This Privacy Policy explains how EightFund Ltd collects, uses, stores, and protects your personal data. Please read this Policy carefully alongside our Terms of Service and ESPA.
1. Introduction and Data Controller
1.1 About This Policy
This Privacy Policy describes how EightFund Ltd ("EightFund," "we," "us," or "our") collects, processes, stores, shares, and protects personal data in connection with the EightFund Platform, website at eightfund.trade, Telegram application, and all related services (collectively, the "Platform").
This Policy applies to all individuals who access, register for, or use the Platform, including Participants, prospective users, website visitors, affiliate partners, and any other persons whose personal data we process.
1.2 Data Controller
EightFund Ltd, a company registered in England and Wales, is the data controller responsible for your personal data under applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).
Data Protection Contact: privacy@eightfund.trade
1.3 Applicable Law
This Policy is governed by and compliant with:
- The UK General Data Protection Regulation (UK GDPR), as retained in UK law under the European Union (Withdrawal) Act 2018;
- The Data Protection Act 2018 (DPA 2018);
- The Privacy and Electronic Communications Regulations 2003 (PECR);
- Any other applicable data protection laws in jurisdictions where we operate or where our Participants are located.
Where Participants are located in the European Economic Area (EEA), EightFund will also comply with the EU General Data Protection Regulation (EU GDPR) to the extent applicable.
2. Personal Data We Collect
2.1 Data You Provide Directly
We collect the following categories of personal data that you provide to us:
- Identity data: full name, date of birth, nationality, government-issued ID documents;
- Contact data: email address, phone number, postal address;
- Financial data: cryptocurrency wallet addresses, payment method details;
- Verification data: KYC documentation, selfie/photo verification;
- Communications: support tickets, emails, feedback, and any other correspondence.
2.2 Data Generated Through Platform Use
We automatically collect and generate the following data through your interaction with the Platform:
- Performance Data as defined in the ESPA (trade entries/exits, position sizing, risk patterns, drawdown behaviour, strategy characteristics, etc.);
- Technical data: IP address, browser type/version, operating system, device identifiers, screen resolution;
- Usage data: pages visited, features used, session duration, click patterns, navigation paths;
- Location data: approximate geolocation derived from IP address.
2.3 Data from Third Parties
We may receive personal data about you from the following third-party sources:
- Identity verification service providers (KYC check results, watchlist screening outcomes, PEP status);
- Payment processors (transaction status, payment confirmations, chargeback notifications);
- Analytics providers (aggregated usage data, attribution data);
- Public sources (sanctions lists, law enforcement databases, publicly available social media profiles);
- Referral partners and affiliates (referral source, campaign identifiers).
2.4 Special Category Data
We do not intentionally collect special category data (also known as sensitive personal data), including data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data for identification purposes, health data, or data concerning sexual orientation. If we inadvertently receive such data, we will delete it promptly unless we have a lawful basis for processing it.
3. Lawful Basis for Processing
We process your personal data only when we have a lawful basis to do so under UK GDPR Article 6. The lawful bases we rely on include:
- Contract performance: Processing necessary to perform our contract with you (Terms of Service, ESPA);
- Legitimate interest: Processing necessary for our legitimate business interests, where those interests are not overridden by your rights;
- Legal obligation: Processing necessary to comply with legal or regulatory requirements;
- Consent: Processing based on your specific, informed consent (e.g., marketing communications).
Legitimate Interest Assessments: Where we rely on legitimate interest as a lawful basis, we have conducted a Legitimate Interest Assessment (LIA) to ensure that our interests do not override your fundamental rights and freedoms. You may request a copy of our LIAs by contacting privacy@eightfund.trade.
4. How We Use Your Data
4.1 Service Delivery
We use your personal data to:
- Create and manage your account on the Platform;
- Operate Challenges and Funded Accounts, including calculating drawdowns, tracking performance, and determining eligibility;
- Process Payout Award requests and distribute approved awards;
- Provide customer support and respond to inquiries;
- Enforce our Terms of Service, ESPA, and Platform rules.
4.2 Security and Compliance
We use your personal data to:
- Verify your identity and prevent fraud, money laundering, and terrorist financing;
- Detect prohibited trading practices and platform abuse;
- Monitor account activity for suspicious behaviour using automated systems, statistical analysis, and manual review;
- Screen against sanctions lists and PEP databases;
- Comply with legal and regulatory obligations, including responding to lawful requests from law enforcement and regulatory authorities.
4.3 Analytics and Data Licensing
As described in the ESPA (Section 5), we use Performance Data for:
- Performance benchmarking, community analytics, and trend analysis;
- Algorithmic testing, strategy modelling, and machine learning training;
- Educational content development;
- Internal and external data licensing and commercial applications;
- Risk assessment and product development.
Performance Data used for analytics and licensing purposes is typically aggregated or pseudonymised. However, certain uses may involve identifiable data where necessary for specific analysis.
4.4 Communications
We use your contact information to:
- Send operational communications (account notifications, Payout Award updates, security alerts, Platform changes);
- Send marketing communications, but only with your explicit consent and with a clear opt-out mechanism in every message;
- Respond to your support requests and inquiries.
6. Data Retention
6.1 Retention Periods
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Standard retention periods include:
- Account and identity data: duration of account relationship plus 6 years;
- Transaction and financial records: 7 years from transaction date;
- KYC/AML documentation: 5 years after end of business relationship;
- Performance Data: retained indefinitely in anonymised/pseudonymised form under ESPA license;
- Marketing consent records: duration of consent plus 2 years;
- Support correspondence: 3 years from last interaction.
6.2 Retention After Termination
When your account is terminated or closed, we will:
- Anonymise or pseudonymise Performance Data that is subject to the ongoing license under the ESPA;
- Retain identifiable data only as required by law or for legitimate purposes (e.g., defending legal claims);
- Securely delete or anonymise all other personal data within the timeframes specified above;
- Maintain minimal records necessary to prevent re-registration by banned Participants.
6.3 Deletion Requests
You may request deletion of your personal data at any time (see Section 7). However, we may retain certain data where we have a lawful basis to do so, including data required for legal compliance, defence of claims, or fraud prevention. Where deletion is not possible, we will explain the reasons and the applicable retention period.
7. Your Data Protection Rights
Under UK GDPR and applicable data protection laws, you have the following rights in relation to your personal data. These rights are not absolute and are subject to certain conditions and exceptions.
- Right of access: obtain confirmation of processing and a copy of your personal data;
- Right to rectification: request correction of inaccurate or incomplete data;
- Right to erasure: request deletion of your personal data in certain circumstances;
- Right to restrict processing: request limitation of processing in certain circumstances;
- Right to data portability: receive your data in a structured, machine-readable format;
- Right to object: object to processing based on legitimate interests or direct marketing;
- Right to withdraw consent: withdraw consent at any time where processing is based on consent;
- Rights related to automated decision-making: see Section 10.
7.1 How to Exercise Your Rights
To exercise any of the above rights, please contact us at privacy@eightfund.trade with the subject line "Data Subject Request." We may require verification of your identity before processing your request.
We will respond to your request within one (1) calendar month of receipt. If your request is complex or if we receive a large number of requests, we may extend this period by up to two (2) additional months, in which case we will notify you.
7.2 No Fee (Usually)
You will not normally have to pay a fee to exercise your rights. However, we may charge a reasonable administrative fee if your request is manifestly unfounded, excessive, or repetitive.
7.3 Performance Data and Erasure
Please note that the Performance Data license granted under the ESPA is irrevocable and survives account termination. However, you may still request:
- Deletion of identifiable personal data associated with your Performance Data (e.g., name, email, IP address);
- Anonymisation of Performance Data so that it can no longer be linked to you personally;
- Restriction of future identifiable processing of your Performance Data.
Anonymised or aggregated Performance Data that can no longer be linked to an identifiable individual is not personal data under UK GDPR and is therefore not subject to data protection rights.
7.4 Right to Complain
If you are not satisfied with our handling of your personal data or our response to a data subject request, you have the right to lodge a complaint with the relevant supervisory authority:
United Kingdom: Information Commissioner's Office (ICO) — Website: ico.org.uk — Telephone: 0303 123 1113 — Email: icocasework@ico.org.uk
If you are located in the EEA, you may also lodge a complaint with your local data protection authority.
9. Data Security
9.1 Security Measures
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit (TLS/SSL) and at rest (AES-256 or equivalent);
- Access controls and authentication mechanisms (role-based access, multi-factor authentication for staff);
- Regular security assessments and penetration testing;
- Secure development practices and code review processes;
- Logging and monitoring of access to personal data;
- Staff training on data protection and information security;
- Incident response procedures for data breaches.
9.2 Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:
- Notify the Information Commissioner's Office (ICO) without undue delay and, where feasible, within 72 hours of becoming aware of the breach;
- Notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms;
- Document the breach, its effects, and the remedial actions taken.
9.3 Your Security Responsibilities
You are responsible for maintaining the security of your account credentials (password, email access, Telegram account). EightFund will never ask you to disclose your password. If you suspect unauthorised access to your account, contact security@eightfund.trade immediately.
10. Automated Decision-Making and Profiling
10.1 Automated Processing
We use automated systems to process certain aspects of your participation on the Platform, including:
- Drawdown monitoring and automatic account termination when limits are breached;
- Detection of prohibited trading practices through pattern analysis and behavioural profiling;
- Risk scoring for Payout Award eligibility review;
- Fraud detection based on IP, device, and behavioural analytics.
10.2 Significance of Automated Decisions
Some automated decisions may have significant effects on you, including the termination of your Funded Account or the denial of a Payout Award request. Where automated processing produces a decision that significantly affects you:
- You have the right to request human review of the decision;
- You have the right to express your point of view and to contest the decision;
- The internal review process described in the ESPA (Section 4.5) serves as the mechanism for human review of Payout Award decisions.
10.3 Profiling
We may create profiles based on your trading behaviour, risk patterns, and Platform usage to improve our services, detect fraud, and assess data quality. Profiling data is processed on the basis of legitimate interest (fraud prevention, platform integrity) and contract performance (ESPA). You may object to profiling for legitimate interest purposes by contacting privacy@eightfund.trade.
11. Children's Privacy
The Platform is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a person under 18, we will take steps to delete that data promptly. If you believe a child has provided us with personal data, please contact us at privacy@eightfund.trade.
12. Third-Party Links and Services
The Platform may contain links to third-party websites, services, or applications that are not operated or controlled by EightFund. This Privacy Policy does not apply to third-party services. We are not responsible for the privacy practices, content, or security of third-party services. We encourage you to review the privacy policies of any third-party services you access through the Platform.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or industry standards. When we make material changes:
- We will post the updated Policy on the Platform with a revised "Effective Date";
- We will notify you by email or in-app notification at least fourteen (14) calendar days before the changes take effect;
- Where changes to processing are based on consent, we will seek renewed consent where required.
We encourage you to review this Policy periodically. Your continued use of the Platform after the effective date of a revised Policy constitutes your acceptance of the changes, except where your consent is specifically required.
14. Information for International Users
14.1 EEA and Swiss Users
If you are located in the European Economic Area or Switzerland, your personal data is protected under the EU GDPR. You may exercise your rights under the EU GDPR by contacting privacy@eightfund.trade. International transfers of your data will be safeguarded as described in Section 5.3.
14.2 Users Outside the UK and EEA
If you access the Platform from a jurisdiction with data protection laws that differ from the UK GDPR, please be aware that your personal data will be transferred to and processed in the United Kingdom and potentially other jurisdictions. By using the Platform, you consent to such transfers, subject to the safeguards described in this Policy. Where local laws provide additional rights, we will comply with those requirements.
15. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:
- Data Protection Contact: privacy@eightfund.trade
- General Support: support@eightfund.trade
- Security Reports: security@eightfund.trade
- Legal and Compliance: legal@eightfund.trade
Supervisory Authority
Information Commissioner's Office (ICO) — Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF — Website: ico.org.uk — Telephone: 0303 123 1113