Privacy Policy

1. Introduction

RoxyTrade B.V. ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our trading platform and services.

We respect your privacy and are committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

2. Information We Collect

We collect several types of information from and about users of our Services:

Personal Identification Information

• Full name, date of birth, and contact details
• Government-issued identification numbers
• Proof of address and identity documents
• Tax identification numbers

Financial Information

• Bank account details and payment card information
• Transaction history and trading activity
• Source of wealth and funds information
• Credit history and financial background

Technical and Usage Data

• IP address, device information, and browser type
• Cookies and similar tracking technologies
• Platform usage patterns and preferences
• Log files and system event information

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide and maintain our trading services
• To verify your identity and comply with KYC/AML regulations
• To process transactions and manage your account
• To communicate with you about platform updates and security
• To improve our services and develop new features
• To prevent fraud, money laundering, and other illegal activities
• To comply with legal obligations and regulatory requirements
• To personalize your trading experience

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contractual Necessity: To fulfill our obligations under our Terms of Use
• Legal Obligation: To comply with financial regulations and anti-money laundering laws
• Legitimate Interests: To operate and improve our services, prevent fraud, and ensure security
• Consent: For marketing communications and certain optional features

5. Data Sharing and Disclosure

We may share your information with:

Service Providers

• Payment processors and banking partners
• Cloud hosting and infrastructure providers
• Customer support and communication services
• Analytics and monitoring tools

Legal and Regulatory Authorities

• Financial regulatory bodies and tax authorities
• Law enforcement agencies when required by law
• Courts and legal proceedings

Business Transfers

• In connection with mergers, acquisitions, or asset sales
• As part of due diligence processes

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International Data Transfers

Your personal data may be transferred to, and processed in, countries outside of the European Economic Area (EEA). When we transfer your data internationally, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the European Commission
• Standard contractual clauses approved by the EU
• Binding corporate rules for intra-group transfers
• Certification under Privacy Shield framework (where applicable)

7. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. These include:

• Encryption of data in transit and at rest
• Multi-factor authentication and access controls
• Regular security testing and vulnerability assessments
• Employee training on data protection
• Physical security measures at our facilities
• Incident response and business continuity plans

8. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Typically, we retain personal data for:

• Account data: 5 years after account closure
• Transaction records: 7 years for tax and regulatory purposes
• KYC/AML documentation: 5 years after business relationship ends
• Marketing data: Until consent is withdrawn

9. Your Data Protection Rights

Under data protection laws, you have rights including:

• Right to Access: Obtain a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data
• Right to Restriction: Limit processing of your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time

To exercise any of these rights, please contact us using the details below.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our Services and hold certain information. Cookies are files with small amounts of data which may include an anonymous unique identifier.

Types of Cookies We Use

• Essential Cookies: Required for platform functionality
• Security Cookies: Used for authentication and security
• Preference Cookies: Remember your settings and preferences
• Analytics Cookies: Help us understand how users interact with our platform
• Marketing Cookies: Track effectiveness of advertising campaigns

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

11. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children under 18. If you become aware that a child has provided us with personal data, please contact us immediately.

If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

12. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by:

• Posting the new Privacy Policy on this page
• Sending you an email notification
• Updating the "Last updated" date at the top of this Privacy Policy
• Providing in-platform notifications for significant changes

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13. Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact our Data Protection Officer at:

You also have the right to make a complaint at any time to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), the Dutch supervisory authority for data protection issues.