Introduction

This Privacy Policy (the “Policy”) is in line with the 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 natural persons. IC (as defined below) has implemented appropriate technical and organisational measures to ensure compliance with applicable data protection legislations. This Policy forms the cornerstone of IC’s compliance with such legislations and is reviewed and updated accordingly

The present Policy provides data subjects with information on how IC collects personal data, what we do with it and with whom it may be shared.

We ask that you read this Policy carefully as we would like to inform you that your privacy on the internet is of crucial importance to us and it also contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are?

IC is the trading name of Raw Trading Ltd, a company incorporated under the laws of Seychelles with company registration number 8419879-1 and Head Office at B11, First Floor, Providence Complex, Providence, Mahe, Seychelles, licensed by the Financial Services Authority of Seychelles with License Number SD018 (hereinafter referred to as "IC", "we", "us" and "our").

IC collects, uses and is responsible for certain personal information about you. We are responsible as "controller" of that personal information for the purposes of applicable laws.

Data Controllers and Contracting Parties

Regardless of your country of residence, IC will be the controller of your personal data provided to, or collected by or for, or processed in connection with our services and regulated activities. This includes personal data processed through any of our trading platforms, including any web-based or mobile applications. Where processing activities are carried out by technology service providers or affiliated companies acting on our behalf, IC remains the data controller and such parties act only as processors under our instruction.

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

The provision of Your Data (as defined below) is required from you to enable us to provide our services. We will inform you at the point of collecting information from you, whether you are required to provide it. If you are unable or unwilling to provide the personal data we require, we may not be able to open or maintain an account for you or provide you with our services.

Information collected by us

In the course of your registration as a client, signing up for a demo or a live account with IC or filling in any form on our Website, subscribing to our services, news or offers, 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 administer our business and carry out our regulated activities in an effort to provide you with superior service.

Information that you provide to us directly:

• Personal information, such as names, addresses, personal registration number, national identification number, passport number and email addresses etc (“Personal Information”), and
• Financial Information, trading experience and employment information for appropriateness assessment will also be collected.

However, the meaning of data “provided to” IC is not limited to this. It is also personal data resulting from observation of your activities (i.e where using a device or service).

This may include:

• History of website usage or search activities, details of your visits to our Website including, communication data;
• Traffic and location data, including approximate geographic location derived from IP address, for fraud prevention, regulatory compliance and service delivery purposes;
• Website traffic pattern information, including IP address, operating system and browser type, for system administration and to monitor and improve the performance of our services. This kind of information is only used in masked or aggregated form, which means that the individual user will not be recognisable. These data do not identify any individual.
• Communications between you and IC via Live Chat, email, or telephone call.

Where you access or use our trading platforms, including any web-based, desktop or mobile application version, we may collect and process additional information relating to your use of the platform, including account identifiers, trading account information, device information, application version information, authentication information, login activity, platform usage data, crash diagnostics and technical performance information.

Where you access ICTrade through Single Sign-On functionality from the Client Area, authentication information may be exchanged between systems operated by IC and its Affiliated Companies in order to facilitate secure access to the Platform.

Your e-mail address may be used by IC in relation to its products and services (including any marketing campaigns related to these products or services). If you do not wish to receive such marketing material and marketing communications, you can opt-out at any time by clicking on “unsubscribe” or by sending an email stating so to enquiries@ic.com.

The type of data collected and purpose of collection

For the purposes of this Policy, personal data means any information relating to an identified or identifiable natural person. Not all data listed in the table below necessarily falls within this definition. The table provides a general overview of the data we collect in connection with our services and regulated activities.

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 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.
Trading account information, including account number, account identifier, account balance, equity, free margin, profit and loss information, open and closed positions and trading history	To provide access to our trading platforms, display account information, facilitate trading activity, provide customer support, maintain records and comply with legal and regulatory obligations.
Platform usage information, device information, application version information and technical diagnostic data	To maintain, support, secure, monitor and improve the performance, functionality and reliability of our trading platforms and related services.
Push notification preferences and device notification tokens (mobile applications only)	To deliver operational and service-related notifications, including maintenance notifications, service interruptions, system updates and other platform communications.
Communications between you and IC, including Live Chat messages, email correspondence and telephone call recordings	To provide customer support, maintain records of communications and comply with regulatory record-keeping obligations
Details of deposits, withdrawals and payment methods used to process payments, comply with AML obligations and maintain financial records	To process payments, comply with AML obligations and maintain financial records
Username, password and account preferences to authenticate your identity and maintain your account	To authenticate your identity and maintain your account

How we use your personal information

We use data we collect in the following ways:

• To ensure that the content in our website is presented to you in the most effective manner and to improve the content of our website;
• To communicate with you and contact you and to provide you with products and services that you request from us or, where you have consented to be contacted, for products and services that we feel may be of interest to you;
• Managing and administering the products and services provided to you;
• Keeping you updated as a Client in relation to changes to our services and relevant matters;
• To provide, improve, test and monitor the effectiveness of our Services.
• To develop and test new products and features.
• To monitor metrics such as total number of visitors, traffic and demographic patterns.
• To diagnose or fix technology problems.
• Where you use any of our trading platforms, we may use technical and usage information to support platform functionality, authenticate users, maintain system security, investigate technical incidents, monitor application performance, analyse aggregate usage trends and improve the operation and reliability of our trading platforms.
• To carry out our obligations arising from any contracts entered between you and us.
• We may also use your data or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by email.
• To notify you about updates to the website.
• To send out newsletters or information about other opportunities that we believe will be of interest to you. We will only send this to you if you have indicated that you wish to receive such information and we will respect your wish not to do so if you communicate such wish to us. You can opt-out receiving marketing communications at any time if you do not wish to receive such marketing material by clicking on “unsubscribe” or by sending an email request to enquiries@ic.com.
• To promote safety and security. We use the information we have to help verify accounts and activity, and to promote safety and security on our regulated services, such as by investigating suspicious activity or violations of our terms or policies. We work hard to protect your account using teams of IT specialists, automated systems, and advanced technology such as encryption.

Who we share your personal information with?

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

• Service providers and other partners: We transfer information to service providers (processors), and other partners who globally support our business, such as providing technical infrastructure services, trading platforms analysing how our Services are used such as measuring the effectiveness of ads and services, providing client service and support, client on-boarding, client identify verification, including PEPs and sanctions, conducting marketing communications and design, services related to our website management, services related to software and business development services.
  We need to transfer personal data to recipients outside of your country of residence or Seychelles; these activities can include dealings with foreign public entities (only when necessary and under request), the outsourcing of services to external providers located outside of your country of residence and/or processing the data outside of your country of residence (i.e cloud computing, client identity verification and individuals from outside your country of residence accessing to our web- services).
• Third parties for legal reasons: We may share your personal data when we believe it is required or compelled by law or to comply with legal obligations and respond to requests from competent government authorities, which may include such authorities outside of your country of residence. We may do so to comply with an order of competent Court and may include competent Courts outside of your country of residence.
• Measurement and Analytics Services: Partners who provide analytics services like Google Analytics, to help us understand how our services are used. We configure such services to minimise the collection of personally identifiable information and do not share directly identifying information such as name or email address with analytics partners.
• In connection with our trading platforms: personal data may be processed by technology service providers (including Affiliated Companies) acting on our behalf. Such service providers act under contractual arrangements requiring appropriate confidentiality, security and data protection measures. Such services may include:

• cloud hosting and infrastructure services for the storage and processing of platform data;
• application performance monitoring, crash reporting and the delivery of operational push notifications for mobile applications;
• mobile application attribution analytics, campaign measurement and installation tracking;
• order routing and connectivity services in connection with trading platform operations.

IC does extensive due diligence before choosing processors assuring that they provide sufficient safeguards, in particular in terms of expert knowledge, data governance, data security, cyber resilience, reliability and resources to implement technical and organisational measures in such a manner that processing will meet the requirements of data protection regulations and ensure the protection of the rights of the data subject.

The adherence of the processor to a Data Processing Agreement is used as an element to demonstrate compliance with the obligations of the controller.

The carrying-out of processing by our processor is governed by a contract binding the processor to the controller (us).

This data sharing with our processor enables us to proceed with our regulated activities and duties to KYC in order to meet our regulatory obligations relating to assessing the appropriateness of our products and services, provide support to clients, etc. Some of those third party recipients (processors) may be based outside Seychelles; if the third party recipient is located outside Seychelles in a country not ensuring an adequate level of data protection, the transfer will only be completed if a written agreement has been entered into between IC and the third party.

We will 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.

Mobile Applications and Analytics Technologies

• Where you use any of our trading platform mobile applications, we may utilise software development kits (SDKs) and similar technologies to support application functionality, security, analytics and communications. For this purpose, third party services may be used to:
• facilitate application performance monitoring, crash diagnostics and operational push notifications. Push notifications will only be sent where permitted by your device settings and applicable laws.
• measure the effectiveness of marketing campaigns, understand application installation sources, evaluate aggregate usage patterns and improve the delivery of our services.
• collect approximate or precise location information from your device where you have granted location permissions, for purposes including fraud prevention, identity verification, regulatory compliance and service delivery.
• record application sessions or screen interactions, in anonymised or aggregated form, for quality assurance, troubleshooting and service improvement purposes.

Where your device supports biometric authentication such as Face ID or Touch ID, we may enable such functionality to verify your identity when accessing the mobile application. Biometric data used for this purpose is processed locally on your device and is not collected or stored by IC.

We shall request any necessary permissions before collecting or processing such information where this is required by applicable laws or platform provider requirements including Apple’s App Tracking Transparency framework and equivalent requirements under Google Play and other mobile platform policies.

How our global services operate

Transfer of your information out of your country of residence

Information collected in connection with your use of our services may be transferred to and processed in other countries, including countries where the data protection standards may differ from those in your country of residence. When such transfers occur, we and our processors utilize standard contractual clauses approved by relevant authorities and adopt other means under applicable laws to ensure appropriate safeguards are in place. We may also seek your consent where required to legitimize such transfers.

How do we respond to legal request or prevent harm?

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

• We can respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognised standards.
• When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorised use of the services or products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or services), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third parties about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our platforms and service.

Information we receive about you (including financial transaction data related to deposits and withdrawals) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm.

Your rights

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

• The right to 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 enquiries@ic.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).
• The 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.
• The right to restrict our processing of your personal information in certain circumstances.

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

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

We will endeavour to respond to your request within one month of receipt. Where requests are complex or numerous, this period may be extended by a further two months, and we will notify you of any such extension within one month of receiving your request.

If you would like to unsubscribe from any emailing or any marketing communications, you can also click on the ‘unsubscribe’ button at the bottom of the email or send an email at enquiries@ic.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 you or to take steps prior to entering into a contract with you.
• Compliance with legal obligations: Processing is necessary for compliance with our legal obligations, including anti-money laundering, KYC and regulatory reporting requirements.
• Legitimate interest: Data will only be processed where it is necessary for the purposes of the legitimate interests pursued by IC, and these interests or fundamental rights are not overridden by the interests, rights and freedoms of the data subject and that the processing would not cause unwarranted harm. For instance, it is a legitimate interest of IC to process personal data on data subjects in order to expand the business, develop new business relations prevention of fraud, maintaining the security of our systems if/when necessary, enhancing, modifying or improving our services. The data subject must be given information on the specific legitimate interest if a processing is based on this provision.
• Consent: In some cases, we may process your personal data, for example for marketing communications or certain mobile application permissions. You may withdraw your consent at any time.

Keeping your personal information secure

Your Data is stored and kept confidential in accordance with the applicable data protection legislation.

Personal data processed through our trading platforms is hosted within cloud infrastructure provided by our service providers. Appropriate technical and organisational measures are implemented to protect the confidentiality, integrity and availability of personal data, including access controls, authentication controls, encryption technologies, monitoring systems and incident response procedures.

We have appropriate security measures in place to prevent personal information from being accidentally lost, misused, modified, disclosed or accessed in an unauthorised 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 authorised 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 any time, but for audit trail purposes, IC shall hold personal data for a period of at least seven (7) years after closing the account in order for us to comply with our record keeping obligations under the Securities (Conduct of Business) Regulations 2008 of Seychelles

At the end of that period, we will delete all personal data relating to you, unless a legal requirement requires us to keep the data for a prolonged period of time, or the data subject has expressly consented to their data being held for an extended period of time.

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 may result in the automatic closure of your account and we will remove your personal data from active processing. However, we will be required to maintain your personal data to comply with our legal and regulatory requirements as well as in accordance with our internal compliance requirements in relation to maintaining records.

How to request the deletion of your data:

• Email us at enquiries@ic.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 licence or passport and a recent utility or credit card bill), and
• 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 the whole of IC or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address and any other information collected through our services may be among the items sold or transferred. Any content you have posted or shared through our platforms will remain yours and will not be treated as an asset of IC in the event of any such transfer. The buyer or transferee will have to honour the commitments we have made in this Privacy Policy.

How to complain?

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

The legal framework gives you right to lodge a complaint with a supervisory authority. In the Seychelles the Data Protection Act (the 'Act') was enacted in 2003 (Act No. 9 of 2003) with the aim of protecting the fundamental privacy rights of individuals against the use of data concerning them without their informed consent.

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 enquiries@ic.com.

National requirements

IC shall comply with all national and international data protection laws and legislations.

If applicable national legislation requires a higher level of protection for personal data than such policies/guidelines, such stricter requirements are to be complied with. If IC policies/guidelines are stricter than the local legislation, our policies/guidelines must be complied with.

Changes to this privacy notice

This privacy policy was initially published in May 2019 and last updated in July 2026.

We may change this privacy policy from time to time, and 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).