سياسة الخصوصية

Protection of client personal information is an important responsibility of Grow Prime Ltd (the "Company", "we", "us" or "our"). This Privacy Policy explains how we collect, use, store, protect, disclose and retain personal data in connection with our website, client portal, trading platforms, onboarding process, brokerage services and related communications.

Grow Prime Ltd may provide services under the brand name "FxGrow". FxGrow is a brand name, trading name and commercial style of Grow Prime Ltd and is not a separate legal entity.

References to FxGrow in this Privacy Policy mean Grow Prime Ltd, unless the context requires otherwise.

This Privacy Policy should be read together with the Client Agreement, Risk Disclosure Notice, Order Execution Policy, Cookie Policy, AML/KYC disclosures and any other legal documents made available by the Company. By accessing our website, applying for an account, using our services or communicating with us, you acknowledge that your personal data may be processed in accordance with this Privacy Policy.

This Privacy Policy applies to personal data relating to prospective clients, clients, authorised representatives, beneficial owners, directors, shareholders, corporate officers, users of our website or client portal, introducing brokers, affiliates, service providers and other persons who interact with the Company.

For the purposes of this Privacy Policy, Grow Prime Ltd is generally the controller of the personal data it collects and processes. Where we process personal data on behalf of another party, we will do so in accordance with the relevant contractual and legal obligations.

This Privacy Policy does not replace any specific privacy notice, consent form or disclosure that may be provided to you in connection with particular services, products, jurisdictions or regulatory requirements.

We may collect and process personal data that you provide to us directly, that is generated through your use of our services, or that we receive from third parties for compliance, risk management, account administration and service delivery purposes.

Personal data may include, without limitation:

• Identification information, such as full name, date of birth, nationality, citizenship, gender, identification number, passport or national ID details and copies of identification documents.
• Contact information, such as residential address, mailing address, email address, telephone number and communication preferences.
• Financial and economic information, such as annual income, source of funds, source of wealth, employment details, occupation, bank account details, payment information, tax information and financial experience.
• Account and trading information, such as account number, account status, balances, deposits, withdrawals, trading history, orders, positions, margin information, platform activity and client classification.
• Compliance and due diligence information, such as KYC documents, sanctions screening results, politically exposed person checks, adverse media checks, fraud prevention checks, credit or risk assessments and information about beneficial ownership or corporate structure.
• Technical and usage information, such as IP address, device identifiers, browser type, operating system, location data derived from IP address, login history, cookies, analytics data and website or platform usage information.
• Communications data, such as emails, telephone call recordings, chat messages, support tickets, client portal messages and other communications with us or with our representatives.
• Marketing preferences and campaign interaction data, including whether you have opted in or out of receiving marketing communications.

We may collect personal data when you complete an account opening application, upload documents, use our website, access a client portal or trading platform, submit deposits or withdrawals, communicate with us, participate in promotions or otherwise interact with the Company.

We may also collect personal data from third parties where permitted or required by law, including identity verification providers, payment service providers, banks, credit reference agencies, fraud prevention agencies, sanctions screening providers, public registers, regulatory authorities, introducing brokers, affiliates, professional advisers and publicly available sources.

Where you provide personal data about another person, such as an authorised representative, beneficial owner, director, shareholder, employee or contact person, you confirm that you have authority to provide such information and, where required, that the person has been informed of this Privacy Policy.

We process personal data only where we have a lawful basis or legitimate business, contractual, regulatory or compliance purpose for doing so. The purposes for which we may process personal data include:

• To assess, approve, open, maintain, administer and close client accounts.
• To verify identity, conduct KYC, AML, counter-terrorist financing, sanctions, fraud prevention, source of funds and source of wealth checks.
• To provide trading, brokerage, account management, payment, reporting, client support and related services.
• To process deposits, withdrawals, transfers, fees, charges, tax-related deductions and other account transactions.
• To assess appropriateness, trading knowledge, experience, risk profile and eligibility for particular products or services.
• To execute and administer the Client Agreement and other legal documents between you and the Company.
• To manage risk, monitor trading activity, detect market abuse, prevent fraud and protect the integrity of our systems and platforms.
• To comply with laws, regulations, regulatory requests, court orders, reporting obligations, audits and internal control requirements.
• To communicate with you about your account, services, product changes, legal documents, operational updates, complaints, notices and security matters.
• To improve our website, platforms, products, services, client experience, systems, security and internal processes.
• To send marketing communications where you have consented or where we are otherwise permitted to do so, subject to your right to opt out.
• To establish, exercise or defend legal claims and protect the rights, property and interests of the Company, clients and third parties.
• The lawful bases for processing may include performance of a contract, compliance with legal or regulatory obligations, legitimate interests, consent, protection of legal rights, and other lawful bases available under applicable data protection laws.

We may share personal data where necessary for the purposes described in this Privacy Policy, where required by law or regulation, where necessary to provide our services, or where necessary to protect our rights and legitimate interests.

Personal data may be disclosed to the following categories of recipients:

• Group companies, affiliates, related entities, business units and authorised personnel of the Company.
• Technology, hosting, CRM, trading platform, cybersecurity, analytics, communication, document management and IT service providers.
• Payment service providers, banks, card processors, e-wallet providers, correspondent banks and other financial institutions involved in payments or account funding.
• Identity verification, KYC, AML, sanctions, fraud prevention, credit reference, risk screening and due diligence providers.
• Liquidity providers, execution venues, trading infrastructure providers and other counterparties or service providers involved in the provision of trading services.
• Introducing brokers, affiliates, referral partners or advisers where they introduced you to us or are otherwise connected with your relationship with the Company.
• Professional advisers, auditors, insurers, consultants, legal advisers and debt recovery providers.
• Regulators, governmental bodies, tax authorities, law enforcement agencies, courts, dispute resolution bodies and other competent authorities.
• Third parties involved in a merger, acquisition, restructuring, transfer, sale, assignment or financing of all or part of the Company's business or assets.
• We require third-party service providers to use personal data only for the purposes for which it is provided and to apply appropriate confidentiality and security measures, subject to applicable law and contractual arrangements.

Your personal data may be processed, stored or transferred in jurisdictions outside your country of residence, including jurisdictions where the Company, its service providers, banks, payment processors, technology providers or affiliates operate.

Where personal data is transferred internationally, the Company will take reasonable steps to ensure that such transfers are made in accordance with applicable legal and regulatory requirements and that appropriate safeguards are applied where required.

Personal data may be stored electronically, in physical records, on secure servers, cloud systems, client management systems, trading platforms, backup systems and other systems used by or on behalf of the Company.

We maintain appropriate technical, administrative and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, disclosure or destruction. Such measures may include access controls, user authentication, encryption, monitoring, staff training, confidentiality obligations and internal data handling procedures.

Although we take reasonable steps to protect personal data, no website, platform, communication channel or information system can be guaranteed to be completely secure. Clients are responsible for keeping login credentials, passwords, devices and account access information confidential and secure.

Where we become aware of a personal data incident that requires notification under applicable law, we will take appropriate steps to investigate, mitigate and notify affected persons or authorities where required.

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including the provision of services, account administration, compliance with legal and regulatory obligations, record keeping, audit, dispute resolution, fraud prevention and enforcement of our rights.

Retention periods may differ depending on the nature of the data, the purpose for processing, the applicable legal or regulatory requirements and the existence of any dispute, investigation, audit or legal claim.

When personal data is no longer required, we will take reasonable steps to delete, anonymise, archive or securely destroy it in accordance with our policies and applicable requirements.

Our website and online services may use cookies, pixels, tags, analytics tools and similar technologies to support website functionality, improve user experience, remember preferences, analyse traffic, monitor performance, assist with security and support marketing or advertising activities where permitted.

Cookies are small files placed on a device when a user visits a website. Some cookies are necessary for the operation of the website, while others may be used for analytics, personalisation or marketing, subject to applicable requirements and user preferences.

Further information may be provided in a separate Cookie Policy or cookie notice on the website. Users may be able to manage cookie preferences through browser settings or the cookie settings made available on the website.

We may use your contact details to send information about our products, services, market updates, events, campaigns or promotions where you have provided consent or where we are otherwise permitted to do so under applicable law.

You may opt out of marketing communications at any time by using the unsubscribe method provided in the communication or by contacting us. Opting out of marketing communications does not prevent us from sending service, legal, regulatory, security or account-related communications.

Subject to applicable law, you may have rights in relation to your personal data. These rights may include the right to:

• Request access to personal data that we hold about you.
• Request correction of inaccurate or incomplete personal data.
• Request deletion of personal data where there is no lawful reason for us to continue processing it.
• Request restriction of processing in certain circumstances.
• Object to certain types of processing, including direct marketing.
• Withdraw consent where processing is based on consent, without affecting processing carried out before withdrawal.
• Request transfer of certain personal data in a structured format, where applicable.
• Lodge a complaint with a competent supervisory or regulatory authority.

Requests should be submitted in writing using the contact details provided by the Company. We may request additional information to verify your identity before responding to a request. Some rights may be limited where we are required or permitted to retain or process personal data for legal, regulatory, contractual, risk management or legitimate business purposes.

Clients must ensure that personal data provided to the Company is accurate, complete and up to date. You must notify us promptly of any change to your personal data, including changes to your address, contact details, employment, financial circumstances, source of funds, tax information, authorised representatives or beneficial ownership information.

Failure to provide accurate or updated information may affect our ability to provide services and may result in account restrictions, delayed transactions, rejected deposits or withdrawals, suspension or termination of services.

We may amend this Privacy Policy from time to time to reflect changes in our services, systems, legal obligations, regulatory requirements, business operations or data protection practices.

The latest version of this Privacy Policy will be made available on our website or through other appropriate communication channels. Continued use of our website, platforms or services after an updated Privacy Policy becomes effective constitutes acknowledgement of the updated policy.

Questions, requests or complaints regarding this Privacy Policy or the handling of personal data should be directed to Grow Prime Ltd through the contact details made available on the Company's website, client portal or registered communication channels.

Where required, the Company may designate a privacy contact, data protection officer or compliance contact for handling personal data requests. Clients should refer to the latest contact information published by the Company.