Privacy Policy 

This Application collects some Personal Data from its Users.


Owner and Data Controller

Blocktopus Enterprise Ltd.,
2nd Floor O’Neal Marketing Associates Building, Wickham’s Cay II
P.O. Box 3174
Road Town, Tortola
British Virgin Islands
Owner contact email: [email protected]


Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
various types of Data; email address; Trackers; Usage Data; number of Users; city; device information;
session statistics; latitude (of city); longitude (of city); browser information.

In case of dedicated Basket Managers, we are collecting the following data:
  • professional experience, 
  • list of documents: relevant diploma, trading history documentation
Please be aware, that we need to execute a KYC (know-your-customer) process, provided by a 3rd party, Sumsub. In this link you can read their Privacy Policy. 

Complete details on each type of Personal Data collected are provided in the dedicated sections of this
privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when
using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this
Data may make it impossible for this Application to provide its services. In cases where this Application
specifically states that some Data is not mandatory, Users are free not to communicate this Data without
consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services
used by this Application serves the purpose of providing the Service required by the User, in addition to any
other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this
Application and confirm that they have the third party’s consent to provide the Data to the Owner.


Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or
unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational
procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the
Data may be accessible to certain types of persons in charge, involved with the operation of this Application
(administration, sales, marketing, legal, system administration) or external parties (such as third-party
technical service providers, mail carriers, hosting providers, IT companies, communications agencies)
appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be
requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the
    Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”),
    without having to rely on consent or any other of the following legal bases. This, however, does not
    apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any precontractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official
    authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in
particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.


The Data is processed at the Owner’s operating offices and in any other places where the parties involved in
the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other
than their own. To find out more about the place of processing of such transferred Data, Users can check the
section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European
Union or to any international organization governed by public international law or set up by two or more
countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document
or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected


  • Personal Data collected for purposes related to the performance of a contract between the Owner and
    the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as
    needed to fulfill such purposes. Users may find specific information regarding the legitimate interests
    pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent
to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to
retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation
or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to
erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the
retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal
obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third
parties), detect any malicious or fraudulent activity, as well as the following: Data transfer outside the EU,
Managing contacts and sending messages, Heat mapping and session recording and Analytics.

For specific information about the Personal Data used for each purpose, the User may refer to the section
“Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:


The services contained in this section enable the Owner to monitor and analyze web traffic and can be used
to keep track of User behavior.

Google Analytics 4

Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending
on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and
examine the use of this Application, to prepare reports on its activities and share them with other Google
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in
any data center or server. Users can learn more by consulting Google’s official documentation.

Personal Data processed: browser information; city; device information; latitude (of city); longitude (of city);
number of Users; session statistics; Trackers; Usage Data.

Place of processing: United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out.

Data transfer outside the EU

The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not
part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal
bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.

Data transfer abroad based on consent (this Application)

If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the
User has explicitly consented to such transfer, after having been informed of the possible risks due to the
absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this

Personal Data processed: various types of Data.

Heat mapping and session recording

Heat mapping services are used to display the areas of this Application that Users interact with most
frequently. This shows where the points of interest are. These services make it possible to monitor and
analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of
the User’s data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information

Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of
the service.

Place of processing: Malta – Privacy PolicyOpt Out.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other
contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the
User, as well as when the User interacted with it, such as by clicking on links included in the message.

MailerLite (UAB “Mailerlite”)

MailerLite is an email address management and message sending service provided by UAB “Mailerlite”.

Personal Data processed: email address.

Place of processing: Lithuania – Privacy Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have
    previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if
    the processing is carried out on a legal basis other than consent. Further details are provided in the
    dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain
    disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it
    to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict
    the processing of their Data. In this case, the Owner will not process their Data for any purpose other
    than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain
    circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive
    their Data in a structured, commonly used and machine readable format and, if technically feasible, to
    have it transmitted to another controller without any hindrance. This provision is applicable provided
    that the Data is processed by automated means and that the processing is based on the User’s consent,
    on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the
Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such
processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they
can object to that processing at any time without providing any justification. To learn, whether the Owner is
processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in
this document. These requests can be exercised free of charge and will be addressed by the Owner as early
as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to
possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of
public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with
additional and contextual information concerning particular Services or the collection and processing of
Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that
record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for
this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at
any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read
their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this
page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice
to Users via any contact information available to the Owner. It is strongly recommended to check this page
often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall
collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal
identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this
Application), which can include: the IP addresses or domain names of the computers utilized by the Users
who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the
method utilized to submit the request to the server, the size of the file received in response, the numerical
code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the
features of the browser and the operating system utilized by the User, the various time details per visit (e.g.,
the time spent on each page within the Application) and the details about the path followed within the
Application with special reference to the sequence of pages visited, and other parameters about the device
operating system and/or the User’s IT environment.


The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf
of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others,
determines the purposes and means of the processing of Personal Data, including the security measures
concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the
Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.


The service provided by this Application as described in the relative terms (if available) and on this

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all
current member states to the European Union and the European Economic Area.


Cookies are Trackers consisting of small sets of data stored in the User’s browser.


Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags
and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on
the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of
Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: September 15, 2022

Privacy Policy

Blocktopus Enterprise Ltd.,
2nd Floor O’Neal Marketing Associates Building,
Wickham’s Cay II
Road Town, Tortola
British Virgin Islands