1. Who We Are

NeuralFX Ltd ("we", "us") is the data controller for personal data processed via https://neuralfx.online/. Our registered address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

2. Data We Collect

2.1 Data you provide directly

• Identity data: first name, last name, username or alias.
• Contact data: email address, telephone number (if provided).
• Financial data: payment card details (tokenised via Stripe/PayPal — we never store raw card numbers), cryptocurrency wallet address (for fund deposits/withdrawals), billing address.
• Investment data: investment amount, plan selected, withdrawal instructions.
• Trading data: MT5 account number (for licence activation and fund management).
• Communications: messages you send us via email, support chat, or contact forms.

2.2 Data collected automatically

• Technical data: IP address, browser type and version, operating system, device identifiers.
• Usage data: pages visited, referral URLs, time on page, click behaviour (via analytics).
• Log data: server access logs including timestamp, IP, resource requested, HTTP status code.

2.3 Data from third parties

• Payment confirmation and transaction IDs from Stripe and PayPal.
• Publicly available blockchain transaction data (for crypto payments).

3. How We Use Your Data

Purpose	Data Used
Licence delivery & activation	Name, email, MT5 account number, Licence Key
Payment processing	Financial data, email, billing address
Fund management & distributions	Identity, investment, MT5, payment data
Customer support	Identity, contact, communications data
Fraud prevention & security	IP, technical, financial data
Legal & regulatory compliance	Identity, financial, investment data
Service improvement & analytics	Usage, technical data (aggregated/anonymised where possible)
Marketing communications (with consent)	Name, email

4. Legal Basis for Processing (UK GDPR Art. 6)

• Contract performance — processing necessary to deliver your licence or manage your fund investment.
• Legitimate interests — fraud prevention, security, analytics, service improvement.
• Legal obligation — AML, tax, and regulatory record-keeping requirements.
• Consent — marketing emails (withdrawable at any time via unsubscribe link or by contacting us).

5. Third Parties & Data Processors

We share your data only where necessary with the following trusted processors, each bound by data processing agreements:

• Stripe, Inc. — payment processing (card payments). Privacy policy: stripe.com/gb/privacy.
• PayPal Holdings, Inc. — payment processing. Privacy policy: paypal.com/uk/legalhub/privacy-full.
• MT5 Broker (Vantage Markets or nominated broker) — trading account management for Fund. The broker operates under its own regulatory and privacy framework.
• Hosting / VPS provider — server infrastructure within the EEA or under Standard Contractual Clauses.
• Email service provider — transactional and marketing emails (e.g., SMTP2GO, SendGrid).
• Telegram (Telegram FZ-LLC) — optional notification delivery if you opt in to our Telegram bot.

We do not sell, rent, or trade your personal data to any third party for marketing purposes.

6. Data Retention

• Customer account data: retained for the duration of your account plus 7 years (UK tax and company law obligations).
• Transaction records: 7 years from transaction date.
• Support communications: 2 years from last contact.
• Marketing consent records: until consent is withdrawn, plus 1 year thereafter.
• Server access logs: 90 days.

7. Cookies

We use the following categories of cookies:

• Strictly necessary: session management, security tokens, CSRF protection. These cannot be disabled.
• Functional: remembering your preferences (theme, language). Enabled by default.
• Analytics: understanding how visitors use our site (e.g., page views, bounce rate). Disabled until you consent.
• Marketing/targeting: retargeting pixels (e.g., Facebook Pixel, Google Ads). Disabled until you consent.

You can manage cookie preferences at any time via the Cookie Settings panel.

8. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

• Access: request a copy of the data we hold about you (Subject Access Request).
• Rectification: ask us to correct inaccurate or incomplete data.
• Erasure ("Right to be Forgotten"): request deletion of your data where there is no compelling reason for continued processing.
• Restriction: ask us to pause processing while a dispute is resolved.
• Portability: receive your data in a structured, machine-readable format.
• Objection: object to processing based on legitimate interests or for direct marketing (absolute right).
• Withdraw consent: where processing is based on consent, you may withdraw at any time without affecting prior processing.

To exercise any right, email privacy@neuralfx.online. We will respond within 30 days. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

9. International Data Transfers

Where personal data is transferred outside the UK or EEA, we ensure adequate protection is in place via: UK Adequacy Regulations, Standard Contractual Clauses (SCCs), or the UK International Data Transfer Agreement (IDTA). Details of transfer safeguards are available on request.

10. Security Measures

We implement industry-standard technical and organisational measures to protect your data, including: TLS 1.2+ encryption in transit, AES-256 encryption at rest, access controls and role-based permissions, regular security audits, and staff data protection training. However, no internet transmission is 100% secure; you share data at your own risk.

11. Children's Data

Our services are not directed at persons under the age of 18. We do not knowingly collect personal data from minors. If you believe a child has provided us with personal data, please contact us immediately and we will delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified by email or a prominent notice on our website. The "Last updated" date at the top of this page reflects the most recent revision.

13. Data Protection Officer & Contact

Data Protection Officer
NeuralFX Ltd
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Email: privacy@neuralfx.online