Privacy Statement & Data Protection Policy

Our Privacy Philosophy

EquitiSurge (“we”, “us”, or “our”) respects the privacy of our investors and website visitors. We are committed to maintaining the confidentiality, integrity, and security of all personal and corporate information entrusted to us.

We do not sell, rent, monetize, or trade investor data with commercial marketing brokers under any circumstances. Data collection is strictly limited to information necessary to establish discretionary trading mandates and comply with applicable anti-money laundering regulations.

Non-Custodial Financial Privacy

Because EquitiSurge operates as a non-custodial trading manager, we never request, receive, or store:

• Your bank account login credentials or online banking passwords.
• Your credit or debit card primary account numbers (PAN), CVVs, or expiration dates.
• Your broker account withdrawal passwords or master portal authentication codes.

All deposits, withdrawals, and capital custodial actions occur directly between you and your chosen regulated broker.

Information We Collect

We collect only the information required to facilitate trading mandates, communicate performance updates, and satisfy legal obligations:

• Contact Data: Full name, corporate entity name, business/personal email address, and telephone number.
• Mandate Identifiers: Your designated broker sub-account number (e.g. MT4/MT5 login number) provided for the sole purpose of linking to our PAMM allocation engine or LPOA roster.
• Communication Records: Records of inquiries, emails, onboarding questionnaires, and customer support transcripts.
• Technical Data: IP address, browser type, operating system, and anonymized session duration collected via essential server logs.

How We Use Your Data

Your personal information is processed strictly for legitimate operational purposes:

• Validating LPOA authorization with partner brokerage custodians.
• Delivering authenticated performance reports, monthly statements, and research digests.
• Monitoring account health and algorithmic trade synchronization.
• Complying with regulatory reporting, anti-fraud, and KYC requirements.

Third-Party Disclosures

We may share your data only with vetted third parties strictly under confidentiality agreements:

• Regulated Broker Custodians: To verify your account mapping and confirm execution mandate parameters.
• Infrastructure Providers: Secure cloud server hosts (ISO 27001 / SOC 2 certified) supporting our quantitative trade transmission.
• Legal & Regulatory Authorities: Only when compelled by formal subpoena, court order, or applicable law.

Security Architecture & Storage

We implement enterprise-grade technical safeguards including TLS 1.3 encryption in transit, AES-256 encryption at rest, role-based access control (RBAC), and multi-factor authentication across all internal systems.

Data is retained only as long as required to fulfill the operational mandate or satisfy statutory financial recordkeeping obligations (typically 5 to 7 years following mandate termination).

Your Data Protection Rights

Depending on your jurisdiction (including rights under the EU/UK General Data Protection Regulation – GDPR), you have the right to:

• Right of Access: Request a full copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete records.
• Right to Erasure (“Right to be Forgotten”): Request deletion of your personal records subject to regulatory retention mandates.
• Right to Restriction & Objection: Object to specific processing activities or request restrictions on data handling.

Cookies & Analytics

Our website utilizes strictly essential session cookies and privacy-preserving analytics to ensure platform stability. We do not employ intrusive cross-site advertising trackers or third-party behavioral profiling pixels.

Contact Our Data Protection Officer

For inquiries regarding your personal data, exercising statutory privacy rights, or submitting a formal data request, please contact our compliance desk:

Email: privacy@equitisurge.com
Attention: Data Protection & Compliance Officer
Response Window: All requests receive a formal acknowledgment within 48 hours.