we have to help verify accounts and activity, and to promote safety and security on our regulated services, such as by investigating suspicious activity or violations of our terms or policies. We work hard to protect your account using teams of IT specialists, automated systems, and advanced technology such as encryption.

Who We Share Your Personal Information With

We will not rent or sell your information to third parties outside of Monte Edge Capital (or the group of companies of which Monte Edge Capital is a part) without your consent. We also impose strict restrictions on how our processors can use and disclose the data we provide. Here are the types of third parties we share information with:

• Service Providers and Other Partners: We transfer information to service providers (processors), and other partners who globally support our business, such as providing technical infrastructure services, trading platforms, analyzing how our services are used (such as measuring the effectiveness of ads and services), providing client service and support, client onboarding, client identity verification (including PEPs and sanctions), conducting marketing communications and design, services related to our website management, services related to software and business development services.

• We need to transfer personal data to recipients outside the European Union: These activities can include dealings with foreign public entities (only when necessary and under request), the outsourcing of services to external providers located outside the EU, and/or processing the data outside the EU (i.e., cloud computing, client identity verification, and individuals from outside the EEA accessing our web services).

• Measurement and Analytics Services: Partners who use our analytics services like Google Analytics (Non-Personally Identifiable Information Only). We do not share information that personally identifies you (personally identifiable information is information like your name or email address that can by itself be used to contact you or identify who you are) with advertising, measurement, or analytics partners.

Monte Edge Capital conducts extensive due diligence before choosing processors, ensuring they provide sufficient safeguards, particularly in terms of expert knowledge, data governance, data security, cyber resilience, reliability, and resources to implement technical and organizational measures in such a manner that processing will meet the requirements of GDPR and ensure the protection of the rights of the data subject.

The adherence of the processor to an SLA Contract is used as an element to demonstrate compliance with the obligations of the controller.

The carrying out of processing by our processor is governed by a contract or other legal act under Union or Member State law, binding the processor to the controller.

This data sharing with our processor enables us to proceed with our regulated activities and duties to KYC to meet our regulatory obligations relating to assessing the appropriateness of our products and services, providing support to clients, etc. Some of those third-party recipients (processors) may be based outside the European Economic Area; if the third-party recipient is located outside the EU/EEA in a country not ensure an adequate level of data protection, the transfer will be subject to appropriate safeguards.

Automated Decision-Making

We do not use your data for any automated decision-making. However, we may do so to fulfill obligations imposed by law.

Legal Basis for Using Your Information

We rely on the following legal grounds to process your personal information:

• Consent: We may use your information as described in this privacy policy subject to your consent. To withdraw your consent, please email askme@monteedge.com.

• Performance of a Contract: We may need to collect and use your personal information to enter into a contract with you or to perform services related to a contract.

• Legitimate Interests: We may use your personal information for our legitimate interests to provide our services and improve them.

• Legal Obligation: We may be required to process your personal information under a legal obligation.

Your Rights Under GDPR

• Right of Access: You have the right to access your personal data and supplementary information.

• Right to Rectification: You have the right to have inaccurate personal data rectified or completed if it is incomplete.

• Right to Erasure: You have the right to have personal data erased.

• Right to Restrict Processing: You have the right to request the restriction or suppression of your personal data.

• Right to Data Portability: You have the right to obtain and reuse your personal data for your purposes across different services.

• Right to Object: You have the right to object to the processing of your personal data.

• Rights Related to Automated Decision Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

How to Complain

We hope we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Changes to This Privacy Policy

We will review and update this policy annually or more frequently if necessary. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

How to Contact Us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to askme@monteedge.com, or write to:

Monte Edge Capital
Data Protection Officer
Room 4, 16F Ho Kim Comm Centre, Hong Kong

Cookies Policy

Monte Edge Capital uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.