Section a - introduction
1. Purpose
Loyal Primus LTD ("we", "our", or "the Company") is committed to protecting the privacy and confidentiality of our clients' personal information. This Privacy Policy outlines how we collect, use, disclose, and protect your data in the course of providing our financial services.
2. Definition of Personal Information
Personal information refers to any data that can identify you directly or indirectly, including but not limited to your name, identification number, address, contact details, financial information, and trading activity.
3. Consent
By using our services, visiting our website, or submitting your personal information, you agree to the terms of this Privacy Policy and consent to our collection, use, and disclosure practices.
Section b - collection of information
4. What We May Collect
We may collect the following types of personal information:
• Full name, date of birth, and gender
• Contact details (email, phone number, address)
• Identification documentation, as required under the Anti-Money Laundering and Counter terrorism Financing Act 2006 (“AML/CTF Act”), including:
i. Passport
ii. Driving License
iii. National Identity Card
iv. Utility Bills
v. Trust Deed
• Financial information (bank details, source of funds, credit card details)
• Employment and trading experience
• IP address, browser type, and usage data
We’re required by law to identify you if you’re opening a new account or adding a new signatory to an existing account. The AML/CTF Act requires us to sight and record details of certain documents (i.e. photographic and non-photographic documents).
• When necessary, we also collect information on the following individuals:
i. trustees
ii. partners
iii. company directors and officers
iv. officers of co-operatives and associations
v. client’s agents
vi. beneficial owners of the client; and
vii. persons dealing with us on a “one-off” basis.
5. How We Collect It
We may collect information:
• Directly from you through account registration, KYC forms, or correspondence
• Indirectly via website visits (cookies, tracking tools)
• From third parties such as payment providers, verification services, or public databases
6. Mandatory Information
Failure to provide mandatory identification and financial information may result in denial of account opening or suspension of services.
Section c - use of information
7. Why We Use Your Information
We use your personal data for the following purposes:
• To verify your identity and comply with KYC/AML requirements
• To enable secure access to our members area
• To open, operate, and manage your trading account
• To process transactions and provide customer support
• To help us monitor, evaluate and develop our products and services
• For internal audits, compliance, and risk management
• To send important service notifications and marketing materials
• To comply with legal and regulatory obligations
• Take measures to detect and prevent fraud, crime or other activity which may cause harm to our business or our products and services.
8. Marketing Communications
We may contact you with promotional materials unless you opt out. You may unsubscribe at any time via your account settings or by contacting support.
9. Automated Decisions
In certain cases, we may use automated tools to analyze account activity, detect fraud, or assess eligibility for offers. You have the right to request human intervention in such decisions.
Section d - sharing and disclosure
10. Who We Share With
We may share your information with our related entities and third parties that we outsource functions to or partner with, in certain limited situations where it’s necessary for us to provide our products and services or perform associated business activities.
We may disclose your information to:
• Our affiliated companies and partners
• Brokers and agents who refer your business to us
• Any person acting on your behalf, including your financial adviser, solicitor, settlement agent, accountant, executor, administrator, trustee, guardian or attorney
• Your employment referee (to confirm details about you)
• Regulatory and law enforcement authorities if required
• Auditors and legal advisors
• Other organizations who assist us to provide products and services by performing functions such as client contact, banking, payments, data processing, debt recovery, marketing and advertising, data analysis, business intelligence, website and technology services. They may also provide products and services that integrate with or complement our products and services.
• We take our obligations to protect your information extremely seriously and make every effort to deal only with parties who share and demonstrate the same attitude. Each of the third parties that we contract with is carefully selected and is only authorized to use your personal information in a secure way, that’s necessary for them to perform their services to us.
11. International Transfers
Your data may be stored or processed in jurisdictions outside of your country, including where data protection standards may differ. By using our services, you consent to such transfers.
12. Third-Party Restrictions
All third parties we share data with are contractually obligated to protect your information and may only use it for the intended purpose.
*Loyal Primus reserves the right to retain or access client data post-termination where legally or commercially necessary.
Section e - data integrity and security
13. Data Accuracy
Clients must ensure that the personal information they provide is accurate and up to date. We may use public databases or third-party sources to verify or update records.
14. Security Measures
We apply industry-standard security protocols, including:
• SSL encryption
• Firewalls and anti-virus systems
• Secure storage for physical and digital records
• Restricted employee access
15. Retention Period
We retain personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by law (minimum 5 years).
Section f – client rights
16. Access and Correction
You may request access to your personal data or request corrections by contacting support@loyalprimus.com. Requests will be fulfilled within a reasonable timeframe, subject to identity verification.
17. Right to Withdraw Consent
You may withdraw your consent for data use at anytime by contacting us. However, this may affect our ability to provide services to you. Withdrawal of consent will result in account suspension or termination where data is essential to service provision.
Section g – cookies and tracking
18. Use of Cookies
We use cookies and similar technologies to enhance user experience, analyze traffic, and deliver targeted content.
19. Managing Cookies
You may disable cookies via your browser settings, but doing so may limit access to some website features.
Section h – policy changes
20. Updates to the Policy
We reserve the right to amend this Privacy Policy at anytime. Updates will be posted on our website and will take effect immediately unless stated otherwise.