Privacy Policy

1. Data Controller Information

May Locvinh ("we", "our", or "us"), located at Park Row 78, BS1 5LJ Bristol, United Kingdom, acts as the data controller responsible for personal data processed via our web domains, APIs, and client dashboards under the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Categories of Data Collected

We collect and process personal data strictly required to deliver fast, secure algorithmic infrastructure. The categories include:

• Identification Details: First and last name, date of birth, proof of residency, and official identity documents where mandatory under anti-money laundering (AML) frameworks;
• Contact Information: Electronic mail address, telephone number, and communication histories;
• Technical & Telemetry Data: IP addresses, browser specifications, operating system versions, access timestamps, referral URLs, and session telemetry;
• Transactional & Execution Records: Trading pair identifiers, order sizes, execution timestamps, leverage allocations, and API request logs.

3. Legal Bases for Processing

We process your personal information strictly under valid lawful bases established in Article 6 of the UK GDPR:

• Contractual Performance: To maintain your user credentials, manage connection interfaces, and deliver algorithmic trade routing services;
• Legal & Regulatory Obligations: To adhere to financial reporting, AML, Counter-Terrorism Financing (CTF), and lawful administrative disclosure requirements;
• Legitimate Interests: To enhance platform resilience, detect automated intrusion attacks, debug system errors, and safeguard digital assets;
• Consent: Where you have provided unambiguous consent for specific communication preferences or analytics telemetry.

4. Cookies and Analytical Tracking

The Platform utilizes technical cookies, session tokens, and local cache storage to secure authenticated states, preserve user interface preferences, and analyze latency trends across regional endpoints. We do not sell tracking profiles to external data brokers.

You can configure your browser preferences to reject non-essential cookies; however, disabling critical authentication cookies may impair the real-time execution capability of our trading algorithms.

5. Information Sharing and Disclosure

May Locvinh does not monetize or lease personal information. Data sharing is limited to the following operational scenarios:

• Regulated Brokerage Partners: Third-party liquidity providers and brokerages that execute your automated trades;
• Infrastructure Suppliers: Cloud computing providers, server hosting facilities, and security verification firms operating under strict non-disclosure obligations;
• Regulatory & Enforcement Authorities: Public bodies, courts, or law enforcement agencies when compelled by valid legal subpoenas or applicable statutes.

6. International Data Transfers

Because our algorithmic execution servers and liquidity venues operate internationally, personal data may be transferred, stored, and processed outside the United Kingdom. When data is transferred to jurisdictions lacking an adequacy decision, May Locvinh enforces standard contractual clauses, international data transfer agreements (IDTAs), and rigorous end-to-end encryption to preserve high privacy standards.

7. Data Retention & Safeguards

We implement multi-layered encryption (TLS 1.3 in transit and AES-256 at rest), zero-trust access controls, and recurring vulnerability audits. Personal records are retained only as long as necessary to fulfill the operational purposes described herein, or for a statutory limitation period of up to seven (7) years following account closure to satisfy financial compliance rules.

8. Your Statutory Rights

Under UK data protection legislation, you are entitled to exercise the following legal rights without cost:

• Right of access to personal records held concerning you;
• Right to rectification of incomplete or inaccurate information;
• Right to erasure ("right to be forgotten"), subject to statutory record-keeping constraints;
• Right to restrict or object to certain processing operations;
• Right to data portability in a machine-readable format;
• Right to lodge a complaint with the Information Commissioner's Office (ICO) in the United Kingdom.

9. Contact the Data Protection Team

To exercise statutory rights, request data updates, or seek clarifications regarding our privacy governance, please direct inquiries to:

Data Protection Officer · May Locvinh
Park Row 78, BS1 5LJ Bristol, United Kingdom
Email: [email protected]
Telephone: +44 20 7946 9667