Privacy Policy

KW INVESTMENTS LTD ("the Company") is authorised and regulated by the Seychelles Financial Services Authority, with licence number SD020. The Company is committed to protecting individuals' personal data in line with the requirements of applicable law.

This commitment applies to all individuals whose personal data the Company may process. "Personal Data" means any information relating to an identified or identifiable natural person and the Company acts as a controller in relation to such data.

This Privacy Policy describes the types of personal data we collect when you choose to use our services, how we will use your personal data, when and with whom we share it, and how we keep it safe. It also explains your rights and how to exercise them. Please take the time to read and understand this policy.

We may update this notice from time to time and it is important that you check for any changes. Any personal information we hold will be governed by the current privacy notice. If we make important changes, we will communicate them to you.

Please note that this notice is addressed to customers and potential customers.

Personal Data That We May Collect

When you create an account with the Company, we require you to provide your first and last name, email address, details about your financial status, residential address, phone number, date of birth, a copy of your national identity card or passport or driving license, a copy of a recent utility bill or bank statement (or similar) as evidence of your residential address, credit or bank card details, tax residence and tax identification number, profession and employment details, knowledge and experience in trading, risk tolerance and risk profile, and any other information we may consider necessary to provide our services.

If the Company requests personal data and you fail to provide it, we may not be able to provide a service and/or enter into an agreement with you, in which case we will inform you accordingly.

The data above is collected when you open a trading account. It is required by the AML Act (the Anti-Money Laundering and Countering the Financing of Terrorism Act, amended from time to time) so that the Company can verify your identity, construct your economic profile, monitor your account, and verify the source of funds where necessary. Additionally, we use this data to set up and administer your trading account, and to provide technical and customer support.

We use cookies to store and collect information about your use of our website. Cookies are small text files stored by the browser on your equipment's hard drive. They enable us to load your personal preferences and improve your experience.

If you are a corporate client, we are required to collect information related to the legal entity (for example, corporate and constitutional documents) plus additional personal information on shareholders, directors, and other officers as needed to comply with legal and regulatory requirements.

We may record any communications—electronic, by telephone, in person, or otherwise—that we have with you in relation to the services we provide. These recordings will be our sole property and constitute evidence of the communications between us.

Legal Grounds for Personal Data Processing

We may process your personal data for one or more lawful bases depending on the specific purpose for which we are using your data. The lawful bases are:

to perform our contractual obligations towards you;
to comply with applicable legal and regulatory requirements;
to pursue our legitimate interests.

Where our use of your personal information does not fall under one of the above lawful bases, we will require your consent. Such consent shall be freely given and you will have the right to withdraw it at any time by contacting us using the contact details in this notice or by unsubscribing from email lists.

How We Use Your Personal Data

Client information held by the Company is treated as confidential and will not be used for any purpose other than in connection with the provision, administration, and improvement of the services, anti-money laundering and due diligence checks, research and statistical purposes, and marketing purposes. Information already in the public domain or already possessed by the Company without a duty of confidentiality will not be regarded as confidential.

The Company may disclose client information (including recordings and confidential documents, card details) in the following circumstances:

where required by law or a court order by a competent court;
where requested by the FSA or any other regulatory authority having control or jurisdiction over the Company or the client or their associates or in whose territory the Company has clients;
to government bodies and law enforcement agencies where required by law and in response to other legal and regulatory requests;
to relevant authorities to investigate or prevent fraud, money laundering, or other illegal activity;
where necessary in order for the Company to defend or exercise its legal rights to any court, tribunal, arbitrator, or governmental authority;
to such an extent as reasonably required to execute orders and for purposes ancillary to the provision of the services;
to payment service providers and banks processing your transactions;
to auditors, contractors, or other advisers auditing, assisting with, or advising on any of our business purposes, provided the relevant professional commits to confidentiality;
to other service providers who create, maintain, or process databases, offer recordkeeping services, email transmission services, messaging services, or similar services which assist the Company in collecting, storing, processing, or using client information or improving the provision of services;
to other service providers for statistical purposes in order to improve the Company's marketing, in which case the data will be provided in aggregate form;
to market research call centres that provide telephone or email surveys with the purpose of improving the Company's services, in which case only contact details will be provided;
where necessary in order for the Company to defend or exercise its legal rights to any court, tribunal, arbitrator, ombudsman, or governmental authority;
to anyone authorised by you;
to an affiliate or introducing broker of the Company or any other company in the same group;
to any third party where such disclosure is required in order to enforce or apply our terms and conditions or other relevant agreements;
to successors, assignees, transferees, or buyers with ten business days' prior written notice to the client. This may occur if the Company decides to sell, transfer, assign, or novate any or all of its rights, benefits, or obligations under the agreement with you, including in the event of merger, acquisition, reorganisation, winding up, or sale or transfer of all or part of the business or assets.

The Safety of Your Personal Data

KW Investments Ltd takes appropriate measures to ensure enhanced security to protect any personal data provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored, or otherwise processed.

The Company implements appropriate technical and organisational measures such as data encryption, access management procedures, clean desk policy, business continuity and disaster recovery planning, IT systems risk assessments, physical and logical access segregation, and data breach processes. Access to personal data is limited to employees, agents, contractors, and other third parties who have a business need to know. They will only process personal data on the Company's instructions and are subject to a duty of confidentiality. Your personal data may be stored electronically or in paper form.

Marketing Activities and Profiling

We may process your personal data to tell you about products, services, and offers that may be of interest to you or your business. The data we process for this purpose consists of information you provide to us and data we collect or infer when you use our services. This information helps us improve services, customise your browsing experience, and inform you of additional products, services, or promotions that are relevant. In some cases, profiling is used—that is, we process your data automatically to evaluate certain personal aspects and provide targeted marketing information.

We can only use your personal data to promote our products and services if we have your explicit consent to do so or, in certain cases, if we consider that it is in our legitimate interest.

Your Rights as a Data Subject

Right of access – request a copy of the personal data that we hold about you.
Right of rectification – request correction of personal data that is inaccurate or incomplete.
Right to be forgotten – request the erasure of personal data from our records in certain circumstances.
Right to restriction of processing – request that we restrict processing of your personal data where certain conditions apply.
Right of portability – request the transfer of your personal data to another organisation where applicable.
Right to object – object, on grounds relating to your particular situation, to certain types of processing such as direct marketing or processing based on legitimate interest.
Right to request data transfer – request that we provide your personal data in a structured, commonly used, machine-readable format to you or a third party.
Right to withdraw consent – withdraw consent at any time where we rely on consent to process your personal data.

We may charge a reasonable fee when a request is manifestly unfounded, excessive, or repetitive, or when we receive a request to provide further copies of the same data. Alternatively, we may refuse to comply with your request in these circumstances.

Contacting Us or Making a Complaint

If you have any queries about this policy, wish to inform us of a change or correction to your personal data, would like a copy of the data we collect on you, or would like to raise a complaint or comment, please contact us at [email protected].

We will try to respond without undue delay and in any case within one month of receipt of the request. If your request takes us longer than one month we will notify you and keep you updated.

Information provided as a result of exercising your rights shall be free of charge. Nonetheless, where requests are manifestly unfounded or excessive, in particular because of their repetitive character, the Company may either:

charge a reasonable fee considering the administrative costs of providing the information or taking the action requested; or
refuse to act on the request.