Effective date: July 22, 2025
1) Data controller and contact
Smart Solution (digital operator; see Terms) is the data controller for processing related to the Platform.
Contact email: smart21trading.solution@gmail.com
2) Data we collect
- Identification & contact: name, email, phone (if applicable), country.
- Account & verification: credentials, 2FA, KYC/AML documents (if requested).
- Financial/operational: deposit/withdrawal history (e.g., USDT/BSC), wallet addresses, transactions, audit logs.
- Technical: IP, device identifiers, logs, cookies, and analytics.
- Support & marketing: communications, surveys, referrals.
3) Purposes and legal bases
- Provide the service (account management, dashboard, integration with MT5 or providers): contract performance and legitimate interests.
- Security & fraud: authentication, 2FA, detection and prevention (AML/KYC compliance): legal obligation and legitimate interests.
- Customer support & operational communications (change notices, maintenance): contract performance.
- Product improvement & analytics (logs, cookies, measurement): legitimate interests.
- Responsible marketing (financial education, transparency, verified content; exclusion of “get-rich-quick” claims): consent where required by law.
4) Cookies and similar technologies
We use strictly necessary, analytics, and functionality cookies. You can configure preferences from the banner or your browser settings. Blocking cookies may impact functionality.
5) Sources and accuracy
Data is obtained directly from you (registration, KYC, support) and automatically (logs, cookies). You are responsible for ensuring information is accurate and up to date.
6) Transfers and third parties
We may share data with providers that support us in:
- Infrastructure & security (hosting, monitoring, DDoS, 2FA).
- Payments/crypto and third-party brokers (e.g., integration with Exness or other regulated providers) for routing/viewing trades and reconciliations.
- Analytics & responsible marketing (no data sales; campaigns focused on education and transparency).
We sign data processing agreements with providers, imposing confidentiality and appropriate security measures. Some transfers may involve international data flows; in such cases, we apply safeguards (e.g., Standard Contractual Clauses or other approved mechanisms).
7) Retention
We retain data while the account is active and for the additional time necessary for:
- Legal/accounting/AML compliance;
- Handling claims;
- Defense of rights.
Afterwards, we anonymize or securely delete it.
8) Security
We apply layered security controls, including 2FA, encryption in transit, audit logs, and role-based segregation. No system is infallible; we ask for your cooperation (best practices, updated devices, safeguarding keys).
9) Your privacy rights
Depending on your jurisdiction, you may have rights of access, rectification, update, portability, objection, restriction, and erasure.
You can exercise them by emailing smart21trading.solution@gmail.com from the address associated with your account. We will process your request within reasonable timeframes, verifying identity and assessing legal exceptions (e.g., AML retention).
10) Minors
The Platform is not directed to minors. If we detect minor accounts, we will close them and delete non-essential data.
11) Responsible marketing and communications
We will respect your preferences. You may opt out of promotional communications. Our marketing focuses on education, evidence-based results, and transparency; we avoid prohibited claims (e.g., “get rich effortlessly”).
12) Changes to this Policy
We may update this Policy to reflect operational, legal, or security changes. We will notify you by reasonable means (dashboard, email) when changes are material. The current version will show the effective date.
13) Contact
For privacy questions: smart21trading.solution@gmail.com
