Privacy Policy

1. Who We Are

Aptus Invest is an investment firm providing financial and trading services through its online platform.

For the purposes of applicable data protection legislation, Aptus Invest is responsible for determining how and why your personal information is processed.

Our registered office is:

2. Personal Information We Collect

The type of personal information we collect depends on your relationship with us and the services you use.

We may collect the following categories of information:

2.1 Identity and Contact Information

This may include:

• Full name
• Date of birth
• Residential address
• Email address
• Telephone number
• Nationality
• Citizenship
• Identification documents
• Signature
• Other information required to verify your identity

2.2 Financial Information

Where necessary to provide our services or meet regulatory obligations, we may collect:

• Bank account details
• Payment information
• Employment information
• Income information
• Financial circumstances
• Investment experience
• Investment objectives
• Source of funds
• Source of wealth
• Trading and transaction information

2.3 Account Information

When you create or use an account, we may collect:

• Username and account details
• Login information
• Account preferences
• Account activity
• Transaction history
• Trading history
• Communications relating to your account

2.4 Technical Information

When you access our website or online platform, we may automatically collect certain technical information, including:

• IP address
• Browser type and version
• Device type
• Operating system
• Time zone
• Login information
• Website interaction information
• Pages visited
• Referring website
• Technical and security information

2.5 Communications

We may collect and retain information contained in communications between you and Aptus Invest, including:

• Emails
• Contact forms
• Customer support enquiries
• Telephone communications
• Complaints
• Other correspondence

3. How We Collect Your Information

We may collect personal information through a number of methods, including:

• Information you provide directly to us;
• When you create or apply for an account;
• When you complete forms on our website;
• When you contact our customer support team;
• When you use our website or online platform;
• When you make transactions or use our services;
• From banks and payment providers;
• From identity verification providers;
• From fraud prevention and compliance providers;
• From publicly available sources;
• From regulators and government authorities; and
• From other third parties where permitted by applicable law.

4. How We Use Your Personal Information

We may use your personal information for the following purposes:

Providing Our Services

We use your information to:

• Create and manage your account;
• Provide our financial and trading services;
• Process transactions;
• Provide customer support;
• Communicate with you about your account;
• Maintain and administer our platform; and
• Provide information about our services.

Identity Verification and Compliance

We may process your information to:

• Verify your identity;
• Conduct customer due diligence;
• Meet Know Your Customer (“KYC”) requirements;
• Prevent money laundering;
• Prevent terrorist financing;
• Conduct sanctions screening;
• Detect and prevent fraud;
• Meet regulatory reporting requirements; and
• Comply with applicable financial services legislation.

Security and Fraud Prevention

We may use personal information to:

• Protect our website and systems;
• Monitor account activity;
• Detect suspicious or fraudulent activity;
• Investigate security incidents;
• Prevent unauthorised access; and
• Protect our clients and business.

Improving Our Services

We may use information to:

• Analyse website usage;
• Improve our website and online platform;
• Develop new features and services;
• Monitor performance;
• Understand customer needs; and
• Improve the overall customer experience.

Marketing

Where permitted by applicable law, we may use your information to send you information about our products, services and relevant updates.

You may opt out of marketing communications at any time.

5. Legal Basis for Processing

Where applicable, we rely on one or more of the following legal bases when processing personal information:

Contract

We may process your information where it is necessary to enter into or perform a contract with you.

Legal and Regulatory Obligations

We may process your information where necessary to comply with applicable laws, regulations, regulatory requirements, financial crime obligations, reporting requirements or other legal obligations.

Legitimate Interests

We may process information where necessary for our legitimate interests, including operating and improving our business, protecting our systems, preventing fraud and managing our services, provided that these interests do not override your fundamental rights and freedoms.

Consent

Where required by applicable law, we may process your information based on your consent.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6. Sharing Your Personal Information

We may share personal information with third parties where necessary and lawful.

These may include:

• Companies within our corporate group;
• Banks and payment providers;
• Identity verification providers;
• Fraud prevention providers;
• Technology and software providers;
• Hosting providers;
• IT and cybersecurity providers;
• Professional advisers;
• Accountants and auditors;
• Legal advisers;
• Regulators and government authorities;
• Law enforcement agencies; and
• Other service providers that assist us in providing our services.

We require service providers that process personal information on our behalf to handle that information appropriately and in accordance with applicable legal requirements.

We do not sell your personal information to third parties for their own independent marketing purposes.

7. Regulatory and Financial Crime Requirements

As a financial services business, Aptus Invest may be required to collect, verify and retain personal information to meet legal and regulatory obligations.

This may include information relating to:

• Identity;
• Source of funds;
• Source of wealth;
• Financial circumstances;
• Transactions;
• Trading activity;
• Account activity;
• Sanctions screening;
• Fraud prevention; and
• Anti-money laundering requirements.

We may be required to disclose information to regulators, government authorities or law enforcement agencies where legally required or permitted.

8. International Transfers

Some of our service providers or business partners may process personal information outside the United Kingdom or European Economic Area.

Where personal information is transferred internationally, we will take appropriate steps to ensure that the transfer is carried out in accordance with applicable data protection laws.

Where required, appropriate safeguards may include approved contractual protections or other lawful transfer mechanisms.

9. Data Security

We take the security of personal information seriously.

We use appropriate technical and organisational measures designed to protect personal information against:

• Unauthorised access;
• Accidental loss;
• Destruction;
• Misuse;
• Alteration; and
• Unauthorised disclosure.

Security measures may include access controls, authentication procedures, encryption, monitoring and other appropriate security technologies and procedures.

However, no method of electronic transmission or storage can be guaranteed to be completely secure.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected.

We may retain information for longer periods where necessary to:

• Comply with legal or regulatory obligations;
• Maintain financial and business records;
• Prevent fraud and financial crime;
• Resolve disputes;
• Establish, exercise or defend legal claims; or
• Meet regulatory record-keeping requirements.

The applicable retention period may vary depending on the type of information and the purpose for which it is processed.

11. Your Data Protection Rights

Depending on your location and applicable data protection law, you may have certain rights regarding your personal information.

These may include:

• Right of access — you may request a copy of personal information we hold about you.
• Right to rectification — you may ask us to correct inaccurate or incomplete information.
• Right to erasure — you may request deletion of your personal information in certain circumstances.
• Right to restriction — you may request that we restrict certain processing.
• Right to object — you may object to certain types of processing.
• Right to data portability — in certain circumstances, you may request your information in a structured, commonly used format.
• Right to withdraw consent — where processing is based on consent, you may withdraw that consent.

These rights are not absolute and may be subject to legal and regulatory exceptions.

12. How to Exercise Your Rights

If you wish to exercise any applicable data protection right, please contact us:

We may need to request additional information to verify your identity before processing your request.

We aim to respond to valid requests within the time period required by applicable data protection legislation.

13. Marketing Communications

Where permitted by applicable law, we may send you marketing communications about our products, services and relevant updates.

You may unsubscribe from marketing communications at any time by:

• Using the unsubscribe option included in the relevant communication; or
• Contacting us directly.

Please note that you may still receive essential communications relating to your account, transactions, security, legal obligations or regulatory requirements.

14. Cookies and Similar Technologies

Our website may use cookies and similar technologies.

Cookies may be used to:

• Enable essential website functionality;
• Maintain security;
• Remember preferences;
• Analyse website traffic;
• Understand how users interact with our website; and
• Improve our services.

Where required by applicable law, we will request your consent before using non-essential cookies.

For more information, please refer to our Cookies Policy.

15. Third-Party Websites

Our website may contain links to websites or services operated by third parties.

This Privacy Policy does not apply to third-party websites.

We are not responsible for the privacy practices, content or security of third-party websites.

We recommend reviewing the privacy policy of any third-party website before providing personal information.

16. Children's Privacy

Our Services are not intended for individuals who are not legally permitted to use financial services.

We do not knowingly collect personal information from individuals where doing so would violate applicable law.

If you believe that we have collected personal information from an individual who is not legally permitted to use our Services, please contact us.

17. Automated Decision-Making

Where applicable, we may use automated systems or screening processes as part of identity verification, fraud prevention, compliance, security or risk-management procedures.

Where applicable law provides you with rights relating to automated decision-making or profiling, those rights will apply subject to relevant legal and regulatory requirements.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes to our services;
• Changes to our business practices;
• Changes to technology;
• Changes to applicable laws or regulations; or
• Changes to our data-processing practices.

When we make changes, we will update the “Last Updated” date at the top of this Privacy Policy.

We encourage you to review this page periodically to remain informed about how we process personal information.

19. Contact Us

If you have any questions about this Privacy Policy, how we process personal information, or your data protection rights, please contact us: