Privacy Policy.

ENARA (“ENARA”, “we”, “us”) is the controller of the personal information described in this policy. The contracting ENARA entity responsible for your data will be identified in your client agreement.

This policy applies to our website, our client onboarding process, and the services provided to account holders. It does not apply to third-party sites we link to, each of which publishes its own policy.

We collect only what we need to operate lawfully and serve you properly.

Identity and contact data

Name, date of birth, nationality, residential address, email address and telephone number.

Verification data

Identity documents, proof of address, and the results of identity, sanctions and politically-exposed-person checks required by law.

Financial and suitability data

Employment status, source of funds and wealth, income band, trading experience and stated investment objectives.

Account and transaction data

Account balances, deposits, withdrawals, orders, positions and the records we are required to keep of them.

Technical data

IP address, device and browser type, operating system, approximate location derived from IP, and pages viewed on our site.

Communications data

Emails, support messages, chat transcripts and, where applicable and disclosed to you, recordings of telephone calls.

We use personal information to:

• Open, verify, administer and close accounts.
• Provide the services you ask for, including executing and recording transactions.
• Meet legal obligations, including anti-money-laundering, sanctions, tax and record-keeping requirements.
• Assess appropriateness and suitability where required by applicable rules.
• Detect, investigate and prevent fraud, market abuse and misuse of our services.
• Provide support and respond to your questions and complaints.
• Improve our website, platforms and educational content.
• Send service messages, and, where you have consented or are otherwise permitted to receive them, marketing communications you can withdraw from at any time.

Where data-protection law requires a legal basis, we rely on one of the following:

Performance of a contract

To take steps at your request before entering into an agreement and to provide the services under it.

Legal obligation

To comply with the financial-crime, regulatory, tax and record-keeping duties that apply to us.

Legitimate interests

To secure our systems, prevent fraud, manage risk and improve our services, where those interests are not overridden by your rights.

Consent

For optional cookies and certain marketing communications. Where we rely on consent, you may withdraw it at any time without affecting prior processing.

We do not sell personal information. We share it only where necessary, and only with parties bound by confidentiality and data-protection obligations:

• Other ENARA group entities, where they are involved in providing or supporting your account.
• Service providers, including identity-verification, payment, hosting, communications and analytics providers.
• Banks, payment institutions and execution or liquidity partners, where required to process your instructions.
• Regulators, tax authorities, law-enforcement agencies and courts, where we are legally required or permitted to disclose.
• Professional advisers such as auditors and lawyers, under duties of confidentiality.
• A purchaser or successor entity in the event of a reorganisation, merger or sale of the business.

We use cookies and similar technologies to operate the site, remember your preferences and understand how the site is used. Essential cookies are necessary for the site to function; all other categories are optional and set only with your consent where required.

Our Cookie Policy explains each category, the purposes served, and how to change your preferences at any time.

We keep personal information for as long as we need it for the purpose it was collected, and then for any period required by law. Client records, transaction records and communications are typically retained for [retention period, to be confirmed] after the end of the client relationship, as required by applicable regulation.

When a retention period ends, information is deleted or irreversibly anonymised. Where deletion is not immediately possible for technical reasons, we isolate the data and protect it until deletion can be completed.

We apply technical and organisational measures appropriate to the sensitivity of the information we hold, including encryption in transit, access controls on a least-privilege basis, logging and monitoring, staff training, and supplier due diligence.

No system is perfectly secure. If a personal-data breach occurs that is likely to result in a risk to your rights, we will notify the relevant authority and, where required, you, within the timeframes set by applicable law.

Subject to applicable law and to our legal and regulatory obligations, you may have the right to:

• Access the personal information we hold about you and receive a copy.
• Have inaccurate or incomplete information corrected.
• Request erasure where we no longer have a lawful reason to keep the information.
• Restrict or object to certain processing, including direct marketing.
• Receive certain information in a portable, machine-readable format.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with your local data-protection authority.

To exercise any of these rights, contact us using the details below. We may need to verify your identity first. We aim to respond within [response period, to be confirmed] and will tell you if we need longer.

ENARA operates internationally, and your information may be processed in a country other than the one you live in. Where we transfer personal information across borders, we put appropriate safeguards in place, such as approved contractual clauses, adequacy findings, or equivalent mechanisms recognised under applicable law.

Details of the safeguards applied to a specific transfer are available on request.

Our services are intended for adults only and are not directed at children. We do not knowingly collect personal information from anyone under the age of majority in their jurisdiction. If we learn that we have, we will delete it promptly.

We may update this policy to reflect changes in our services, technology or legal obligations. The date at the top of this page shows when it was last revised. Where a change is material, we will give you notice by an appropriate means before it takes effect.

Questions about this policy, or about how we handle your information, can be sent to info@enara.com. Written enquiries may be addressed to [registered address, to be confirmed], marked for the attention of the Data Protection contact [name, to be confirmed].