1. Introduction

This Privacy Policy applies to personal data (“information”) held by Thero Markets Limited (“we”, “us” or “our”) as data controllers. It explains the types of information we collect about you and how we use this information.

Please read this policy carefully. Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to stay informed of any updates.

2. The information we may collect

2.1 Information you provide to us

• Personal details (e.g. name, date of birth, gender) 

• Contact details (e.g. address, email, phone number) 

• Identity information (e.g. nationality, passport details, photo ID, National Insurance number) 

• Bank details (e.g. account name, number, sort code) 

2.2 Information we collect about you

• Transactional information (e.g. payments made to and from your accounts) 

• Communication records (e.g. written and verbal interactions with us) 

• Preferences (e.g. marketing consents and communication preferences) 

• Publicly available information (e.g. LinkedIn profiles or company websites) 

• Usage data (e.g. how you use our products and services) 

• Investigations data (e.g. anti-money laundering checks, credit checks, due diligence reports) 

• Regulatory information (e.g. suspicious activity monitoring and compliance data) 

• Risk rating information (e.g. credit risk and transactional behaviour) 

• Website usage data, including: 

  • IP address 

  • Login data 

  • Browser type and version 

  • Time zone settings 

  • Operating system and platform 

  • Website navigation and interaction data 

This information helps us monitor, maintain, and improve our services. For further details, please refer to our Cookie Policy.

3. How we collect your information

We collect personal information directly from you or via third-party systems when you:

• Use or subscribe to our services 

• Complete forms on our website 

• Communicate with us by phone, email, or other channels 

• Provide documentation for identity verification 

3.1 Information from other sources

We may receive your information from third parties where we have consent, a legal obligation, or a legitimate interest, including:

• Introducing partners 

• Clients making payments to you 

• Credit reference agencies 

• Fraud prevention agencies 

• Identity verification providers 

• Sub-contractors and advisers 

• Agents and suppliers 

• Government and regulatory bodies (e.g. Companies House, HMRC) 

• Public sources (e.g. company registries, websites, social media) 

3.2 Information about other individuals

If you provide us with personal information about another person, you must ensure they are aware of how their information will be used.
We will only use such information to facilitate services (e.g. payments) and never for marketing purposes.

3.3 Cookies

We use cookies to distinguish users and improve website functionality. Please refer to our Cookie Policy for further details.

3.4 Third-party tools

Google Analytics
We use Google Analytics to analyse website usage. Data may be transferred to servers in the United States. IP anonymisation is applied where applicable.
You can opt out via: https://tools.google.com/dlpage/gaoptout

Google reCAPTCHA
We use reCAPTCHA to protect against fraud and automated abuse. This service analyses user behaviour and may collect data such as IP address and interaction patterns.
Further details: https://policies.google.com/privacy

4. How we use your information

We only process your information where lawful to do so:

Contractual necessity

To provide services (e.g. executing payments, managing accounts)

Legal obligations

To comply with regulatory requirements, including:

• Financial reporting 

• Identity verification 

• Fraud prevention 

• Anti-money laundering checks 

• Recording communications where required 

Consent

Where you have explicitly agreed (e.g. marketing communications)
You may withdraw consent at any time.

Legitimate interests

We may process your data where it supports our business operations, including:

• Marketing and communication 

• Improving services and client experience 

• Managing relationships 

• Complaint handling 

• Website optimisation 

4.2 Combining information

We may combine information from different sources for the purposes outlined above.

5. How we share your information

We may share your personal information where necessary:

• To comply with legal obligations 

• To conduct background checks 

• To support investigations 

• To enforce agreements 

• To protect rights, safety, or property 

• Where we have a legitimate interest or your consent 

We may share information with:

• Payment and financial service partners 

• Introducing partners 

• Clients (for payment purposes) 

• Credit and fraud agencies 

• Identity verification providers 

• Agents, suppliers, subcontractors and advisers 

• Regulatory authorities 

6. International transfers and security

Your information may be transferred outside the UK or EEA where required.
Where this occurs, appropriate safeguards (e.g. contractual protections) will be implemented to ensure your data is protected to equivalent standards.

We maintain strict security procedures to protect your information.

7. Data retention

We retain personal data in line with regulatory and operational requirements.
Typically, data is retained for 5 years, unless a longer period is required by law.

8. Your rights

You have the following rights:

Access – request a copy of your data
Erasure – request deletion where appropriate
Restriction – request limited processing
Rectification – correct inaccurate data
Portability – transfer data to another provider
Withdraw consent – at any time
Object – to processing based on legitimate interests
Marketing opt-out – unsubscribe at any time

To opt out of marketing, use the unsubscribe link in communications.

9. Submitting a request

To exercise your rights, contact:
operations@thero-markets.com

We may require identity verification before processing your request.

No fee is required unless requests are excessive or unfounded.

You also have the right to complain to the Information Commissioner’s Office (ICO):
https://ico.org.uk

10. Data deletion and retention

Upon termination of services, we will either delete or return your personal data, unless retention is required by law.

We may retain data for up to 5 years for legal, regulatory, or backup purposes.

11. Further information

If you have any questions regarding this Privacy Policy, please contact:

Thero Markets Limited
Formal House
60 St Georges Place
Cheltenham
England
GL50 3PN

Email: operations@thero-markets.com