Privacy Policy

Last updated: 19 April 2026

This Privacy Policy explains how UGOFX Trading Ltd (“UGOFX”, “we”, “us”, “our”) collects, uses, shares, and protects your personal data when you use the UGOFX website (ugofx.com) or apply for, subscribe to, or use the UGOFX Signal Intelligence Platform (the “Service”).

This Privacy Policy applies to personal data processed in connection with the Service. UGOFX Trading Ltd is the data controller for that personal data.

1. Who we are

UGOFX Trading Ltd
Company No. 14350765
Registered in England and Wales
Registered office: [REGISTERED OFFICE ADDRESS — TO BE ADDED]
Contact: support@ugofx.com

2. What personal data we collect

We collect the following categories of personal data:

2.1 Data you provide when you apply

  • Full name
  • Email address
  • Country of residence and country of tax residence
  • Date of birth
  • Source of funds
  • MT5 broker and trading account number
  • Account capital range
  • How you heard about UGOFX
  • Your acknowledgements of the eligibility, risk, and jurisdictional conditions of the Service

2.2 Data collected automatically when you use our website

  • IP address
  • Browser type and user agent string
  • Date and time of your request
  • Pages visited

We do not use Google Analytics, Facebook Pixel, or any third-party analytics or advertising tracker on ugofx.com. We do not use non-essential cookies. We log basic server access information for security and fraud-prevention purposes only.

2.3 Data collected if you become a subscriber

  • Payment information relating to your USDT wallet transactions to UGOFX (on-chain transaction hashes and wallet addresses; we do not store full private wallet data)
  • Your MT5 account number, for the purpose of issuing and enforcing your licence key
  • Subscriber EA licence validation requests (the Subscriber EA sends its licence key and account number to our signal server to confirm validity)
  • Email correspondence between you and UGOFX

We do not collect your trading performance data, equity, balance, or trade history from your MT5 account. The Subscriber EA does not transmit this data to UGOFX.

3. Why we process your personal data and our legal basis

Under the UK General Data Protection Regulation (“UK GDPR”) we process your personal data on the following legal bases:

  • Contract (Article 6(1)(b)). To review and process your application, deliver the Service, maintain your subscription, issue and validate your licence key, provide technical support, and communicate with you about your subscription.
  • Legal obligation (Article 6(1)(c)). To comply with UK anti-money-laundering, tax, and record-keeping obligations, and to respond to lawful requests from regulators or courts.
  • Legitimate interests (Article 6(1)(f)). To verify that applicants meet the eligibility criteria, to prevent fraud, to maintain the security of our systems, to keep evidence that each subscriber approached UGOFX on their own initiative (reverse-solicitation record), and to enforce the Terms of Service. These interests are balanced against your rights and freedoms.

4. Who we share your personal data with

We share your personal data only with the following categories of recipient:

4.1 Service providers (processors acting on our instructions)

  • Google Cloud Platform (Google LLC). Our web server and signal server are hosted on Google Cloud in the United States (region: us-west1, Oregon). This means your personal data is stored on infrastructure located in the USA.
  • Brevo (Sendinblue SAS). We use Brevo, a France-based email service provider, to send transactional emails such as application confirmations. Brevo processes your name, email address, and the content of emails we send to you.
  • Microsoft Ireland Operations Limited (Microsoft 365). We use Microsoft 365 for our own business email. When you email us, Microsoft processes your email address and message content on our behalf.

We require each of these processors to protect your personal data in accordance with UK GDPR standards and to process it only on our documented instructions.

4.2 Professional advisers

We may share your personal data with our legal, accounting, or compliance advisers where necessary to obtain advice, respond to a regulatory enquiry, or defend a legal claim.

4.3 Regulators, courts, and law enforcement

We may disclose your personal data where required by law, court order, or a lawful request from a regulator, tax authority, or law enforcement agency.

4.4 Successors in interest

If UGOFX is sold, merged, or undergoes a change of control, your personal data may be transferred to the successor entity, subject to the same obligations under this Privacy Policy.

We do not sell your personal data. We do not share your personal data with advertisers or marketing partners.

5. International transfers

Some of our service providers are located outside the United Kingdom and the European Economic Area, in particular Google Cloud in the United States. Where your personal data is transferred outside the UK, we rely on one of the following safeguards approved under UK GDPR:

  • The UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, incorporated into our contracts with the receiving party; or
  • A UK adequacy regulation covering the relevant country, where one is in force.

You can request a copy of the relevant transfer safeguard by contacting us at the address in Section 1.

6. How long we keep your personal data

We keep your personal data for the following periods:

  • Rejected applications. Up to 12 months from the date of the application, then deleted.
  • Approved applications and subscriber records. For the duration of your subscription and for six (6) years after termination. This period reflects UK company law record-keeping requirements (six years under the Companies Act 2006), UK tax record-keeping requirements (six years under HMRC rules), and limitation periods for civil claims in England and Wales.
  • Acknowledgement records (reverse-solicitation evidence, risk acknowledgements, jurisdiction confirmations). For the duration of your subscription and for six (6) years after termination.
  • Email correspondence. For six (6) years after the end of the relevant business relationship or dispute.
  • Server access logs. Up to 12 months.

We may keep personal data for longer where we are required to do so by law, or where we reasonably need to defend a legal claim.

7. Your rights

Under UK GDPR you have the following rights in relation to your personal data:

  • Right of access. You can request a copy of the personal data we hold about you.
  • Right to rectification. You can ask us to correct inaccurate or incomplete personal data.
  • Right to erasure. You can ask us to delete your personal data in certain circumstances. This right is not absolute — for example, we may refuse to delete data we are required to keep by law or to defend a legal claim.
  • Right to restrict processing. You can ask us to limit how we use your personal data in certain circumstances.
  • Right to data portability. You can ask us to provide your personal data in a structured, machine-readable format.
  • Right to object. You can object to our processing of your personal data where we rely on legitimate interests.
  • Right to withdraw consent. Where we rely on your consent, you can withdraw it at any time. Withdrawal does not affect processing that happened before withdrawal.

To exercise any of these rights, contact us at support@ugofx.com. We will respond within one month. We may need to verify your identity before acting on your request.

8. Complaints

If you are unhappy with how we handle your personal data, please contact us first so we can try to resolve the issue. You also have the right to complain to the UK Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
United Kingdom
ico.org.uk · Helpline: 0303 123 1113

9. Cookies

The UGOFX website uses only essential cookies required for the website to function (for example, to maintain your session). We do not use analytics cookies, advertising cookies, or any third-party tracker. No cookie consent banner is required under UK law for this limited use, but we want you to know what to expect.

10. Security

We use reasonable technical and organisational measures to protect your personal data, including HTTPS encryption for all data in transit, access controls on our servers, and principle-of-least-privilege on administrative tools. No system is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your own device, account credentials, and licence key secure.

11. Children

The Service is not available to anyone under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected personal data from a child, please contact us and we will delete it.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be notified by email to active subscribers and posted on the website with a revised “Last updated” date. Your continued use of the Service after that date constitutes acceptance of the updated Privacy Policy.

13. Contact

Questions about this Privacy Policy should be sent to support@ugofx.com.

UGOFX Trading Ltd
Company No. 14350765
Registered in England and Wales
Registered office: [REGISTERED OFFICE ADDRESS — TO BE ADDED]

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