Privacy Policy

1. Introduction

MITON GROUP Asset Management ("MITON GROUP," "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us.

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

2. Information We Collect

2.1 Personal Information

We collect personal information that you voluntarily provide to us, including:

• Identity Information: Full name, date of birth, nationality, government-issued ID numbers
• Contact Information: Email address, phone number, mailing address
• Financial Information: Bank account details, investment history, income information, net worth
• Employment Information: Employer details, job title, work address
• Investment Preferences: Risk tolerance, investment goals, sector preferences

2.2 Automatically Collected Information

When you use our services, we automatically collect certain information:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent on pages, click patterns, session duration
• Location Data: General geographic location based on IP address
• Transaction Data: Investment transactions, account balances, trading activity

2.3 Third-Party Information

We may receive information about you from third parties, including:

• Credit reporting agencies and identity verification services
• Financial institutions and payment processors
• Regulatory databases and sanctions lists
• Marketing partners and referral sources

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Provision

• Opening and maintaining your investment accounts
• Processing investment transactions and managing portfolios
• Providing customer support and responding to inquiries
• Sending account statements and investment reports

3.2 Legal and Regulatory Compliance

• Verifying your identity and conducting KYC (Know Your Customer) procedures
• Monitoring for anti-money laundering (AML) compliance
• Reporting to regulatory authorities as required
• Maintaining records for audit and examination purposes

3.3 Business Operations

• Improving our services and developing new products
• Conducting market research and analytics
• Personalizing your experience and recommendations
• Marketing our services (with your consent where required)

3.4 Security and Fraud Prevention

• Detecting and preventing fraudulent activities
• Monitoring for suspicious transactions
• Protecting the security of our systems and data
• Investigating security incidents

4. Information Sharing and Disclosure

We may share your personal information in the following circumstances:

4.1 Service Providers

We share information with trusted third-party service providers who assist us in operating our business, including:

• Custodial banks and financial institutions
• Payment processors and clearing houses
• Technology service providers and cloud hosting companies
• Identity verification and compliance service providers
• Professional service providers (auditors, lawyers, consultants)

4.2 Legal Requirements

We may disclose your information when required by law or regulation:

• In response to court orders, subpoenas, or legal process
• To comply with regulatory reporting requirements
• To cooperate with law enforcement investigations
• To protect our rights, property, or safety

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

4.4 Consent

We may share your information for other purposes with your explicit consent or at your direction.

5. Data Security

We implement comprehensive security measures to protect your personal information:

5.1 Technical Safeguards

• Encryption: All data is encrypted in transit and at rest using industry-standard protocols
• Access Controls: Multi-factor authentication and role-based access controls
• Network Security: Firewalls, intrusion detection systems, and regular security monitoring
• Secure Infrastructure: SOC 2 Type II certified data centers and cloud providers

5.2 Administrative Safeguards

• Regular security training for all employees
• Background checks for personnel with access to sensitive data
• Incident response procedures and breach notification protocols
• Regular security audits and penetration testing

5.3 Physical Safeguards

• Secure office facilities with controlled access
• Locked storage for physical documents
• Secure disposal of sensitive materials
• Environmental controls and monitoring

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience and collect information about how you use our services.

6.1 Types of Cookies

• Essential Cookies: Required for basic website functionality and security
• Performance Cookies: Help us understand how visitors interact with our website
• Functional Cookies: Remember your preferences and personalize your experience
• Marketing Cookies: Used to deliver relevant advertisements and measure campaign effectiveness

6.2 Cookie Management

You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our services. You can also use our cookie preference center to manage your cookie settings.

6.3 Third-Party Tracking

We may use third-party analytics and advertising services that use cookies and similar technologies. These services have their own privacy policies governing their use of information.

7. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

7.1 Access and Portability

• Request access to your personal information
• Receive a copy of your data in a portable format
• Request information about how your data is processed

7.2 Correction and Updates

• Correct inaccurate or incomplete information
• Update your contact information and preferences
• Request completion of incomplete data

7.3 Deletion and Restriction

• Request deletion of your personal information (subject to legal requirements)
• Restrict processing of your data in certain circumstances
• Object to processing based on legitimate interests

7.4 Marketing Communications

• Opt out of marketing emails and communications
• Manage your communication preferences
• Withdraw consent for marketing activities

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

8.1 Retention Periods

• Account Information: Retained for the duration of your relationship with us plus 7 years
• Transaction Records: Retained for 7 years after the transaction date
• Communications: Retained for 3 years unless longer retention is required
• Marketing Data: Retained until you opt out or for 3 years of inactivity

8.2 Secure Disposal

When we no longer need your personal information, we securely delete or destroy it using industry-standard methods to prevent unauthorized access or reconstruction.

9. International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers.

9.1 Transfer Mechanisms

• Standard Contractual Clauses approved by relevant authorities
• Adequacy decisions by regulatory bodies
• Binding Corporate Rules for intra-group transfers
• Your explicit consent for specific transfers

9.2 Data Protection Standards

Regardless of where your data is processed, we maintain the same high standards of data protection and security outlined in this Privacy Policy.

10. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately using the information provided in Section 12.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending you an email notification (if you have provided your email address)
• Providing notice through our services or other appropriate means

The updated Privacy Policy will be effective immediately upon posting, unless otherwise specified. Your continued use of our services after the effective date constitutes acceptance of the updated Privacy Policy.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us: