Effective Date: 1 January 2025 | Last Updated: 1 January 2025
N1CM ("we", "us", "our", or the "Company") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website at n1cm.com, open a trading account, or otherwise interact with our services. By accessing our website or using our services, you acknowledge that you have read and understood this Privacy Policy.
1. Information We Collect
1.1 Personal Information You Provide
When you register for an account, apply for a trading account, or contact us, we may collect the following categories of personal information:
- Identity Data: Full legal name, date of birth, nationality, gender, and a copy of your government-issued identification document (passport, national ID card, or driving licence).
- Contact Data: Email address, telephone number, residential address, and postal code.
- Financial Data: Bank account details, payment card information, source of funds, annual income, net worth, and employment status.
- Trading Experience Data: Information about your previous trading experience, investment knowledge, and risk tolerance as required for our suitability and appropriateness assessments.
- Tax Data: Tax identification number and country of tax residence, as required by applicable regulations including the Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA).
1.2 Information Collected Automatically
When you visit our website or use our trading platforms, we automatically collect certain technical information, including:
- Device Information: IP address, browser type and version, operating system, device type, screen resolution, and unique device identifiers.
- Usage Data: Pages visited, time spent on each page, click patterns, referral URLs, and navigation paths through our website.
- Trading Activity Data: Transaction records, order history, account balances, profit and loss statements, and trading platform usage patterns.
- Location Data: Approximate geographic location derived from your IP address.
- Cookie Data: Information collected through cookies and similar tracking technologies as described in our Cookie Policy.
1.3 Information from Third Parties
We may receive personal information about you from third-party sources, including:
- Identity verification and anti-money laundering (AML) screening providers.
- Credit reference agencies and fraud prevention services.
- Introducing Brokers or business partners who refer you to us.
- Payment service providers who process your deposits and withdrawals.
- Publicly available sources such as company registries and sanctions lists.
2. How We Use Your Data
We use the personal data we collect for the following purposes:
2.1 Account Opening and Management
- To verify your identity and conduct Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by applicable regulations.
- To open, maintain, and administer your trading account.
- To assess your suitability and appropriateness for our financial products and services.
- To process deposits, withdrawals, and other financial transactions.
2.2 Service Delivery
- To provide you with access to our trading platforms, tools, and educational resources.
- To execute your trades and manage your open positions.
- To send you account statements, trade confirmations, and other transactional communications.
- To provide customer support and respond to your enquiries.
2.3 Legal and Regulatory Compliance
- To comply with applicable laws, regulations, and regulatory requirements, including those imposed by financial regulators.
- To report suspicious transactions and comply with anti-money laundering and counter-terrorism financing obligations.
- To maintain records as required by financial services regulations.
- To respond to lawful requests from law enforcement or other governmental authorities.
2.4 Marketing and Communications
- To send you promotional materials, market analysis, educational content, and information about new products and services, subject to your marketing preferences.
- To personalise your experience on our website and trading platforms.
- To conduct surveys and collect feedback to improve our services.
2.5 Security and Fraud Prevention
- To detect and prevent fraud, unauthorised access, and other security incidents.
- To monitor trading activity for potential market abuse or manipulation.
- To protect the rights, property, and safety of our Company, our clients, and others.
3. Data Sharing and Disclosure
We do not sell your personal data to third parties. However, we may share your information in the following circumstances:
3.1 Service Providers
We share personal data with trusted third-party service providers who assist us in operating our business, including:
- Payment processors and banking partners for transaction processing.
- Identity verification and compliance screening providers.
- Cloud hosting and IT infrastructure providers.
- Customer relationship management (CRM) platform providers.
- Email and communication service providers.
- Analytics and data processing companies.
3.2 Regulatory and Legal Requirements
We may disclose your personal data to:
- Financial regulators and supervisory authorities in jurisdictions where we operate.
- Law enforcement agencies, courts, and governmental bodies in response to lawful requests or legal proceedings.
- Tax authorities as required under CRS, FATCA, and other applicable tax reporting regulations.
3.3 Business Partners
Where you have been referred to us by an Introducing Broker or affiliate partner, we may share relevant account information with that partner to the extent necessary for the administration of the referral relationship, subject to applicable data protection laws.
3.4 Corporate Transactions
In the event of a merger, acquisition, reorganisation, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity, provided that the successor entity agrees to handle your data in accordance with this Privacy Policy.
4. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse website traffic, and personalise content. Cookies are small text files stored on your device when you visit our website.
We use the following types of cookies:
- Essential Cookies: Required for the basic operation of our website and cannot be disabled.
- Performance Cookies: Help us understand how visitors interact with our website by collecting anonymous statistical data.
- Functionality Cookies: Remember your preferences and settings to provide a personalised experience.
- Targeting Cookies: Used to deliver relevant advertisements and measure the effectiveness of our marketing campaigns.
For detailed information about the cookies we use and how to manage your cookie preferences, please refer to our Cookie Policy.
5. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- Encryption: All data transmitted between your browser and our servers is encrypted using industry-standard SSL/TLS encryption protocols.
- Access Controls: Access to personal data is restricted to authorised personnel who require it for legitimate business purposes, with role-based access controls and multi-factor authentication.
- Firewalls and Intrusion Detection: We deploy advanced firewalls, intrusion detection systems, and continuous monitoring to protect our network infrastructure.
- Data Minimisation: We collect and retain only the personal data that is necessary for the purposes described in this Privacy Policy.
- Regular Audits: We conduct regular security assessments, vulnerability testing, and compliance audits to ensure the effectiveness of our security controls.
- Employee Training: All employees who handle personal data receive regular training on data protection and information security best practices.
While we take all reasonable precautions to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee the absolute security of your personal information, and any transmission is at your own risk.
6. Data Retention
We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. Specifically:
- Active Accounts: Your data is retained for the duration of your account relationship with us.
- Closed Accounts: Following account closure, we retain your data for a minimum period of five (5) years, or longer if required by applicable regulations (typically up to seven years for financial records).
- Marketing Data: If you unsubscribe from marketing communications, we will retain a record of your opt-out to ensure we respect your preferences.
- Unsuccessful Applications: Data related to account applications that were not approved is retained for a minimum of one (1) year.
7. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data:
- Right of Access: You have the right to request a copy of the personal data we hold about you and information about how we process it.
- Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
- Right to Erasure: You have the right to request deletion of your personal data in certain circumstances, subject to our legal and regulatory obligations to retain certain records.
- Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
- Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
- Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
- Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
- Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data infringes applicable data protection laws.
To exercise any of these rights, please contact us using the details provided in Section 8 below. We will respond to your request within thirty (30) days, or within such other timeframe as required by applicable law. We may need to verify your identity before processing your request.
8. International Data Transfers
Your personal data may be transferred to, stored in, and processed in countries outside your country of residence. When we transfer personal data internationally, we ensure that appropriate safeguards are in place, including:
- Standard Contractual Clauses approved by the relevant regulatory authorities.
- Transfers to countries that have been deemed to provide an adequate level of data protection.
- Binding Corporate Rules where applicable.
9. Children's Privacy
Our services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will take immediate steps to delete such data from our records.
10. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated policy on our website with a revised "Last Updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.
11. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:
We aim to resolve any privacy-related concerns promptly and fairly. If you are not satisfied with our response, you have the right to escalate your concern to the relevant data protection supervisory authority in your jurisdiction.
