1.Introduction

Ace Up Capital Ltd. (hereinafter “the Company”, “We”, “Us”, or “Our”) is committed to protecting your privacy and safeguarding your Personal Data.

This Privacy Notice (hereinafter “the Notice”) outlines the purposes and methods by which the Company collects and processes your Personal Data.

2.Scope

This Notice provides you with information on how we collect and process your Personal Data through your use of this website and our services. We strongly advise you to read this document carefully, as it forms part of the Company’s Terms and Conditions and demonstrates our compliance with the GDPR and the Law.

This Notice details the conditions for collecting and processing your Personal Data, ensuring adherence to the transparency principle under applicable data protection laws. It describes our methods for acquiring and handling your Personal Data through digital interfaces and software associated with this Notice.

This Notice is directed to natural persons who are:

*   Current, potential, or past clients of the Company;

*   Beneficial owners or authorized representatives/agents of legal entities that are current, potential, or past clients of the Company;

*   Authorized representatives/agents of natural persons who are current, potential, or past clients of the Company.

Our website, located at https://aceupcapital.com/ https://help.aceupcapital.com/ (the “Website”), and any other website owned by the Company, is not intended for children under 18, and we do not knowingly collect data relating to children.

By accepting this Notice and using our Website, you consent to the data practices described herein and in all extensions and addendums to this Notice. The Notice applies to all Personal Data the Company holds relating to identifiable individuals. Ace Up Capital is the data controller, as it determines the purposes and means of the processing.

3. Personal Data

As per Article 4 of the GDPR, “Personal Data” refers to any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable person is one who can be distinguished directly or indirectly by reference to an identifier such as a name, identification number, location data, online identifier, or other factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.

The Company will collect and process various types of Personal Data. In line with Article 5 of the GDPR, all Personal Data is processed according to the following principles:

*   Processed lawfully, fairly, and in a transparent manner;

*   Collected for specified, explicit, and legitimate purposes and not processed further in an incompatible manner;

*   Adequate, relevant, and limited to what is necessary for the purposes;

*   Accurate and, where necessary, kept up to date;

*   Kept in an identifiable form only for as long as necessary;

*   Processed securely to ensure protection against unauthorized or unlawful processing, accidental loss, destruction, or damage.

3.1 Purposes for Data Collection and Processing

The Company collects, uses, stores, and transfers Personal Data to provide services to its clients and to ensure compliance with legal obligations. If you fail to provide the requested information, we may be unable to provide our services. It is your responsibility to ensure that all information provided is accurate and up-to-date.

3.2 Categories of Personal Data Collected

The Company may collect and process the following types of Personal Data:

*   Identity Data: Name, maiden name, surname, proof of identity, username, marital status, title, date and place of birth, gender, country of residence, and citizenship.

*   Tax and Financial Data: Country of tax residence, tax identification number, bank account details, payment card details, e-wallet information.

*   Transaction Data: Payment details, products and services purchased, and transaction purposes.

*   Technical Data: IP address, login data, browser type and version, time zone, operating system, device information, and other technical data related to your use of our Website.

*   Profile Data: Username and password, order history, preferences, feedback, marketing communication preferences, and survey responses.

The Company may also process Personal Data obtained from publicly available sources such as the internet, media, the Department of Registrar of Companies, and the Land Registry. Additionally, we may process sensitive personal information for employment purposes as permitted by law.

4. Usage of Personal Data

Ace Up Capital is committed to protecting and respecting your privacy. By accessing or using our platform, you consent to the data practices outlined in this Notice.

4.1 Purposes of Personal Data Usage

We may collect and use Personal Data for the following purposes:

*   Account Management: To open and maintain your account on our platform.

*   Service Improvement: To enhance services and optimize website functionality.

*   Communications: To send newsletters, alerts, and updates with your consent.

*   Performance Analytics: To monitor and analyze website interactions for improvement.

*   Legal Compliance: To fulfill legal obligations and requirements.

*   Contractual Fulfillment: To execute agreements with users or partners.

4.2 Necessity of Personal Data

The collection and processing of Personal Data are justified by the following reasons:

*   Website Operation: To provide access to our platform and ensure smooth operations.

*   Market Data Products: To provide market data services or similar products.

*   Personalized Services: To tailor content and services to individual preferences.

*   Communication Retention: To retain your data for communication purposes regarding your account and updates.

4.3 Use of Cookies and Tracking Technologies

We utilize cookies and tracking technologies for the following purposes:

*   Website Management and Analytics: To manage website operations and analyze user behavior to improve our services.

*   Monitoring User Interactions: To understand how users interact with our website and services to enhance the user experience.

*   Tracking Communication Engagement: To track links opened or interacted with in communications sent to you.

5. Legal Basis for Processing Personal Data

The legal grounds for processing your Personal Data are as follows:

Legitimate Interest: Processing necessary to safeguard and promote the Company’s business interests.

Consent: Where we have your explicit consent for processing, such as for newsletters or marketing.

Performance of a Contract: To fulfill contractual obligations between you and the Company.

Legal Compliance: To comply with applicable legal requirements.

5.1 Multiple Legal Bases for Processing

We may process Personal Data under more than one legal basis depending on the specific purpose. The table below details the purposes, data categories, and corresponding legal bases:

| Purpose | Data Category | Legal Basis |

| :— | :— | :— |

| To register you as a new user and provide access to services. | Registration Data, Contact Data, Log-in Data | Performance of a contract |

| To allow access to services. | Usage Data | Performance of a contract |

| To manage our relationship with you and provide services. | Registration Data, Contact Data, Profile Data, Usage Data | Performance of a contract, Legal obligation |

| Direct marketing of third-party services (e.g., bonuses, offers). | Marketing Communication Data | Legitimate interest, Consent |

| Social Media Marketing | Contact Data | Legitimate interest, Consent |

| Commercial business analysis and reporting. | Usage Data, Analytics Data | Legitimate interest |

| Web Analytics | Usage Data, Analytics Data | Legitimate interest |

5.3 Direct Marketing

In compliance with relevant laws and based on legitimate interest or your consent, the Company may periodically notify you about similar products or services, including new services, promotions, bonuses, and offers. Such notifications may be sent via:

*   Email or SMS;

*   Social media;

*   Live phone calls;

*   Push notifications (desktop and/or app).

When relying on legitimate interest, we will provide you with the option to object to direct marketing during registration. When relying on consent, it will be obtained from you during the registration process.

6. Disclosure of Personal Data

The Company is committed to ensuring the protection and confidentiality of your Personal Data. The following outlines our protocols for data disclosure and transfer:

Recipient Identification: Personal Data may be transferred globally to the Company’s subsidiaries, affiliates, and third-party service providers. These transfers are conducted in strict adherence to data protection standards.

International Data Transfer Protocols: We implement measures such as encryption, pseudonymization, and robust contractual agreements to safeguard your data during international transfers.

Confidentiality and Legal Obligations: Your data is treated as confidential and may be shared within the Company and with partners to fulfill contractual and legal obligations. Partners are bound by confidentiality agreements and may only use your data for the purposes defined by the Company.

6.1 Authorized Recipients of Personal Data

The Company may disclose Personal Data to the following recipients:

  Technology experts for system maintenance.

 Platform providers supporting service delivery.

Payment service providers and credit institutions to facilitate transactions.

 Governmental and regulatory bodies as required by law.

Fraud prevention and verification service providers. 
Data reporting service providers for regulatory compliance.

External consultants and auditors.

The Company’s Data Protection Officer (who may be an outsourced entity).

The Company may also disclose Personal Data if required by law, to prevent harm, combat illegal activities, enforce our Terms and Conditions, or support corporate functions like mergers or sales. In such business transitions, we will implement protective measures to maintain your data’s confidentiality.

Third-party service providers are not permitted to use your Personal Data for their own purposes and must process it only per our instructions and in compliance with applicable laws.

7. Third-Party Sites

Our Website may contain links to external websites. Clicking these links will redirect you away from our site. The Company does not endorse or sponsor these third-party sites. You are solely responsible for your use of these external links, which are subject to the terms and privacy notices of the respective third-party websites.

8. User Forums

If you participate in user forums on this Site or on linked third-party platforms (e.g., Discord, Telegram), please be aware that any information you share may be accessible to others. The Company is not responsible for the practices of third parties who collect and use information you disclose publicly. Exercise caution when sharing personal or sensitive information in such forums.

9. Mobile Device Information

The Company uses trusted third-party providers to analyze our mobile applications. This analysis helps us optimize performance, track usage patterns, and promptly fix errors. The reports generated include aggregate usage data, browsing patterns, device information, and application error details.

10. Data Retention

We will retain your Personal Data only for as long as necessary to fulfill the purposes we collected it for, including for legal, accounting, or reporting requirements. Our retention criteria depend on the nature of the data. We retain Personal Data for the maximum period allowed by applicable laws (e.g., tax, corporate laws). If no laws prescribe a retention period, we will keep the data for the duration necessary to defend against legal claims. Where data is no longer required, we will securely delete or anonymize it.

11. Usage of Automated Chatbots

The Company may use chatbots as an initial point of contact to facilitate customer service. Chatbots are used to triage user inquiries. Inquiries that fall beyond predetermined parameters (e.g., those not covered in FAQs) are escalated to human agents. The use of chatbots is supervised by human personnel.

12. Data Security

We have implemented appropriate security measures to prevent your Personal Data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorized way. We use industry-standard encryption for data in transit and at rest.

Access to your Personal Data is limited to employees, agents, contractors, and other third parties who have a business need to know. They will only process your data on our instructions and are subject to a duty of confidentiality.

While we take all reasonable precautions, absolute security cannot be guaranteed. In the event of a data breach, we will conduct a thorough risk assessment and notify impacted individuals as required by law.

13. Your Rights under the GDPR

In accordance with the EU and UK GDPR, you have the right to request confirmation regarding the processing of your Personal Data. Upon request, we will provide you with access to the following information:

*   The Personal Data we hold about you;

*   The purposes of the processing;

*   The categories of recipients to whom your data has been disclosed;

*   The intended retention period;

*   Information about international transfers and safeguards;

*   Your data subject rights;

*   The process for making a complaint;

*   The source of your data;

*   Details of any automated decision-making, including profiling.

13.1 Right to Rectification

You have the right to request the correction of inaccurate or incomplete Personal Data. Please notify us of any changes, and we will take reasonable steps to update your information.

13.2 Right to Erasure

You have the right to request the deletion of your Personal Data when:

*   It is no longer necessary for the purposes collected;

*   You withdraw consent (where processing is based on consent) and no other legal ground exists;

*   You object to processing and there are no overriding legitimate grounds;

*   The data has been processed unlawfully;

*   A legal obligation requires erasure.

13.3 Right to Restriction of Processing

You have the right to request the restriction of processing (i.e., storing but not using your data) in the following cases:

*   You contest the accuracy of the data, for a period allowing us to verify it;

*   The processing is unlawful, but you oppose erasure;

*   We no longer need the data, but you require it for legal claims;

*   You have objected to processing, pending verification of our legitimate grounds.

13.4 Right to Data Portability

You have the right to receive your Personal Data in a structured, machine-readable format and to transmit it to another controller, where the processing is based on consent or contract and is carried out by automated means.

13.5 Right to Object

You have the right to object to processing based on legitimate interests or the performance of a task in the public interest. You have an absolute right to object to direct marketing at any time.

13.6 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before the withdrawal.

13.7 Right to Lodge a Complaint

You have the right to file a complaint with a supervisory authority, such as the Office of the Commissioner for Personal Data Protection in Cyprus. We encourage you to contact us first to resolve any issue.

You may exercise any of these rights by emailing [support@aceupcapital.com](mailto:support@aceupcapital.com).

14. Your Rights under the California Consumer Privacy Act (“CCPA”)

For California residents under 18 who are registered users, California law permits the request for removal of publicly posted content or information.

This Notice outlines the categories of Personal Data we collect, process, and disclose, along with the business purposes for these actions, in compliance with the CCPA.

Under California law, you may request, up to twice in a 12-month period, information about our collection, use, and disclosure of your Personal Data in the preceding 12 months, including:

*   Categories of Personal Data collected and their sources.

*   The business or commercial purpose for collecting or selling data.

*   Categories of third parties with whom we shared the data.

You may also request the specific pieces of Personal Data collected about you and/or shared with third parties. You have the right to request the deletion of your Personal Data, subject to certain legal exceptions.

To process your request, we will need to verify your identity by collecting specific Personal Data as required by the CCPA. The Company will not discriminate against you for exercising your CCPA rights.

15. Cookies

Our Website uses cookies. For detailed information on the cookies we use, how we use them, and how you can manage your cookie preferences, please read our Cookies Consent Preferences.

16. Record Keeping: Recording of Communications**

The Company records, monitors, and processes telephone conversations and electronic communications (e.g., phone, email, social media, electronic messages) between you and the Company. This includes communications that may result in transactions, even if no transaction is concluded. The content of relevant in-person conversations may also be recorded in minutes or notes.

17. Security

The privacy of your personal information is of fundamental importance to us. We employ strict security measures to protect against unauthorized access, alteration, disclosure, or destruction of data.

We restrict access to personal information to employees who need it to operate, develop, or improve our services. These individuals are bound by confidentiality obligations. The Personal Data you provide is protected by your password, which you must keep secure. This data is stored on secure servers with access restricted to authorized personnel, and we use encryption techniques to prevent unauthorized access.

18. Changes to this Privacy Notice

The Company reserves the right to change this Notice. If changes significantly reduce your rights, we will notify you. For material changes, we will notify you via email, a notice on our homepage, or by updating the version date at the top of this document. The latest version will always be available at [https://aceupcapital.com/privacy-policy Any revised Notice is effective immediately upon posting.

19. Legal Disclaimer

The Company reserves the right to disclose your personally identifiable information as required by law or when we believe disclosure is necessary to protect our rights, comply with a judicial proceeding, court order, or legal process.

The Company is not liable for the misuse or loss of personal information from cookies on our site that we do not control. We are also not liable for the unlawful or unauthorized use of your personal information due to the misuse or misplacement of your passwords.

20. Contact Us

For any questions regarding this Privacy Notice, the retention of your data, or other data privacy concerns, please contact our customer support team at support@aceupcapital.com