Privacy Policy

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Introduction

This Policy is in line with national and international legal frameworks, taking into account the nature, scope, context, and purposes of processing, as well as the risks to the rights and freedoms of individuals. First Notch has implemented appropriate technical and organizational measures to ensure compliance with relevant data protection legislations. This Policy serves as the foundation of First Notch’s commitment to such legislation and is reviewed and updated regularly.

This Policy provides data subjects with clear information on how First Notch collects personal data, how it is used, and with whom it may be shared.

We kindly ask you to read this Privacy Policy carefully, as protecting your privacy online is of utmost importance to us. It also contains important details about who we are, how and why we collect, store, use, and share your personal information, your rights regarding your data, and how you can contact us or the relevant supervisory authorities if you have a concern or complaint.

Who we are?

First Notch (“us”, “our”, or “we”) collects, uses, and is responsible for certain personal information about you. We act as the “controller” of that personal information for the purposes of applicable laws.

Data Controllers and Contracting Parties

Regardless of whether you reside inside or outside the “Designated Countries”, First Notch will be the controller of your personal data that is provided to us, collected by us or on our behalf, or processed in connection with our services and regulated activities.

Whether information has to be provided by you, and if so why

The provision of your personal data is necessary for us to deliver our services. At the point of collecting information from you, First Notch will clearly inform you whether the information is mandatory or optional.

Information collected by us

In the course of your registration as a client, signing up for a demo or live account with First Notch, filling in any form on our website, subscribing to our services, news, or offers, opting in for marketing communications, or posting material, the following information about you (“Your Data”) will be collected and stored for administrative, service-related, and/or legal purposes.

We will limit the collection of personal information to what is necessary to operate our business and carry out our regulated activities, with the goal of providing you with superior service.

Information that you provide to us directly may include:

Personal information such as name, address, personal registration number, national identification number, passport number, and email address.
Financial information, trading experience, and employment information, collected for appropriateness assessments.

The meaning of data “provided to” First Notch is not limited to information you submit directly. It also includes personal data resulting from observation of your activities (for example, when using a device or service).

This may include:

History of website usage or search activities, details of your visits to our website, and communication data.
Traffic and location data.
Website traffic pattern information, such as IP address, operating system, and browser type, which are used for system administration and reporting in aggregate form. This data is masked or aggregated so that individual users cannot be identified.
Communications between you and First Notch via live chat, email, or telephone calls.

Your email address may be used by First Notch in relation to its products and services (including any marketing campaigns). If you do not wish to receive such marketing materials or communications, you may opt out at any time by clicking “unsubscribe” or by sending an email request to support@thetrademasters.com.

The type of data collected and purpose of collection

The type of data we collect along with the purpose for collection is listed below:

Personal data type:	Purpose:
Personal information such as gender, name, date of birth and address	To meet our anti money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. To verify your identity using our verification processes.
Contact information (email address and phone number)	In order to send you correspondence in relation to the services provided and to fulfil our regulatory and compliance obligations.
Employment information, financial information	In order to comply with KYC obligations and in order to meet our regulatory obligations relating to assessing the appropriateness of our products and services.
Ethnicity, citizenship and social security numbers or national identity and passport	In order to comply with KYC and regulatory trade reporting and other AML obligations.
Proof of photo ID, address verification	In order to comply with KYC and regulatory trade reporting and other AML obligations.
Unique device number (IP address) and device information including version of web browser you use	When you visit our website, navigate through the pages or fill in any forms, we may collect your unique device number or IP address in order to set up your profile.
Financial sanctions and credit header information	In order to perform our electronic AML screening checks and to comply with other fraud detection policies. This may generate further information on your credit history, criminal convictions or political interests leading to us making decisions based on the results of these checks.

How we use your personal information

We use information held about you in the following ways:

To ensure that the content on our website is presented in the most effective manner and to continuously improve the quality of our website.
To communicate with you, respond to your inquiries, and provide you with the products and services you request. Where you have agreed to be contacted, we may also provide information about products and services that we believe may be of interest to you.
To manage and administer the products and services provided to you.
To keep you informed as a client about updates, changes to our services, and other relevant matters.
To provide, improve, test, and monitor the effectiveness of our services.
To develop and test new products, features, and solutions.
To monitor important metrics such as the total number of visitors, traffic patterns, and demographics.
To diagnose or fix technical problems and ensure smooth operation of our systems.
To fulfill our obligations arising from any contracts entered into between you and First Notch.
To use your data or allow carefully selected third parties and processors to use it, in order to provide you with information about goods and services that may interest you. You may be contacted about these by email.
To notify you about updates or changes to our website.
To send newsletters or information about other opportunities that we believe may be of interest to you. Such communication will only be sent if you have indicated that you wish to receive it. You may opt out at any time by clicking “unsubscribe” or by sending an email request to support@thetrademasters.com.
To promote safety and security. We use the information we collect to help verify accounts and activities, and to maintain the integrity of our services. This includes investigating suspicious activity or potential violations of our terms or policies. First Notch is committed to protecting your account through dedicated IT teams, automated systems, and advanced technologies such as encryption.

Who we share your personal information with?

We will not rent or sell your information to third parties outside of First Notch (or the group of companies of which First Notch is part of) without your consent. We also impose strict restrictions on how our processors may use and disclose the data we provide. Below are the categories of third parties with whom we may share information:

Service providers and business partners: We transfer information to service providers (processors) and partners who support our operations globally. These may include providers of technical infrastructure, trading platforms, analytics tools to measure service effectiveness, client service and support, client onboarding and identity verification (including PEP and sanctions checks), marketing and design services, website management, software services, and business development support.
Cross-border transfers: We may need to transfer personal data to recipients outside of your country of residence. This can include dealings with foreign public entities (only when legally required), outsourcing to service providers located abroad, or processing data in other jurisdictions (for example, cloud services, identity verification, or remote access to our web services).
Legal obligations: We may share your personal data when required by law, to comply with legal obligations, or to respond to requests from competent authorities or courts. This may include authorities or courts located outside of your country of residence.
Measurement and analytics services: We may share non-personally identifiable information with partners that provide analytics services, such as Google Analytics. Personally identifiable information (e.g., name or email address) is not shared with advertising, measurement, or analytics partners.

First Notch conducts extensive due diligence before engaging any processor, ensuring that they provide appropriate safeguards, including expert knowledge, data governance, data security, cyber resilience, reliability, and sufficient resources to meet data protection requirements and to protect the rights of data subjects.

The processor’s adherence to a service-level contract is used to demonstrate compliance with the controller’s obligations.

All processing carried out by our processors is governed by a binding contract between the processor and First Notch.

This data sharing with our processors enables us to carry out our business activities, including client onboarding, KYC procedures, assessing the appropriateness of our products and services, and providing client support. Some processors may be located outside your country of residence; if the recipient is in a jurisdiction that does not ensure an adequate level of data protection, the transfer will only occur under a written agreement with appropriate safeguards.

We will also share personal information with law enforcement or other authorities if required by applicable law.

Cookie Data

We use cookies and similar technologies to provide and support our Services. When you use our website we will use cookies to distinguish you from other users of our website.

For more information about cookies and how we use them, please read our Cookies Policy.

How our global services operate

Transfer of your information out of your country of residence

Information collected within your country of residence may be transferred to other countries for the purposes described in this policy, based on the lawful grounds of contractual necessity and compliance with our legal obligations.

When data is transferred outside your country of residence, First Notch and our processors use standard contractual clauses approved by relevant authorities and may adopt other measures permitted under applicable laws. Where required, we may also obtain your consent to legitimize such data transfers.

How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others by request:

First Notch may respond to legal requests when we have a good-faith belief that the response is required by law in a specific jurisdiction, affects users in that jurisdiction, and aligns with internationally recognized standards.
We may act in good faith when it is necessary to: detect, prevent, and address fraud, unauthorized use of our services or products, violations of our terms or policies, or other harmful or illegal activity; protect First Notch (including our rights, property, or services), you, or others, including as part of investigations or regulatory inquiries; or prevent death or imminent bodily harm. For example, we may provide information to, and receive information from, third parties regarding account reliability to prevent fraud, abuse, or other harmful activity on and off our services.

Information we receive about you, including financial transaction data such as deposits and withdrawals, may be accessed and preserved for an extended period when required by legal requests or obligations, governmental investigations, or investigations of potential violations of our terms or policies, or to prevent harm. We also retain information from accounts disabled for terms violations for at least one year to prevent repeat abuse or other violations.

Your rights

Under the national and international data privacy legal framework you have a number of important rights.

Fair processing of information and transparency over how we use your personal information.
The right to access personal data: via a Subject Access Request. Your request should be made in writing to support@thetrademasters.com. We may ask you for proof of identity before providing you with the data. There is usually no charge for such requests; however, in limited circumstances we may be able to charge an administrative fee (and we will inform you in response to your request if that is the case).
The right to request that your personal data is corrected if it is found to be inaccurate: require us to correct any mistakes in your information which we hold.
The right to request that your personal data is erased where it is no longer necessary. In some circumstances this right may not apply (e.g., if there is some other compelling reason for us to keep or process your data, and we will inform you in response to your request if that is the case).
Right to data portability: to receive the personal information concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party (another controller) in certain situations.
The right to withdraw consent to processing at any time, where relevant, i.e., where we are relying on your consent to process the data and not another legal reason for processing.
The right to object at any time to processing of personal information concerning you for direct marketing.
The right not to be subject to a decision which is based solely on automated processing, including profiling which produces legal effects concerning you or significantly affects you.
The right to object in certain other situations to our continued processing of your personal information.
Otherwise restrict our processing of your personal information in certain circumstances.

If you would like to exercise any of those rights, please:

Email us at support@thetrademasters.com.
Provide enough information to identify you (e.g., account number, username, registration details).
Provide proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill).
Let us know the information to which your request relates, including any account or reference numbers, if you have them.

If you would like to unsubscribe from any emailing or marketing communications, you can also click on the ‘unsubscribe’ button at the bottom of the email or send an email to support@thetrademasters.com stating so.

Legal basis for processing personal data

Reasons we can collect and use your personal information: There must be a lawful basis for all processing of personal data (unless an exemption or derogation applies). We rely on:

Contractual necessity: Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract to conduct regulated activities, when processing is necessary for the entry into, or performance of a contract with the data subject, or in order to take steps at their request prior to the entry into a contract.
Compliance with legal obligations: Processing is necessary for compliance with our legal obligations. First Notch has the necessity for compliance with a legal obligation.
Legitimate interest: Data will only be processed where it is necessary for the purposes of the legitimate interests pursued by First Notch, and these interests or fundamental rights are not overridden by the interests, rights, and freedoms of the data subject, and the processing would not cause unwarranted harm. For instance, it is a legitimate interest of First Notch to process personal data on data subjects in order to expand the business, develop new business relations, prevent fraud, maintain the security of our systems if/when necessary, and enhance, modify, or improve our services. The data subject must be given information on the specific legitimate interest if processing is based on this provision.

Keeping your personal information secure

Your Data is stored and kept confidential according to the legislation on protection of personal data and processing thereof applicable in the jurisdiction in which First Notch, with which you have signed up, is located.

We have appropriate security measures in place to prevent personal information from being accidentally lost, misused, modified, disclosed, or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How long your personal information will be kept

Data retention:

You can close your account at any time, but for audit trail purposes, First Notch shall hold personal data for a period of at least seven (7) years after closing the account in order to comply with our record-keeping obligations under applicable Money Laundering Regulations.

At the end of that period, we will delete all personal data relating to you, unless a legal requirement obliges us to keep the data for a longer period, or you have expressly consented to your data being held for an extended period.

Your right to request the deletion of your data:

You have the right to request the deletion of your personal data from our database. In that case, this will result in the automatic closure of your account, and we will remove your personal data from active processing. However, we will still be required to retain your personal data to comply with legal and regulatory requirements, as well as our internal compliance requirements related to record retention.

How to request the deletion of your data:

Email us at support@thetrademasters.com.
Share with us enough information to identify you (e.g., account number, username, registration details).
Share with us proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill).
Share with us the information to which your request relates, including any account or reference numbers, if you have them.

What happens in the event of a change of control?

If we sell or otherwise transfer part or all of First Notch or our assets to another organization (e.g., in the course of a merger, acquisition, bankruptcy, dissolution, or liquidation), your information, such as name, email address, and any other information collected through our services, may be among the items sold or transferred. You will continue to own your user content. The buyer or transferee will be required to honour the commitments we have made in this Privacy Policy.

How to complain?

We hope that our Data Protection Officer, client support, or compliance team can resolve any query or concern you raise about our use of your information.

If you are not satisfied with our response, or believe we are not processing your personal data in accordance with the law, you can escalate your complaint to the data protection supervisory authority in your jurisdiction.

How to contact us?

If you wish to contact us with any queries, concerns, or complaints, you can email us at support@thetrademasters.com.

National requirements

First Notch shall comply with all national and international data protection-related legislation.

If applicable national legislation requires a higher level of protection for personal data than our policies or guidelines, such stricter requirements will be complied with. If First Notch policies or guidelines are stricter than the local legislation, our policies and guidelines will be followed.

Changes to this privacy notice

This privacy policy was published in September 2025 and last updated in September 2025.

We may change this privacy policy from time to time, and when we do, we will inform you via our website or via email.

Do you need extra help?

If you would like this notice in another format (for example: audio, large print, braille), please contact us (see ‘How to contact us’ above).

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