Privacy Policy
GDPR Compliant Data Protection for Elite Clients
Data Controller Information
Company Details
Legal Name: CryptoElite Pro Limited
Registration: CEP-2024-ELITE-7892
FCA Reference: FRN-ELITE-789456
ICO Registration: ZA999888777
Contact Details
Address: 123 Crypto Elite Tower
Canary Wharf, London EC1V 2NX, UK
DPO Email: [email protected]
Privacy Email: [email protected]
1. Introduction
CryptoElite Pro Limited ("we", "our", "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, share, and protect your personal information in compliance with:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- FCA regulations and guidelines
- Anti-Money Laundering regulations
- International data transfer requirements
Your Rights: Under GDPR, you have extensive rights over your personal data. See Section 8 for details.
2. Personal Data We Collect
Identity & Contact Data
- • Full name and title
- • Date of birth and nationality
- • Contact details (email, phone, address)
- • Government-issued ID documents
- • Professional credentials
- • Beneficial ownership information
Financial Data
- • Bank account details
- • Source of funds documentation
- • Wealth verification
- • Investment experience
- • Risk tolerance assessment
- • Transaction history
Technical Data
- • IP address and geolocation
- • Device and browser information
- • Session logs and timestamps
- • Security event data
- • Platform usage analytics
- • API access patterns
Compliance Data
- • AML/KYC verification results
- • PEP and sanctions screening
- • Enhanced due diligence records
- • Ongoing monitoring data
- • Suspicious activity reports
- • Regulatory correspondence
3. Legal Basis for Processing
Legal Obligation
Processing required to comply with FCA regulations, AML/KYC requirements, tax reporting, and other legal obligations.
Contract Performance
Processing necessary to provide our cryptocurrency services, execute transactions, and manage your account.
Legitimate Interests
Risk management, fraud prevention, security monitoring, and service improvement where not overridden by your rights.
Consent
Marketing communications, optional analytics, and non-essential processing where you have provided explicit consent.
4. How We Use Your Personal Data
Service Provision
- Account opening and management
- Transaction processing and settlement
- Portfolio management and reporting
- Customer support and communications
- Platform access and authentication
Regulatory Compliance
- KYC verification and ongoing monitoring
- AML screening and transaction monitoring
- Regulatory reporting and disclosures
- Tax reporting and documentation
- Audit and examination support
Risk Management
- Fraud detection and prevention
- Security monitoring and threat detection
- Risk assessment and profiling
- Market abuse surveillance
- Cybersecurity incident response
5. Data Sharing and Disclosure
Regulatory Authorities
We may share data with FCA, HMRC, law enforcement, courts, and other regulatory bodies as required by law.
Service Providers
Custody providers, exchanges, payment processors, IT services, and professional advisors under strict confidentiality agreements.
Group Companies
Other entities within the CryptoElite Pro group for operational, risk management, and compliance purposes.
We DO NOT Sell Data
We never sell, rent, or trade personal data to third parties for marketing or commercial purposes.
6. International Data Transfers
Transfer Safeguards
When we transfer personal data outside the UK/EEA, we ensure adequate protection through:
- • Adequacy Decisions: Transfers to countries with adequate protection
- • Standard Contractual Clauses: EU-approved contract terms
- • Transfer Impact Assessments: Risk evaluation for each transfer
- • Binding Corporate Rules: Internal data protection standards
Current transfer destinations include: United States (cloud services), Singapore (custody), Switzerland (compliance services).
7. Data Security
Technical Measures
- • End-to-end encryption
- • Multi-factor authentication
- • Network security monitoring
- • Regular security audits
- • Secure data centers
- • Backup and recovery systems
Organizational Measures
- • Staff training and vetting
- • Access controls and permissions
- • Data minimization policies
- • Incident response procedures
- • Regular compliance reviews
- • Third-party security assessments
Certifications: ISO 27001, SOC 2 Type II, Cyber Essentials Plus
8. Your Data Protection Rights
Right of Access
Request a copy of the personal data we hold about you and information about how we process it.
Right to Rectification
Request correction of inaccurate or incomplete personal data.
Right to Erasure
Request deletion of personal data in certain circumstances (subject to legal retention requirements).
Right to Restrict Processing
Request limitation of processing in specific situations while maintaining data storage.
Right to Data Portability
Request transfer of your data in a structured, machine-readable format.
Right to Object
Object to processing based on legitimate interests or for direct marketing purposes.
How to Exercise Your Rights
To exercise any of these rights, contact our Data Protection Officer:
- • Email: [email protected]
- • Response Time: Within 1 month (complex requests may take up to 3 months)
- • Verification: Identity verification required for all requests
- • Fee: Usually free (excessive requests may incur reasonable fees)
9. Data Retention
Regulatory Requirements
Financial records: 7 years after relationship ends (FCA requirement)
AML/KYC data: 5 years after relationship ends (MLR 2017)
Transaction records: 5-7 years depending on asset type
Operational Data
Account data: Duration of relationship + 7 years
Communication records: 7 years
Technical logs: 2 years (unless longer retention required)
Marketing Data
Consent-based: Until consent withdrawn
Legitimate interests: 3 years since last interaction
Suppression lists: Maintained indefinitely
10. Changes to Privacy Policy
We may update this Privacy Policy periodically to reflect changes in:
- Legal or regulatory requirements
- Our services or business practices
- Industry standards or best practices
- Technology or security measures
We will notify you of material changes via email or platform notifications at least 30 days before implementation.
11. Complaints and Supervisory Authority
Right to Complain
If you believe we have not handled your personal data properly, you can complain to:
Information Commissioner's Office (ICO)
Website: ico.org.uk
Phone: 0303 123 1113
Post: Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Contact Us First
We encourage you to contact us first so we can try to resolve your concerns directly.
DPO: [email protected]
Last Updated: December 2024 | Version 2.1
© 2024 CryptoElite Pro Limited. All Rights Reserved.