We take your privacy seriously. This policy explains what personal data we collect, why we collect it, how we use it, and your rights regarding your data under GDPR and UK data protection law.
Unicorn Traders Ltd ("Unicorn Traders", "we", "us") is the data controller responsible for your personal data. We are registered in England and Wales (Company No. 12345678) and authorised by the Financial Conduct Authority (FRN: 987654).
This Privacy Policy applies to data collected through our website, trading platform, mobile applications, and any communications you have with us. It should be read alongside our Terms and Conditions and Cookie Policy.
We are committed to protecting your privacy and handling your data with care, transparency, and in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
We collect different types of personal data depending on how you interact with us:
We use your personal data for the following purposes:
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Account creation and management | Identity, contact data | Contract performance |
| KYC/AML verification | Identity, financial data | Legal obligation |
| Providing trading services | All account data | Contract performance |
| Processing transactions | Financial, identity data | Contract performance |
| Fraud prevention & security | Technical, transaction data | Legitimate interests |
| Regulatory reporting | Trading, financial data | Legal obligation |
| Platform improvement | Usage, technical data | Legitimate interests |
| Marketing communications | Contact, preference data | Consent |
| Customer support | All relevant data | Contract performance |
We process your personal data under one or more of the following legal bases as defined by UK GDPR:
We may share your personal data with third parties in the following circumstances:
We work with carefully selected third-party providers who process data on our behalf, including payment processors, identity verification services, cloud infrastructure providers, customer support tools, and marketing platforms. All processors are bound by data processing agreements and required to maintain appropriate security standards.
We are required to share certain data with the FCA, HMRC, the National Crime Agency, and other regulatory bodies as required by law. We may also disclose data in response to valid court orders or legal proceedings.
In the event of a merger, acquisition, or sale of our business, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.
We do not sell your personal data to third parties. We do not share your data with third parties for their independent marketing purposes without your explicit consent.
Some of our service providers are based outside the UK or European Economic Area (EEA). Where we transfer data internationally, we ensure appropriate safeguards are in place, including:
You may request details of specific transfer safeguards applicable to your data by contacting our Data Protection Officer.
We retain personal data for as long as necessary to fulfil the purposes for which it was collected, subject to applicable legal and regulatory requirements:
| Data Category | Retention Period | Legal Basis |
|---|---|---|
| Account & identity documents | 5 years after account closure | AML Regulations 2017 |
| Transaction records | 5 years from transaction date | MiFID II / FCA Rules |
| Communications (calls, emails) | 5 years from recording date | FCA COBS Rules |
| Marketing preferences | Until consent withdrawn + 1 year | Consent |
| Technical / access logs | 12 months | Legitimate interests |
| Complaint records | 3 years from resolution | FCA DISP Rules |
After the retention period expires, data is securely deleted or anonymised in accordance with our data destruction policy.
Our website and platform use cookies and similar technologies. We use these to ensure the platform functions correctly, to remember your preferences, to measure and analyse usage, and to deliver relevant content.
You can manage your cookie preferences through our cookie consent tool or your browser settings. Please note that disabling certain cookies may affect platform functionality. See our full Cookie Policy for details.
Under UK GDPR, you have the following rights regarding your personal data:
To exercise any of these rights, contact our Data Protection Officer at dpo@newdemo.com or in writing. We will respond within 30 days. If you are dissatisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we discover that a minor has provided us with personal data, we will take steps to delete such information immediately. If you believe we have inadvertently collected data from a minor, please contact us immediately at dpo@newdemo.com.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes via email and/or in-platform notification at least 14 days before changes take effect.
We encourage you to review this Policy periodically. The version date at the top of this page indicates when it was last updated. Your continued use of our services after changes take effect constitutes acceptance of the revised policy.
For any questions, concerns, or to exercise your data rights, please contact our Data Protection Officer:
You also have the right to contact the Information Commissioner's Office (ICO), the UK's independent data protection authority, if you have concerns about our use of your personal data: