Privacy Policy

1. Introduction

Last updated: May 15, 2024

At Modern Investment Platform ("we," "our," or "us"), we are committed to protecting your privacy and the security of your personal information. This Privacy Policy outlines our practices regarding the collection, use, disclosure, and safeguarding of your information when you visit our website, use our trading platform, or engage with our services.

By accessing or using our services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with our policies and practices, please do not use our services.

2. Information We Collect

3. Legal Basis for Processing

We process your personal information for the purposes described in this Privacy Policy based on the following legal grounds under Swiss Federal Data Protection Act (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR):

• Contractual Necessity: To perform our contractual obligations to you, including providing our services and processing transactions.
• Legitimate Interests: To pursue our legitimate business interests, such as improving our services, preventing fraud, and ensuring the security of our platform.
• Legal Compliance: To comply with applicable Swiss laws, regulations, and legal requirements, including financial regulations and anti-money laundering (AML) obligations.
• Consent: Where you have given us consent to process your personal information for specific purposes.

4. How We Use Your Information

We use the information we collect for various business and commercial purposes, including:

• To create, maintain, and secure your account
• To provide, operate, and maintain our trading platform and services
• To process and complete transactions, and send related information including transaction confirmations and invoices
• To comply with legal and regulatory requirements, including KYC, AML, and tax reporting obligations
• To verify your identity and prevent fraud, money laundering, and other prohibited or illegal activities
• To respond to your inquiries, comments, feedback, or questions
• To send administrative information, such as updates, security alerts, and support messages
• To personalize your experience and deliver content and product offerings relevant to your interests
• To monitor and analyze usage, trends, and activities to improve our services
• To develop new products, services, features, and functionality
• To communicate with you about promotions, upcoming events, and other news about products and services
• To protect our rights, property, or safety, and that of our users or others

5. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

• 256-bit SSL encryption for all data transmissions
• Multi-factor authentication for account access
• Regular security assessments and penetration testing
• Strict access controls and authentication procedures
• Continuous monitoring for suspicious activities
• Regular data backups and disaster recovery planning

However, please be aware that no security system is impenetrable, and we cannot guarantee the absolute security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.

6. Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including to satisfy any legal, regulatory, accounting, or reporting requirements. In determining the appropriate retention period, we consider:

• The amount, nature, and sensitivity of the personal information
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process the information and whether we can achieve those purposes through other means
• Applicable legal, regulatory, tax, accounting, or other requirements

For regulatory and compliance purposes, we typically retain account information and transaction data for a minimum of five years after an account is closed.

7. Your Rights

Under Swiss data protection law and, where applicable, the GDPR, you have the following rights regarding your personal information:

• Right to Access: You have the right to request copies of your personal information that we hold.
• Right to Rectification: You have the right to request that we correct inaccurate information or complete incomplete information.
• Right to Erasure: You have the right to request that we delete your personal information in certain circumstances.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information in certain circumstances.
• Right to Data Portability: You have the right to request that we transfer the information you have provided to us to another organization or directly to you.
• Right to Object: You have the right to object to the processing of your personal information in certain circumstances.
• Right to Withdraw Consent: Where we rely on consent as the legal basis for processing, you have the right to withdraw your consent at any time.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) if you believe that we have violated your data protection rights.

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We may need to verify your identity before responding to your request.

8. Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect and store information about your interactions with our platform. These technologies help us:

• Remember your preferences and settings
• Understand how you interact with our services
• Analyze trends and gather demographic information
• Improve the functionality and user experience of our platform
• Provide personalized content and recommendations
• Detect and prevent fraud and security issues

You can control cookies through your browser settings. Most browsers allow you to refuse to accept cookies and to delete cookies. However, if you disable or refuse cookies, please note that some parts of our platform may become inaccessible or not function properly.

9. International Data Transfers

We may transfer, store, and process your information in countries other than Switzerland. Our servers and third-party service providers may be located in various countries around the world. When we transfer your information internationally, we take measures to ensure that adequate safeguards are in place to protect your information in accordance with Swiss data protection laws.

For transfers to countries that do not provide an adequate level of protection according to the Swiss Federal Data Protection and Information Commissioner, we implement appropriate safeguards such as standard contractual clauses approved by the Swiss Federal Council or the European Commission.

10. Third-Party Disclosure

We may share your information with third parties in the following circumstances:

• Regulatory Authorities: To comply with legal obligations, including reporting requirements to financial regulators, tax authorities, and law enforcement agencies.
• Financial Institutions: To facilitate transactions, including banks, payment processors, and other financial service providers.
• Service Providers: With third-party vendors, consultants, and other service providers who perform services on our behalf, such as hosting providers, analytics companies, and customer service providers.
• Business Partners: With business partners with whom we jointly offer products or services.
• Professional Advisors: With professional advisors, such as lawyers, auditors, and insurers, where necessary in the course of the professional services they provide to us.
• Corporate Transactions: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

We require all third parties to respect the security of your personal information and to treat it in accordance with applicable laws. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

11. Children's Privacy

Our services are not intended for individuals under the age of 18, and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will take steps to delete such information as quickly as possible.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically to stay informed about our information practices.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our Data Protection Officer at: