Privacy Policy

This Privacy Policy describes how Marginbase, operating the online trading platform at marginbase.com (hereinafter — the "Company", "We", "Us", "Our"), collects, uses, stores, and discloses personal data about users of our services (hereinafter — "you" or "the Client").

This Policy forms an integral part of the Client Agreement and is incorporated into it by reference. By using our Platform, you acknowledge and agree to the terms of this Privacy Policy. Continued use of the Platform following any updates constitutes your acceptance of the revised Policy.

We strongly encourage you to read this Policy carefully. If you have any questions, please contact us at [email protected].

1. What Data We Collect and Why

We collect personal data that is necessary to provide our services, comply with legal obligations, and protect the legitimate interests of the Company and our Clients. The table below sets out the categories of data we collect, the purposes for which we process them, and the legal bases we rely upon.

Data Type

Examples

Purpose

Legal Basis

Identity Data

Name, date of birth, passport, ID, driver's license

Account management, KYC/AML compliance, fraud prevention

Contract performance; Legal obligation

Contact Data

Email address, phone number, billing address

Account management, service notifications, support

Contract performance; Legitimate interests

Payment Data

Card details, wallet address, transaction ID, bank details

Payment processing, AML compliance, fraud prevention

Contract performance; Legal obligation

KYC Data

ID documents, proof of address, selfie, source of funds

Identity verification, AML/CFT compliance

Contract performance; Legal obligation

Transaction Data

Deposits, withdrawals, trade history, balance, ROI

Account management, compliance monitoring, analytics

Contract performance; Legitimate interests

Technical Data

IP address, device type, browser, cookies, IMEI

Security, fraud detection, platform analytics

Legitimate interests; Consent (cookies)

Usage Data

Platform improvement, fraud detection, analytics

Legitimate interests

Location Data

Country, time zone, interface language

Geo-compliance, service personalisation

Contract performance; Legal obligation

Marketing Data

Communication preferences, campaign interactions

Marketing communications (with consent)

Consent; Legitimate interests

Profile Data

Username, account level, preferences, leaderboard position

Account management, Copy Trading, leaderboard

Contract performance; Legitimate interests

Economic Profile

Occupation, income, investment purpose, source of wealth

AML risk assessment, regulatory compliance

Contract performance; Legal obligation

We process personal data in compliance with applicable data protection legislation and solely for the purposes described above. We do not collect more data than is necessary for those purposes.

2. How We Collect Personal Data

2.1 Directly from you — when you register an Account, complete identity verification, make deposits or withdrawals, contact our support team, participate in promotions, or respond to surveys.

2.2 Automatically — when you use the Platform, we collect technical and usage data through cookies, log files, and similar tracking technologies. This includes IP address, device identifiers, browser type, session data, and pages visited.

2.3 From third parties — we may receive data from identity verification providers, payment processors, fraud prevention services, and analytics partners, where permitted by applicable law.

3. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our Platform. A cookie is a small data file placed on your device when you visit our website.

3.1 Session Cookies — stored temporarily during your browsing session. They are required for the Platform to function correctly and are automatically deleted when you close your browser.

3.2 Persistent Cookies — remain on your device for a set period. They allow us to recognise returning users and remember preferences such as language settings.

3.3 Third-Party Cookies — set by external services that operate on our Platform, such as analytics providers (including Google Analytics) and advertising networks. These help us understand user behaviour and deliver relevant content.

We may use third-party analytics tools to better understand how users interact with our Platform. These tools may collect anonymised data such as visit frequency, pages accessed, and usage patterns. This data is not linked to personally identifiable information. The use of such tools is subject to the respective provider's terms of service and privacy policy.

3.4 You may remove or disable cookies at any time through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform.

3.5 Where required by applicable law, we will request your consent before placing non-essential cookies on your device.

4. Leaderboard and Copy Trading

4.1 By using the Platform, you acknowledge that your trading activity may contribute to the leaderboard and Copy Trading features. If you appear on the leaderboard, the following data may be visible to other users:

Your display name or User ID (if no name is set)

Country flag icon and optional profile photo

Leaderboard rank, experience points, and total winnings

ROI percentage (calculated over the past 7 days)

Asset, trade direction, and trade duration (to enable copying)

4.2 The actual monetary amount of your Trades is never made public. Only the ROI metric is used for leaderboard ranking.

4.3 By participating in Copy Trading as a signal provider, you grant other users permission to replicate your Trades. You may opt out of appearing on the leaderboard through your account settings.

5. How We Use Your Personal Data

We use your personal data for the following purposes:

To provide and manage your Account and the trading services on the Platform;

To verify your identity and conduct KYC/AML procedures as required by law;

To process deposits, withdrawals, and other financial transactions;

To detect, prevent, and investigate fraud, money laundering, and other illegal activity;

To comply with applicable laws, regulations, and requests from competent authorities;

To communicate with you regarding your Account, transactions, and service updates;

To send marketing communications where you have provided consent or where we have a legitimate interest in doing so;

To personalise your experience on the Platform, including language, content, and promotional offers;

To operate and improve the Platform through analytics and performance monitoring;

To enforce our Client Agreement, Payment Policy, and AML/KYC Policy;

To protect the rights, property, and safety of the Company, our Clients, and third parties.

6. Legal Bases for Processing

We process your personal data on the following legal bases:

6.1 Performance of a contract — processing is necessary to provide the services you have registered for, including account management, trading operations, and payment processing.

6.2 Legal obligation — processing is required to comply with applicable AML, KYC, CFT, and other regulatory requirements.

6.3 Legitimate interests — processing is necessary for our legitimate business interests, including fraud prevention, platform security, analytics, and direct marketing, provided these interests are not overridden by your rights.

6.4 Consent — where required by law, we will request your explicit consent before processing your data for specific purposes such as marketing communications or non-essential cookies. You may withdraw consent at any time.

7. Sharing Your Personal Data

We do not sell, rent, or trade your personal data to third parties. We may share your data in the following circumstances:

7.1 Service Providers

We share data with trusted third-party providers who assist us in delivering our services, including:

Identity verification and KYC/AML screening providers;

Payment processors and financial institutions;

Cloud hosting and data storage providers;

Analytics and performance monitoring tools;

Customer support and communications platforms;

Marketing and advertising partners (non-personal, aggregated data only).

All third-party providers are required to handle your data in accordance with this Privacy Policy and applicable data protection law.

7.2 Legal and Regulatory Disclosures

We may disclose your personal data to competent authorities, regulators, law enforcement agencies, or courts where required by applicable law or where we have a good faith belief that such disclosure is necessary to:

Comply with a legal obligation or official request;

Enforce our agreements or investigate potential violations;

Prevent or detect fraud, money laundering, or criminal activity;

Protect the rights, property, or safety of the Company, our Clients, or others.

7.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the acquiring or successor entity, which will be bound by the obligations set out in this Privacy Policy.

7.4 Affiliates

We may share data with our affiliated entities as part of normal business operations, subject to equivalent data protection standards.

8. International Data Transfers

8.1 The Platform serves users across multiple jurisdictions. Your personal data may be transferred to and processed in countries outside your country of residence. Where such transfers occur, we apply appropriate safeguards to protect your data, including standard contractual clauses or equivalent measures recognised under applicable law.

8.2 By using the Platform, you acknowledge and consent to the transfer of your personal data to countries that may have different data protection standards than your country of residence.

9. Data Retention

9.1 We retain your personal data for as long as necessary to fulfil the purposes described in this Policy, including the duration of your Account and any applicable statutory or regulatory retention periods.

9.2 Transaction records, KYC documentation, and AML-related data are retained for a minimum of 5 years from the end of the Client relationship or the date of the transaction, as required by applicable law.

9.3 After the applicable retention period, we will securely delete or anonymise your personal data, unless we are required by law to retain it for longer.

9.4 Deletion of your Account does not necessarily result in the immediate deletion of all personal data. Certain data may be retained for fraud prevention, legal compliance, and dispute resolution purposes.

10. Advertising and Marketing

10.1 We may use your personal data — such as name, email address, and usage behaviour — to send you marketing communications about our services, promotions, and features. We will only do so where you have consented, or where we have a legitimate interest in communicating with you as an existing Client.

10.2 You may opt out of marketing communications at any time by clicking the unsubscribe link in any email, updating your notification preferences in your Account settings, or contacting us at [email protected].

10.3 We may employ interest-based advertising technologies to deliver relevant ads when you use our Platform or visit third-party websites. These technologies may use cookies and tracking pixels to tailor ad content to your interests.

10.4 You may opt out of interest-based advertising through your device or browser settings. Opting out does not mean you will stop seeing ads — it means the ads you see may be less targeted to your interests.

11. Your Rights

Subject to applicable law, you have the following rights in relation to your personal data:

11.1 Right of access — you may request a copy of the personal data we hold about you.

11.2 Right to rectification — you may request correction of inaccurate or incomplete personal data.

11.3 Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.

11.4 Right to restriction — you may request that we restrict the processing of your data in certain circumstances.

11.5 Right to object — you may object to processing based on legitimate interests, including for direct marketing purposes.

11.6 Right to data portability — where processing is based on consent or contract, you may request a copy of your data in a structured, commonly used format.

11.7 Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at [email protected]. We will respond within a reasonable timeframe and in accordance with applicable law. We reserve the right to verify your identity before processing any request.

12. Account Deletion and Data Removal

12.1 You may request deletion of your Account by contacting Client Support at [email protected] or through the account settings interface.

12.2 Following Account deletion, we will cease using your data for marketing and non-essential purposes. However, certain data — including transaction history, KYC documentation, and compliance records — will be retained for the minimum period required by applicable law.

12.3 In exceptional cases, we may contact you after Account deletion if we are legally obligated to do so, for example in connection with a dispute or regulatory inquiry.

12.4 To request restoration of a deleted Account, please contact [email protected]. Account restoration may not be possible depending on the reason for deletion or the time elapsed.

13. Data Security

13.1 We implement industry-standard security measures to protect your personal data against unauthorised access, loss, disclosure, or misuse. These include SSL/TLS encryption, access controls, secure data storage, and regular security assessments.

13.2 While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security and disclaim liability for unauthorised access caused by factors beyond our reasonable control.

13.3 If you believe your account has been compromised or your privacy has been violated, please contact us immediately at [email protected].

14. Third-Party Websites and Services

Our Platform may contain links to third-party websites, applications, or services. This Privacy Policy applies only to data collected directly by Marginbase. We are not responsible for the privacy practices of third parties and encourage you to review their privacy policies before providing any personal data.

15. Minors

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a minor, we will take steps to delete it promptly. If you believe a minor has provided us with personal data, please contact us at [email protected].

16. Updates to This Privacy Policy

16.1 We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. The latest version will always be published at marginbase.com.

16.2 Where changes are material, we will notify you through the Platform or by email. Continued use of the Platform following any update constitutes your acceptance of the revised Policy.

16.3 We recommend reviewing this Policy periodically to stay informed about how we protect your data.

17. Contact Us

For any questions, requests, or concerns relating to this Privacy Policy or the processing of your personal data, please contact:

Data & Privacy — [email protected]

Website — marginbase.com

We will respond to all legitimate requests in a timely manner and in accordance with applicable data protection law.