Privacy Policy

APME FX Trading Europe LTD (hereinafter referred to as the "Company") is committed to protecting your privacy and to handling your data transparently. The Company recognizes the importance of maintaining the confidentiality and privacy of your personal information. By entrusting us with your data, we would like to assure you of our commitment to keeping this data private. We have taken measurable measures to protect the confidentiality, security, and integrity of your data.

If you are an individual, APME FX Trading Europe LTD is the processor of personal data and the controller of your personal data in connection with the processing activities of your personal data as set out below.

For the purposes of this statement:

a) Personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

b) Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its appointment may be laid down in Union or Member State law.

c) Processor means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.

The purpose of this Privacy Notice is to provide you with an overview of how the Company collects and processes your personal data and to inform you of your rights under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation - hereinafter referred to as the "GDPR"),  as well as the Act on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of Such Data of 2018 (Act 125(1)/2018) (hereinafter referred to as the "Laws"), as amended. This statement is addressed to individuals who are current, past or potential clients of the Company and their representatives (for example, attorneys acting on their behalf).

As a follow-up to the above, this statement provides you with information about the circumstances under which the Company may share your personal data with any relevant party related to the Company, such as payment service providers.

As part of the client account opening procedures and ongoing obligations, the Company must comply with the legislative framework currently in place with the Cyprus Securities and Exchange Commission (CySEC). In particular, the Company must comply with its legal obligations under the Prevention and Suppression of Money Laundering and Terrorist Financing Act 2007 to 2021 and the Anti-Money Laundering Directive 2020 (R.A. D 125/2020) when ascertaining the Client's economic profile and preventing money laundering, as well as comply with the relevant record-keeping obligations under the European Commission Delegated Regulation (EU) 2017/565 (hereinafter referred to as the "Delegated Tax Act"). Regulation") and Law 87(1)/2017 to determine the suitability and adequacy of each client on the basis of the services offered by individual Cypriot investment firms (Suitability and Adequacy Tests) and records of telephone conversations, transactions with clients, FATCA and CRS.

Based on the above, the Company is obliged to request, collect and store the following data for at least five (5) years:
• Name and surname
• Date of birth
• Place of birth
• Nationality
• A copy of your passport and/or identity card.
• Utility bill (including the client's full address)
• Tax identification number
• Tax residence
•Telephone number
• Email
• Employer name
• Profession
• Employment sector
• Gross annual income
• Net worth
• Expected turnover
• Amount to invest
• Bank account details
• Knowledge and experience

The Company may collect such information directly from you (during the account opening process) and/or from other persons, including, but not limited to, credit reference agencies, fraud prevention agencies, banks, other financial institutions, third-party verification service providers (the Company uses Lexis-Nexis for verification and background check purposes) and public registry providers.

The Company may obtain such information directly from you (during the account opening process) and/or from other persons, including, for example, credit reference agencies, fraud prevention agencies, banks, other financial institutions, third-party verification service providers (the Company uses Lexis-Nexis for verification and background check purposes) and providers of public registers.

The Company may also collect information about your use of our website, such as the pages visited, frequency, duration of visit, and business activities. The Company also keeps records of your business conduct, including:
• The products you trade and their performance.
• Historical data about the trades and investments you have made, including the amount invested.
• Historical data about your payment and withdrawal activities.

In addition to the above, the Company may also request additional information in order to improve its services to you (existing or potential clients) or our activities (if you are our business data provider) under our relevant contract, or to comply with applicable regulations.

The Company records any electronic, telephone, personal or other communication we have with you in connection with the services provided by the Company to you and the relationship with you. The said records will be the exclusive property of the Company and will constitute evidence of communication between the Company and you.

As part of the use of your personal data for the purposes set out above, we may disclose your data to:


(a) service providers and specialized advisors who have been contracted to provide us with IT, financial, regulatory, compliance, accounting and/or other services.
(b) Regulatory authorities.
(c) To anyone authorized by you.
(d) Competent authorities for the purpose of investigating or preventing fraud, money laundering or other illegal activity.
(e) Trade Archives or similar bodies.


Employees of the Company in order to perform their duties in support of the Agreement between us or to ensure
the efficient functioning of our Platform, the automated order features and the Trading Data;
The Company requires organizations outside the Company that process or obtain personal data to confirm confidentiality
This information, they are committed to respecting each individual's right to privacy and to comply with all applicable data protection laws and this Privacy Notice.

The Company will use, store, process and handle your personal data in accordance with the General Data Protection Regulation 2016/679 and the Personal Data Processing (Personal Data Protection) Act 2001, as amended.

Your personal data (not publicly available information and/or data already held by the Company without complying with the provisions of the General Data Protection Regulation) will be collected and processed explicitly and specifically only for the purposes for which it was collected (purpose limitation), whereby the Company must only request the information necessary in relation to the purposes for which it was collected.

We may transfer your personal data outside of the European Economic Area. If we make such a transfer, we will ensure that the transfer is lawful and that appropriate security measures are in place to protect your personal data in accordance with applicable regulations. Furthermore, the Company will follow the instructions of the European Commission in this matter and will ensure that the third country to which your Data may be transferred is recognized by the EU Commission as adequate in terms of the protection of your personal data.

The use of your personal data is based on a lawful basis:


(a) to perform our contractual obligations to you
(b) to comply with legal and regulatory requirements
(c) to pursue our legitimate interests


In accordance with the above points, we are legally obliged to process your personal data. If our use of your personal information does not fall under one of these three lawful bases, we need your consent. Such consent will be given in accordance with the Client Agreement which we provide to you during the account opening procedure and which is also available on the Company's website(s). The Company will rely on the consent provided as its legal basis for processing your personal data. You have the right to withdraw this consent at any time by contacting us by phone or e-mail at dataprotection@apmefx.com.
If you are a natural person and the use of your personal data requires your consent, the Company will require that your consent be given freely, specifically, informed and unambiguously expressing your wish, which by a statement or a clear affirmative act constitutes consent to the processing.
If, in any case, you feel compelled to agree, or if you do not agree, you suffer negative consequences, your consent will not be valid. In addition, your consent must not be bound as an integral part of the Terms and Conditions, as doing so would mean that you did not freely give your consent.

In certain circumstances, the Company may process your data without your consent. The following cases are considered to be the most significant:

• The processing is necessary for compliance with a legal obligation to which the controller is subject.

• Processing is necessary for the performance of a contract to which the data subject is a party or to take measures at the request of the data subject prior to entering into a contract.

• The processing is necessary to protect the vital interests of the data subject.

• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority or of a third party to whom the data are disclosed.

• Processing is necessary for the purposes of the legitimate interests of the controller or of a third party to whom the personal data are disclosed, provided that these interests override the rights, interests and fundamental freedoms of the persons.

The Company stores your personal data for as long as it has a business relationship with you (a natural person). After the termination of the business relationship, we may retain your data for a maximum of five (5) years in accordance with the laws governing the company. The Company may retain your personal data for more than five (5) years for legal, regulatory, and/or other mandatory reasons.

The retention period will be determined taking into account the type of information collected and the purpose for which it is collected, taking into account the requirements applicable to the situation and the need to destroy outdated, unused information as soon as reasonably possible.

The Company has taken all appropriate organizational measures to ensure the security of your personal data. In addition, the Company has implemented internal training for its employees to mitigate any risks that may affect your data. Employees who process your data are trained to respect the confidentiality of customer information and the privacy of individuals. We consider breaches of your privacy to be a top priority and the company will strengthen its internal procedures to prevent such incidents.

The Company has implemented procedures regarding the protection of your data. Only employees of the Company who need to have access to the information to enable the continuity of the contract between you and the Company have access to your data.

In addition, we store personal information in a combination of secure computer storage, secure servers, and from time to time, and if we deem it necessary, we keep it in paper files. The Company has taken all necessary measures to protect the personal data it holds against misuse, loss, unauthorized access, alteration or disclosure.

Although we will use all reasonable efforts to protect your information, please note that the use of the Internet is not completely secure and, for this reason, we cannot guarantee the security or integrity of any personal information transmitted from or to you via the Internet.

You may notify the Company at any time that your information has changed or that you wish the Company to delete the information we hold about you by sending an email to dataprotection@apmefx.com, we will change or delete your information in accordance with your instructions, except where we are required to retain your information for regulatory or legal purposes in order to provide you with the requested Services or to maintain reasonable business records.

As an individual, you have the right to obtain a copy of any personal data we hold about you and to notify us of any inaccuracies found. In addition, you can also ask for a justification for holding such information.

To make a request, please contact us, verify your identity and indicate what information you request. You can contact us via email at dataprotection@apmefx.com.

As an individual, you have the right to request confirmation as to whether we are processing your personal data and to obtain a copy of any personal data we hold about you In addition, you can also request a justification for the retention of such information. If you require additional copies, we may charge you a reasonable administration fee.

To make a request, please contact us, verify your identity and indicate what information you request. You can contact us via email at dataprotection@apmefx.com.

If the personal data we hold about you is inaccurate or incomplete, you have the right to have it corrected. You may inform the Company at any time that your data has changed or that you wish the Company to delete or correct the data we hold about you by sending an email to dataprotection@apmefx.com, we will amend, correct or delete your data in accordance with your instructions, except where we are required to retain your data for regulatory or legal purposes;  to provide you with the services you have requested or to keep reasonable business records.

Under certain conditions set out in applicable law, you have the right to request the Company to restrict the processing of your personal data.

Under certain conditions, you have the right to request that the Company transfer the data we have collected to another organization or directly to you.

You have the right to object to the processing of your personal data at any time on grounds relating to your situation.

We generally do not make decisions about you solely on the basis of an automated process (e.g. through automated profiling) that affects your ability to use the Services or otherwise has a significant impact on you. However, if we do so, you have the right to be informed and you may request that such a decision not apply to you, unless we can demonstrate to you that such decision is necessary for the conclusion or performance of a contract between you and us.

If you have any questions about this Privacy Notice, would like to access or change your information, or have a complaint, or if you have any questions about security on our website, you may email us at dataprotection@apmefx.com.

In addition, if you are not satisfied with the quality of the services we have provided to you in relation to the processing of personal data, you as an individual have the right to lodge a complaint with our supervisory authority, which is the Data Protection Commissioner of the Republic of Cyprus.

This notice is subject to change without notice. For this reason, we recommend that you check for updates from time to time.

Last updated: September 2022