1. Scope
This Privacy Policy explains how Upward Trading FZCO ("Company", "we", "us", "our") collects, uses, stores, and protects personal information when you use FundedSmart, including fundedsmart.com, app.fundedsmart.com, and related services.
2. Information We Collect
2.1 Information You Provide
- Account information: name, email address, phone number, and authentication credentials
- Identity verification (KYC): government-issued ID, proof of address, date of birth, and selfie when required for reward payouts or compliance
- Payment-related information: billing details and transaction references processed by our payment processor. We do not store full payment card numbers, UPI credentials, or other full payment instrument details
- Communications: support correspondence and complaint history
2.2 Information Collected Automatically
- Usage data: pages visited, features used, date and time of access, time spent, navigation patterns, referring URLs
- Product / platform telemetry: general statistical and tracking information such as when you access the trading application or evaluation features and approximate time spent, used for operations, security, and resource management
- Device information: IP address, browser type, operating system, device type
- Cookies and similar technologies: see Cookie Policy
2.3 Information from Third Parties
- Simulated trading platform providers: challenge performance, trading activity, and rule-compliance signals
- Identity verification providers: verification results
- Payment processors: payment status and limited billing metadata needed to confirm transactions
- Analytics providers: aggregated or pseudonymous usage insights
3. How We Use Your Information
- Deliver and administer the Service (accounts, purchases, evaluations, rewards eligibility review)
- Identity verification, fraud prevention, and security
- Customer support and complaint handling
- Service communications (transactional)
- Improve the product and user experience
- Comply with legal obligations
Marketing communications (if any) are sent only where permitted and with an opt-out. Service/transactional messages may still be sent.
4. Legal Bases / Grounds (high level)
This Policy is issued by Upward Trading FZCO under the laws of the United Arab Emirates, including the UAE Personal Data Protection Law (PDPL) as it applies to the Company. UAE legal counsel has reviewed and approved this Policy. We process data based on:
- Necessity to provide the Service under our contract with you
- Compliance with legal obligations
- Legitimate operational needs such as security and fraud prevention
- Consent, where we rely on it (for example certain marketing communications)
5. Cookies and Tracking
We use essential cookies and may use analytics tools as described in the Cookie Policy. You can control some cookies via browser settings (essential cookies may be required for login).
6. Data Sharing and Disclosure
We may share information with:
- Simulated trading platform providers — trading platform operations and evaluation signals
- Payment processors — payment processing (we do not store full payment instrument details)
- KYC providers — identity verification
- Hosting / infrastructure — e.g. Vercel and cloud providers
- Analytics — Google Analytics (via GTM), Microsoft Clarity, Vercel Analytics
- Professional advisers and authorities when required by law
We do not sell your personal information.
7. International Transfers
Upward Trading FZCO is established in the United Arab Emirates. Many users are in India. Vendors may process data in the UAE and other regions. Cross-border processing is part of operating the Service. We take reasonable steps to use appropriate safeguards.
8. Data Storage and Security
We implement reasonable technical and organisational measures, including encryption in transit (TLS), access controls, and vendor diligence appropriate to our size and risk. No method of transmission or storage is 100% secure.
9. Data Retention
Typical retention (subject to legal holds and applicable law):
- Account data: for the life of the account plus approximately 12 months after closure
- KYC data: up to 5 years after account closure or as required by applicable law
- Usage analytics: individual-level data approximately 24 months; aggregates may be retained longer
- Support / complaints: as needed to resolve disputes and meet legal requirements
10. Your Rights
Under UAE law applicable to the Company, you may request access, correction, erasure, restriction, or objection to certain processing, and you may withdraw consent where processing is consent-based. Email support@fundedsmart.com. We may need to verify your identity. Some data may be retained where required for legal, security, or dispute purposes.
11. Privacy / Grievance Contact
Email: support@fundedsmart.com (subject line: Privacy / Grievance)
Contact us at the email above for privacy or grievance requests. We aim to acknowledge privacy requests within 5 business days and to respond substantively within 30 days where practicable (complex requests may take longer with notice).
The counsel-approved privacy and grievance channel is support@fundedsmart.com. We do not appoint a separate named statutory officer.
12. Children's Privacy
The Service is not intended for individuals under 18. We do not knowingly collect personal information from minors. If we learn that a minor has provided personal data, we will delete it.
13. Third-Party Services
Third-party services (including our simulated trading platform, payment processor, analytics, and hosting providers) process data under their own policies. Review those providers’ privacy notices as applicable. Their terms may also apply to your use of their services.
14. Changes
We may update this Privacy Policy. Material changes will be reflected with an updated “Last updated” date and, where appropriate, email or in-product notice.
15. Contact and Identity
Upward Trading FZCO
Dubai Silicon Oasis, Dubai, United Arab Emirates
Email: support@fundedsmart.com