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Privacy Policy

A. Purpose of the Policy

This Privacy Policy (hereinafter the "Policy") provides you with information about how your data are processed.

When using our services we process personal data of our customers ("you", "your" or the "Client").

Herein below you will find information regarding the following:

1. The controller of personal data is H EDU SOLUTIONS LTD, with its registered office at 10 Coldbath Square, London, England, EC1R 5HL with Registration Number: 16657142 operating as Zorrox Fund (hereinafter referred to as "we", "our", "our Company" or "Controller").

You can contact us at support@zorrox.fund regarding any questions and the exercise of rights relating to the processing of your personal data.

2. We are committed to securing your personal data and your privacy. As part of this commitment, it is important for us to be transparent about how we handle the information that we (or others on our behalf) collect about our users, when we collect information about them, and how we use such information.

3. This Policy provides information regarding the use of data that we collect about the users of the https://zorrox.fund/ website and the various services offered by the Company over any of its related products and services. By accessing and using the website or the services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy.

4. This Policy is part of and should be read in conjunction with Our Terms of Service available at the Company's website.

5. In this Policy, any reference to personal data is to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that we have or that we have access to.

B. Collection of Users' Personal Data

1. In this section, you can read general information about which of your personal data we collect and how we collect it. All information on the basis of which we can directly or indirectly identify you or which is related to you is considered personal data.

2. We obtain most of the data we collect about you directly from you in connection with your use of our services. This includes, in particular:

  • Data that you provide to us yourself, especially when you register on the website, enter information into your user account, order services, participate in our events and projects, or when you communicate with us through customer support or social networks. These are identification and contact data, specifically the name, surname, telephone number, e-mail address, postal address, date of birth, username and password, and business identification number or tax registration number, if you are an entrepreneur; payment data, such as bank details; and other data, such as records of communication between you and our company or details of any warranty claims.
  • Data that we automatically collect when you use our services. These are data about your device (such as the IP address, device type, operating system, browser used, connection provider); website usage data (such as the date, time and duration of visit, a country from which you visit the website, website browsing history), and data on the use of services (such as the login and logout information, your account settings, the value of your fictitious capital, your account currency, business strategy).

3. Some data about you is provided to us by third parties, such as providers of trading platforms that you choose for use of our services, and social network operators if you decide to link your social networking accounts to an account on the website. For information on how your personal data are processed by trading platform providers and social network operators for their own purposes, please refer to the privacy policies of those parties.

4. You are not obligated to provide us with any personal data about you. However, in some instances, not providing such personal data will prevent us from providing you with the services you requested to receive and will prevent your use of the services or a part of it.

C. What types of Personal Data do We collect?

We (or others on our behalf) may collect the following types of Clients' Personal Data:

a. When you register:

Upon the creation of an account with us, you provide us with certain information that can be used to identify you, including your full name, email address and country of residence, proof of residential address as well as any other information as the Company may deem necessary to collect at the point of registration.

b. KYC AML information:

We may require you to provide us or any other third party on our behalf with additional information for the purpose of compliance with Know-Your-Customer ("KYC") and Anti-Money Laundering applicable legal requirements and best practices.

c. Communication information:

When you contact us, though any channel whatsoever, or when you subscribe to our website or social media networks, you may provide us with your full name, email address and the content of your communication with us.

d. Website or Services usage information:

This information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, crash reports and type of browser used, and information regarding the device you used. Some of this information may not identify you personally, and therefore does not constitute Personal Data.

e. Website or Services activity information:

Whenever you use the website, we monitor your use of the website and record your activity. The information that we gather about you in this context includes any activity that you perform in the website or services; please be advised that we may receive your trading data from the services, the length of time you will be watching content on the website, your interaction with content in the website, etc.

f. Aggregate Information:

We will also create statistical, aggregated and anonymized data relating to our users and the service for analytical purposes, including business development and services improvements. We will share this aggregate information with our third-party partners. Aggregated data is derived from personal information and user data but in its aggregated form it does not relate to or identify any client or individual or any specific user's data. This data is used to understand our customer base and to develop, improve and market our Services.

D. The Purposes of The Processing of Personal Data

We process your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

We will not process your Personal Data unless there is a legal basis for such processing.

The legal bases according to which the Company may process your Personal Data are as follows:

Legitimate Interests - Processing is necessary for the purposes of provision of the services, or any other legitimate interests pursued by the Company or by a third party. For example, to improve our services, we will use the data collected during your use of the services to enhance our website or services, or for the exercise or defence of legal claims.

Consent - Your consent that the Company will process your Personal Data for one or more specific purposes. For example, for the purpose of sending you marketing materials.

E. How Do We Use Personal Data?

We may use personal data for the following purposes:

  • to operate the website and provide the services;
  • to contact you for the purpose of operational purposes;
  • to personalize content and offers for you;
  • to respond to your queries, requests and/or complaints;
  • to send you materials regarding the services, events and other information we think will be of interest to you, subject to your consent;
  • to analyze and improve the services, as well as to develop and offer new services;
  • to analyze and track usage to determine the usefulness or popularity of certain content and to better understand the online activity of the website users;
  • monitor and analyze trends, usage and activities in connection with the services;
  • to perform and maintain various activities supporting the offering and provision of the services, including, but not limited to, the services (such activities include back-office functions, business development activities, strategic decision making, financing management, third party services integration etc.);
  • to protect our and third parties' interests, rights and assets, including detecting, investigating and preventing fraudulent transactions or unauthorized or illegal activities and initiation or exercise or defense of legal claims and preventing them; and
  • to perform KYC checks.

F. How do we store personal data and how are they secured?

We process your personal data in an encrypted database on computers and other devices. In order to ensure protection against unauthorized access or unauthorized alteration, disclosure or destruction of the data that we collect and process, we have adopted organizational and technical measures to secure them, which we strictly adhere to.

G. How long do we process your data?

Personal data are processed to the extent necessary to fulfil the purposes described above and for the time necessary to achieve those purposes or for a period directly stipulated by law. Thereafter, the personal data are deleted or anonymized.

Generally, personal data will be kept for the entire period of the contractual relationship and for a reasonable period of time after the end of the contractual relationship. Most data are retained by virtue of legal obligations for the storage of data (in particular under accounting and tax regulations) or will be anonymized after such period has elapsed.

H. Sharing Personal Data with Third Parties

We may share your Personal Data with the following entities, who will process such data in compliance with applicable law and their respective privacy policies:

  • Our affiliates and subsidiaries;
  • Third-party service providers, including but not limited to providers of trading platforms, payment processors, analytics providers, identity verification services, cloud infrastructure providers, customer support tools, and other technology and operations partners who process data on our behalf;
  • Business partners involved in the co-development, maintenance, or promotion of the services;
  • Professional advisors such as auditors, legal counsel, tax advisors and consultants;
  • Governmental, regulatory, or judicial authorities, as required by applicable law, regulation, legal process, or enforceable government request;
  • Any third party in the context of a potential or actual corporate transaction, including a merger, acquisition, reorganization, sale of assets, or bankruptcy proceedings, to the extent necessary to facilitate such transaction.

We require all third parties with whom we share Personal Data to maintain appropriate security measures and to process such data only in accordance with our instructions and applicable data protection laws.

We do not sell, rent, or otherwise distribute your Personal Data to third parties for their own marketing purposes without your explicit prior consent.

I. Cookies

We use "cookies" to improve the functionality of our website and to enhance your online experience. A cookie is a small piece of data stored on your device. A cookie often includes an anonymous unique identifier that allows us to distinguish between individual visitors. The information collected and stored through the cookie does not usually include your name or address.

Most cookies stored on your device through our website are so-called "session cookies", which are automatically deleted from your device after the end of the browser session. Other cookies will remain stored on your device until their expiration date (unless you delete them before that date), and they will enable us or our partners (third-party cookies) to recognize your browser during your next visit. You can set your browser to block all cookies (including cookies associated with our services) or to indicate when a cookie is being set. However, some features or services available on our website may not function properly without cookies.

When you visit our website, we will use the following cookies:

  • Strictly necessary cookies: these cookies are needed in order to enable the use of the core functionalities of the website (e.g. allow registered clients to authenticate) and are not stored on the client's device.
  • Analytical cookies: these cookies are used to track visitor interactions with the website and their behavior on the website. They are stored on the visitor's device for a period of time. We use analytical cookies (including Google Analytics) to improve the functionality and content of the website.
  • Marketing cookies: these cookies are used to display personalized advertisements on the website and third-party websites to visitors of our website. They are stored on the visitor's device for a period of time. We use marketing cookies to display personalized advertisements.

J. Links to Third-Party Websites

Please note that certain portions of the website or services may contain links to other websites or applications for your convenience and information. We do not have ownership or control over any external websites. Other websites and applications may also reference or link to our website. We do not control these third-party websites and applications, nor the collection and processing of Personal Data by these entities. Therefore, we are not responsible for the privacy practices. This Policy does not apply to any actions taken via such websites and applications.

Whenever you access such third-party websites and applications, we recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data.

K. Clients' Rights in respect of Personal Data

You can exercise all your rights mentioned below, including your right to erasure of personal data and the withdrawal of your consent, by sending a request to us via email at support@zorrox.fund alternatively you can contact us via livechat. There are no specific words that you must use in your request, but please be specific enough, so we can help you with your request (e.g. identify yourself, specify the right you wish to exercise, what action you wish us to take, details of what personal data you want erased/deleted, etc.).

In addition to the processing right of your personal data you have the following rights:

Right of access to personal data

You can ask us at any time to send you a confirmation as to whether or not your personal data are being processed. If we process your data, we will provide you with further details on the processing. If you request it, we will also provide you with a copy of the personal data processed. Please note that the first copy is free of charge, but later copies will be provided for a small fee.

Right to rectification of personal data

If we process your personal data inaccurately, you can notify us of this fact, and we will rectify the inaccurate personal data without undue delay. If you register on the Website, you will be able to rectify and amend your personal data yourself by editing your user account.

Right to erasure of personal data – "Right to be forgotten"

You have the right to obtain from us the erasure of personal data concerning you without undue delay in the following cases:

  • If the data are no longer necessary in relation to the purposes for which we have collected or otherwise processed them;
  • If you withdraw your consent to their processing and, at the same time, there will be no other legal ground for their processing (this only applies in the cases where we process personal data on the basis of your consent);
  • If you object and there are no overriding legitimate grounds for the processing, or if you object to the processing for direct marketing purposes; or
  • If your personal data are processed unlawfully.

We will not be able to act on the request for the erasure of personal data if their processing is necessary for exercising the right of freedom of expression and information, for compliance with any of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise, or defense of our legal claims, or for other reasons provided for by law.

Right to data portability and to the provision of data in a machine-readable format

In the case of automated processing based on your consent or performance of the contract, you have the right to receive the data in a structured, commonly used and machine-readable format and to have them transmitted by us to another personal data controller.

Right to object

If we process personal data on the basis of our legitimate interest, you have the right to object to such processing. If you file such an objection, we will not be able to process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests or rights and freedoms, or for the establishment, exercise or defense of our legal claims.

In case we process your personal data for marketing purposes about our products and services, we will terminate the processing without undue delay upon receipt of the objection. In such a case, we will no longer be able to send you offers of our products and services.

Right to withdraw consent

If processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on the consent given before its withdrawal.

Right not to be the subject of automated decision-making

Except where processing is necessary for entering into, or performance of, a contract, where this is permitted by applicable law, or based on your express consent, you have the right not to be the subject of any decision which is based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you to a significant extent.

L. Transfer of Personal Data to a third country or an international organization

Clients' Personal Data may be transferred to a third country (i.e. jurisdictions other than the clients' residence) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Clients' Personal Data and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.

If the client is an EEA resident, please note that these safeguards and protection will be available if any of the following are met:

  • The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR");
  • The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
  • The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR.

The Client may request that the Company provides him with details concerning the safeguards employed by it to protect the Personal Data that are transferred to a third country or an international organization, by sending an email to the following address: support@zorrox.fund.

M. Changes to the Policy

We may amend the terms of this Policy unilaterally, from time to time. Whenever we amend this Policy, we will notify you of such amendments by publishing the updated Policy on the website. In addition, when we make significant amendments to this Policy, we will strive to inform you about such amendments via means of communication we believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on our website. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our website or the designated page on the website.

N. Contact Details

For any queries relating to this Policy, please contact us at support@zorrox.fund.

O. Cross-Entity Transfer to Licensed Investment Entity

Where a Client successfully completes the evaluation or challenge phase provided by H EDU SOLUTIONS LTD, the Client may become eligible to apply for onboarding with Zorrox Ltd, a licensed Full Investment Dealer (excluding underwriting) incorporated in the Republic of Mauritius and regulated under applicable Mauritius financial services legislation ("Zorrox").

Successful completion of the evaluation phase does not constitute automatic acceptance, approval, or onboarding with Zorrox.

H EDU SOLUTIONS LTD may transfer certain Personal Data to Zorrox for onboarding assessment purposes, including but not limited to:

  • Full name and contact details;
  • Date of birth and nationality;
  • Identification and proof of address documents;
  • KYC/AML documentation and verification results;
  • Trading performance and evaluation results;
  • Account and transaction history.

The decision whether to accept a Client for regulated services rests solely with Zorrox in its capacity as a licensed investment dealer and independent data controller. Zorrox reserves the right to conduct its own compliance review, risk assessment and due diligence procedures.

As part of such review, Zorrox may request additional, updated, renewed or enhanced KYC/AML documentation, including but not limited to renewed proof of identity, proof of address, source of funds documentation, sanctions screening confirmations, or any other information required under applicable regulatory obligations.

If the Client does not provide the requested documentation, or if Zorrox determines that onboarding criteria are not satisfied, Zorrox may decline the onboarding application in accordance with its regulatory obligations.

Zorrox acts as an independent data controller in respect of Personal Data received and will process such data in accordance with its own Privacy Policy and applicable regulatory requirements.

As Zorrox is incorporated in Mauritius, this constitutes a transfer of Personal Data outside the United Kingdom. H EDU SOLUTIONS LTD ensures that appropriate safeguards are implemented in accordance with the UK GDPR and the Data Protection Act 2018, including inter-company data protection agreements and contractual safeguards designed to protect Client data.

By applying for onboarding with Zorrox following successful completion of the evaluation phase, the Client acknowledges and expressly consents to such cross-entity transfer of Personal Data for regulatory and operational purposes.

Clients may request further details regarding the safeguards implemented for such international transfer by contacting support@zorrox.fund.