Privacy Policy

1.1 In this Privacy Policy ("Policy"):

• (a) "Chargeback Proceedings" means any dispute, claim, reversal request, or related process initiated by the User or on the User's behalf through a payment card network, financial institution, payment processor, or any analogous mechanism, including but not limited to chargeback requests, payment disputes, retrieval requests, and fraud claims relating to transactions conducted on or through the Platform.
• (b) "Communications Data" means any and all records of interaction between the Company and the User, including but not limited to: live chat transcripts, chatbot session logs, support ticket correspondence, email communications, in-platform messaging, voice or video call recordings and transcripts (where applicable), form submissions, questionnaire responses, onboarding documentation, and any other data or metadata generated in the course of communications between the parties, howsoever transmitted or recorded.
• (c) "Company," "we," "us," and "our" mean Solo Clash L.L.C-FZ, a limited liability company registered in the Meydan Free Zone (Meydan Grandstand, 6th Floor, Meydan Rd, Nad Al Sheba 1, Dubai, UAE; license number: 2538558.01).
• (d) "Data Subject" means an individual whose Personal Data is processed by us.
• (e) "Personal Data" means any information relating to an identified or identifiable natural person.
• (f) "Proceedings" means any judicial, arbitral, regulatory, administrative, or quasi-judicial proceedings, whether commenced, threatened, or anticipated, including without limitation civil litigation, arbitration, mediation, regulatory investigations, enforcement actions, compliance reviews, and any dispute resolution procedures.
• (g) "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• (h) "Services" means the website soloclash.com, proprietary trading challenges, evaluation programmes, funded trading accounts, and any related services offered by us.

2.1 This Policy sets out how the Company collects, uses, stores, transfers, and protects Personal Data of Data Subjects who access or use the Services.

2.2 This Policy sets out the legal basis we rely on for each purpose (section 7). Where a purpose relies on your consent, we ask for it separately and you may withdraw it at any time; using the Services is not treated as consent.

2.3 This Policy applies to all Personal Data processed by the Company, whether collected online via our Site or offline through other channels.

3.1 The Company acts as the Data Controller for Personal Data collected through the Services.

3.2 Our contact details are:

Solo Clash L.L.C-FZ
Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
Email: [email protected]

4.1 We may collect and process the following categories of Personal Data:

• (a) Identification Data: name, date of birth, nationality, identification documents.
• (b) Contact Data: email address, phone number, postal address.
• (c) Account Data: username, password, profile preferences.
• (d) Financial Data: payment details and billing information.
• (e) Trading Data: performance metrics, challenge results, evaluation outcomes.
• (f) Technical Data: IP address, device identifiers, browser data, and cookies. For the Site measurement described in section 5.2, the IP address and browser user-agent are used only to derive an identifier and are not stored.
• (g) Communication Data: correspondence and support requests.

4.2 We do not knowingly collect Personal Data from individuals under the age of 18. By creating an account, you confirm that you are at least 18 years of age.

5.1 We collect Personal Data:

• (a) Directly from you when you register, submit identification, or communicate with us.
• (b) Automatically through your use of our Site and Services, including through cookies and analytics tools.
• (c) From third parties, including payment processors, analytics providers, and identity verification partners.

5.2 Part of that automatic collection measures the Site itself rather than an individual, and is deliberately built to hold as little as possible. When a page is opened we may record, without storing a cookie or any other identifier on your device: the page and language version, an approximate country derived from the network the request arrived on, a device category (desktop, mobile, or tablet), how long the page was actively open, and which purchase option was selected where the page offers one. Each record carries an identifier produced by irreversible hashing that changes every day, so records cannot be followed from one day to the next. Your IP address and browser user-agent string are used to produce that identifier and are not themselves stored. Requests identified as automated are discarded, and the measurement is not carried out at all where your browser sends a Global Privacy Control or "Do Not Track" signal.

5.3 Separately, and only where you have accepted cookies and arrived through one of our own campaign links, we place a random identifier in a cookie (sc_journey) so that the pages of that visit can be read together rather than as unconnected page views. What is recorded under it is the route of each page opened, the language version, whether a plan was selected and which one, and whether a form or newsletter signup was completed. It holds no name, no email address, no payment detail and no campaign detail, it is never shared, and the identifier cannot be read by scripts in your browser. This is the only processing described in this Policy that links your activity across more than one page, which is why it happens only with your consent. See the Cookie Policy for the cookie itself.

6.1 We process Personal Data for the following purposes:

• (a) To create, manage, and maintain user accounts.
• (b) To process payments and verify user identity.
• (c) To administer proprietary trading challenges and funded accounts.
• (d) To comply with legal obligations, including AML and KYC requirements.
• (e) To improve our Services and user experience.
• (f) To communicate with users about their accounts and our Services.
• (g) To detect, prevent, and address fraud, security issues, or misuse.
• (h) To measure, in aggregate, how our pages, articles, and marketing campaigns perform.

7.1 We process Personal Data based on the following legal bases:

• (a) Contractual necessity – to perform obligations under the Terms & Conditions.
• (b) Consent – where users have provided consent (e.g. for marketing).
• (c) Legal obligation – to comply with applicable law.
• (d) Legitimate interests – to operate and develop our Services and protect our business.

7.2 The measurement described in section 5.2 relies on legitimate interests, specifically our interest in knowing whether our own pages and campaigns work. We rely on that basis rather than consent because the measurement stores nothing on your device, is confined to this Site, builds no profile, is never shared with a third party for that party's own purposes, and is used only in aggregate. It also applies to every visitor equally, which is what makes the resulting figures an honest comparison rather than a picture of whoever agreed to be counted. You may object at any time under section 10.3, and the measurement does not run where your browser sends a "Do Not Track" signal.

7.3 Cookies that are not strictly necessary, including analytics and advertising cookies, rely on consent given in the cookie banner and are addressed in the Cookie Policy. That consent can be withdrawn at any time through Cookie Preferences in the footer of every page, and withdrawing deletes the record described in section 5.3 rather than merely stopping it.

8.1 We may share Personal Data with:

• (a) Third-party service providers and processors.
• (b) Regulatory authorities or law enforcement agencies.
• (c) Professional advisers.

8.2 Personal Data may be transferred outside the UAE, including to the European Union and to the United States, where several of our service providers are established. Where such transfers occur, we ensure appropriate safeguards in accordance with applicable data protection laws.

8.3 The User hereby expressly consents to, and authorises, the Company to collect, store, retain, and use Communications Data for the following purposes:

• (d) Defending Against Claims and Proceedings: The Company may access, review, preserve, and submit Communications Data as evidence or supporting documentation in any Proceedings in which the Company is or may become a party, including without limitation claims brought by the User or on the User's behalf, third-party claims arising from the User's use of the Platform, and regulatory inquiries directed at the Company.
• (e) Chargeback and Payment Dispute Resolution: The Company may use Communications Data, including transaction logs, user activity records, session data, and any correspondence relating to the relevant transaction or service, to contest, rebut, or respond to Chargeback Proceedings, payment reversals, or fraud claims. The User acknowledges that such data may be shared with payment processors, acquiring banks, card networks, and other relevant financial institutions solely to the extent necessary for the resolution of such disputes.
• (f) Regulatory and Compliance Obligations: The Company may retain and disclose Communications Data to competent regulatory authorities, supervisory bodies, or law enforcement agencies where required or permitted by applicable law, or where the Company reasonably determines such disclosure is necessary to demonstrate compliance with its legal and regulatory obligations.
• (g) Fraud Prevention and Abuse Detection: The Company may use Communications Data to investigate, detect, and prevent fraudulent activity, abuse of the Platform, or breaches of the Company's Terms and Conditions, and to take appropriate remedial action thereupon.

9.1 Personal Data will be retained only as long as necessary for the purposes described in this Policy or as required by law.

9.2 The measurement records described in section 5.2 have definite periods:

• (a) Records of visits that did not arrive through one of our own campaign links are deleted within 92 days of collection. A daily job first reduces each completed day to totals, which are counts only and hold no record of an individual visit, and then deletes the individual records for that day.
• (b) Records of visits that arrived through one of our own campaign links, and records of article reading, are retained for as long as the performance of that campaign or article is being assessed. These records hold no cookie identifier, no IP address, and no user-agent string, and the daily identifier they carry cannot be reversed.
• (c) The consented record described in section 5.3 is deleted in full 30 days after it begins, and immediately if you withdraw your consent before then. Nothing derived from it is kept after deletion.

9.3 Upon request, and subject to legal obligations, we will delete or anonymise Personal Data.

10.1 Data Subjects have the right to:

• (a) Access their Personal Data.
• (b) Request correction of inaccurate data.
• (c) Request deletion of their data.
• (d) Withdraw consent where applicable.
• (e) Object to or restrict processing.
• (f) Request data portability.

10.2 Requests to exercise these rights should be submitted to [email protected].

10.3 To object to the measurement described in section 5.2, write to [email protected]. It also stops on its own if your browser sends either the Global Privacy Control signal or the older "Do Not Track" setting, where your browser still offers them. Cookie consent is separate and is withdrawn through Cookie Preferences in the footer.

11.1 We implement appropriate technical and organisational measures to protect Personal Data against unauthorised access, loss, misuse, alteration, or destruction.

11.2 While we strive to use commercially acceptable means to protect Personal Data, no transmission over the internet or electronic storage method is 100% secure.

12.1 Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of such third parties, and users are encouraged to review their policies.

13.1 We may amend this Policy from time to time. Updated versions will be posted on our Site with an updated "Last Updated" date. Continued use of the Services constitutes acceptance of the revised Policy.

14.1 This Policy and any non-contractual obligations arising out of or in connection with it shall be governed by and construed in accordance with the laws of the Dubai International Financial Centre (DIFC) and applicable UAE law.

14.2 The courts of the DIFC shall have exclusive jurisdiction to settle any dispute arising out of or in connection with this Policy.

15.1 For any questions regarding this Policy or your Personal Data, please contact us at: [email protected]