Privacy Policy
What data is collected, on what legal basis, who it is shared with, how long it is kept and how to exercise your rights. Including the specific provisions of LGPD, LFPDPPP and Law 1581 of 2012.
The Sening Capital Privacy Policy describes the processing of personal data by Sening Capital Ltd as controller. Seven categories of data are processed: identification, contact, financial, professional, technical, behavioural and communication data. The legal bases are performance of the contract, compliance with KYC and AML legal obligations, legitimate interest and consent. Identification and transaction data is kept for a minimum of 5 years from the closure of the account. The company does not sell personal data to third parties.
1. Data controller
Sening Capital Ltd, with its registered office at 12 John Princes Street, London, Westminster, W1G 0JR, United Kingdom. Contact for data protection matters: [email protected].
2. What data is collected
| Category | Content | Legal basis |
|---|---|---|
| Identification | Full name, date of birth, nationality, document number | Performance of the contract; legal obligation |
| Contact | Address, email, telephone | Performance of the contract |
| Financial | Source of funds, payment details, trading history | Legal obligation (AML) |
| Professional | Trading experience, knowledge of the instruments, income level | Assessment of the service's suitability |
| Technical | IP address, device, browser, cookie identifiers | Legitimate interest (security, analytics) |
| Behavioural | Trading activity, pages visited | Legitimate interest (service improvement) |
| Communication | Records of emails and telephone calls | Service quality; evidential purposes |
3. Legal bases for processing
- Performance of the contract with the data subject.
- Compliance with legal obligations (KYC, AML, tax and reporting obligations).
- Legitimate interest (fraud prevention, infrastructure security, service improvement).
- Consent of the data subject (commercial communications and non-necessary cookies).
4. Purposes of processing
Opening and maintaining the account; identification and verification; execution of payment transactions; prevention of fraud and money laundering; provision of technical support; sending commercial communications where consent exists; and compliance with requests from regulators and authorities.
5. Disclosure to third parties
Data is disclosed to: payment service providers, to the extent necessary to execute the transaction; identity verification providers; liquidity providers, in anonymised form; auditors and legal advisers; regulators and competent authorities, following a legal request; and hosting and cloud service providers. The Company does not sell personal data to third parties.
6. International transfers
Data may be transferred to jurisdictions other than the Client's country of residence. Every transfer is accompanied by contractual safeguards providing protection equivalent to the level of protection in the data's country of origin.
7. Retention periods
Identification and transaction data is kept for a minimum of 5 years from the closure of the account, in accordance with anti-money laundering rules. Communication records are kept for 5 years. Data processed for marketing purposes is kept until consent is withdrawn. Once those periods expire, the data is deleted or anonymised.
8. Rights of the data subject
The Client has the right to: access their data; request rectification of inaccurate data; request erasure, to the extent it does not conflict with mandatory AML retention; restrict processing; obtain their data in a portable format; object to processing based on legitimate interest; withdraw consent for commercial communications; and lodge a complaint with the supervisory authority in their country.
How to exercise them: send your request to [email protected], evidencing your identity. Response time: 30 calendar days.
9. Regional provisions
For clients in Brazil, processing complies with the Lei Geral de Proteção de Dados (LGPD, Lei nº 13.709/2018). For clients in Mexico, with the Ley Federal de Protección de Datos Personales en Posesión de los Particulares. For clients in Colombia, with Law 1581 of 2012. For clients in Chile, Peru and Argentina, with the corresponding national legislation. The Client may contact the supervisory authority in their country: ANPD (Brazil), INAI (Mexico), SIC (Colombia).
10. Security
TLS 1.3 encryption, cryptographic hashing of passwords, role-based access control for staff, logging of access to data and periodic security testing are applied. In the event of a security breach that poses a risk to data subjects' rights, the Company notifies the affected individuals and the supervisory authority within the period laid down by law.
11. Minors
The services are not provided to persons under 18. Data relating to minors is not knowingly collected; if detected, it is deleted.
12. Changes to this policy
The new version is published on the website with the date indicated. In the event of material changes, a notification is sent by email.
Entity details
Sening Capital Ltd — registered office 12 John Princes Street, London, Westminster, W1G 0JR, United Kingdom, company registration number 11237561, licence FCA 806721.
All correspondence — legal matters, data protection, compliance and complaints — goes to the single address [email protected]. State the matter in the subject line so that the message reaches the right department.
In the event of any discrepancy between translated versions of this document, the English version prevails.
Frequently asked questions
Seven categories are collected: identification data (name, date of birth, nationality, document number), contact data (address, email, telephone), financial data (source of funds, payment details, trading history), professional data (trading experience and income level), technical data (IP address, device, browser, cookie identifiers), behavioural data and communication data (records of emails and calls).
No. The company does not sell personal data. It is disclosed only to payment service providers to the extent necessary for the transaction, to identity verification providers, to liquidity providers in anonymised form, to auditors and legal advisers, to regulators and authorities on a legal request, and to hosting and cloud service providers.
Identification and transaction data is kept for at least 5 years from the closure of the account, in accordance with anti-money laundering rules. Communication records are kept for 5 years. Data processed for marketing purposes is kept until consent is withdrawn. Once those periods expire, the data is deleted or anonymised.
Send your request to [email protected], evidencing your identity. The response time is 30 calendar days. You may request access, rectification, erasure (to the extent it does not conflict with mandatory AML retention), restriction of processing, portability, objection to processing based on legitimate interest and withdrawal of consent for commercial communications.
For clients in Brazil the Lei Geral de Proteção de Dados applies (LGPD, Lei nº 13.709/2018); for Mexico, the Ley Federal de Protección de Datos Personales en Posesión de los Particulares; for Colombia, Law 1581 of 2012; and for Chile, Peru and Argentina, the corresponding national legislation. You may contact your national authority: ANPD (Brazil), INAI (Mexico), SIC (Colombia).
In the event of a security breach that poses a risk to data subjects' rights, the company notifies the affected individuals and the supervisory authority within the period laid down by the applicable rules, describing the nature of the incident, the categories of data affected and the measures taken.