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Privacy Policy

PRVT MARKET LTD - prvtmarket.com

Last updated: March 2026

Effective date: March 2026. Subject to periodic updates.

Key points

  • PRVT MARKET LTD is the data controller for personal data collected through the platform.
  • We are in the process of incorporating in ADGM, United Arab Emirates.
  • We collect account, identity/KYC, financial, technical, and communication data to provide and secure services.
  • We do not sell, rent, or trade personal data.

Table of contents

1. Who We Are

PRVT MARKET LTD ("PRVT Market", "we", "our", or "us") operates the prvtmarket.com platform, which facilitates access to secondary market transactions in private company securities.

We are in the process of incorporating in the Abu Dhabi Global Market (ADGM), United Arab Emirates.

PRVT Market is the data controller for personal data collected through the platform. For any privacy-related queries, please contact us at legal@prvtmarket.com.

2. Scope of This Policy

This Privacy Policy describes how we collect, use, share, and protect personal data when you use prvtmarket.com or contact us directly. It applies to all users, registered or not. It should be read alongside our Terms of Use.

If you are based in the European Economic Area (EEA), including France, this policy is written to comply with the EU General Data Protection Regulation (GDPR). Your rights as an EEA data subject are set out in Section 9.

3. Personal Data We Collect

3.1 Account and Registration Data

  • Full legal name, email address, phone number
  • Username and password (stored in hashed, encrypted form)
  • Date and time of account creation

3.2 Identity and KYC/AML Data

As a platform that facilitates financial transactions, we are legally required to verify your identity before you can access transaction features.

  • Government-issued photo ID (passport or national identity card): document number, issuing country, expiry date, and a scan or image of the document
  • Proof of residential address (utility bill or bank statement dated within three months)
  • Date of birth and nationality
  • Source of funds and source of wealth declaration
  • Professional background and self-declared investment experience where requested

3.3 Financial and Transaction Data

  • Self-declared investment objectives, risk tolerance, and financial capacity
  • Bank account details where required for transaction settlement
  • Records of buy/sell interests submitted through the platform
  • Completed transaction records (reference, security, amount, date, counterparty reference)

3.4 Usage and Technical Data

  • IP address and approximate geolocation derived from it
  • Device type, operating system, and browser
  • Pages visited, features used, time on platform, and actions taken
  • Referral source and session timestamps

3.5 Communications

  • Emails and messages sent to us via any channel
  • Support ticket content and history
  • Survey responses and feedback

3.6 Data from Third Parties

We may receive data about you from identity verification providers (verification outcomes, fraud risk assessments, document authenticity results), sanctions databases (UN, EU, OFAC, UAE), and publicly available sources used in enhanced due diligence.

4. How and Why We Use Your Data

We process personal data only for specific, lawful purposes. Under the GDPR, each purpose requires a legal basis.

Account creation and access

Account data

Contract - Art. 6(1)(b)

Identity verification / KYC

Identity and KYC data

Legal obligation - Art. 6(1)(c)

Sanctions and PEP screening

Identity data, third-party data

Legal obligation - Art. 6(1)(c)

Transaction facilitation

Account, transaction, financial

Contract - Art. 6(1)(b)

Fraud prevention and security

All categories

Legitimate interests - Art. 6(1)(f)

Regulatory reporting

Identity, transaction data

Legal obligation - Art. 6(1)(c)

Platform analytics and improvement

Usage and technical data

Legitimate interests - Art. 6(1)(f)

Customer support

Communications, account data

Contract - Art. 6(1)(b)

Marketing (opt-in only)

Account and usage data

Consent - Art. 6(1)(a)

5. Sharing Your Data

We do not sell, rent, or trade your personal data.

We share personal data only in the following limited circumstances:

5.1 Service Providers: Identity verification and KYC/AML providers, cloud infrastructure and hosting providers, payment and settlement processors, communications platforms, and analytics providers.

5.2 Legal and Regulatory Disclosure: Disclosures to regulators, law enforcement agencies, or courts where required or permitted by law, including AML/CTF and tax reporting obligations.

5.3 Professional Advisers: Lawyers, auditors, or accountants where strictly necessary and confidential.

5.4 Business Transfers: Data may be transferred in a merger, acquisition, or sale of assets.

5.5 With Your Consent: We share data in other circumstances only with your explicit prior consent.

6. International Transfers

PRVT Market is being incorporated in ADGM, United Arab Emirates. ADGM has adopted data protection legislation (ADGM Data Protection Regulations 2021) modeled on the GDPR, providing an equivalent level of protection.

Where data is transferred to service providers in other countries, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other mechanisms recognized under applicable law.

You may request details of these safeguards by contacting legal@prvtmarket.com.

7. Data Retention

Identity and KYC/AML data: 5 years after the end of the business relationship (AML legal obligation)

Transaction records: 7 years from the relevant transaction date (financial records obligation)

Account data: Duration of account plus 2 years (legitimate interests - dispute resolution)

Communications and support: 3 years from the last communication

Usage and technical data: Up to 13 months (analytics, aggregated or anonymized after this period)

Marketing preferences: Until you opt out, or 2 years of inactivity (whichever comes first)

8. Cookies and Tracking Technologies

The platform uses cookies and similar technologies to operate correctly and understand platform usage.

  • Strictly necessary cookies: Essential for the platform to function (session authentication, security). Cannot be disabled.
  • Functional cookies: Remember your preferences.
  • Analytics cookies: Aggregate, anonymized usage statistics to help us improve the platform.
  • No advertising or cross-site tracking cookies are deployed.

You can manage cookies through your browser settings. Disabling strictly necessary cookies will prevent the platform from functioning correctly.

9. Your Rights

Depending on your location and applicable law, you may have the following rights:

  • Access: Request a copy of the personal data we hold about you and how we use it.
  • Rectification: Ask us to correct inaccurate or incomplete personal data.
  • Erasure: Request deletion where it is no longer necessary, subject to legal retention obligations.
  • Restriction: Ask us to pause processing in specific circumstances.
  • Portability: Request your data in a machine-readable format.
  • Object: Object to processing based on legitimate interests.
  • Withdraw Consent: Where processing is based on consent, at any time.
  • Complain: Lodge a complaint with your local supervisory authority.

To exercise any right, email us at legal@prvtmarket.com. We will respond within 30 days and may need to verify your identity.

If you are in France, your supervisory authority is CNIL (www.cnil.fr).

10. Security

We implement appropriate technical and organizational measures to protect personal data, including encryption of data in transit (TLS/HTTPS) and at rest, access controls limiting data to authorized personnel, secure storage of identity documents, and regular security reviews.

No internet transmission is completely secure. If you believe your account has been compromised, contact us immediately at legal@prvtmarket.com.

11. Children

The platform is not directed at persons under 18. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with data, contact legal@prvtmarket.com and we will promptly delete it.

13. Updates to This Policy

We may update this policy from time to time. When we make material changes, we will update the effective date and notify registered users by email or through a prominent platform notice. Your continued use of the platform after the updated policy takes effect constitutes acceptance.

14. Contact and Complaints

Controller: PRVT MARKET LTD

Email: legal@prvtmarket.com

Platform: prvtmarket.com

Jurisdiction: Abu Dhabi Global Market (ADGM), United Arab Emirates

If you are a resident of France or another EEA country and are not satisfied with our response, you have the right to lodge a complaint with your national data protection authority. In France, this is CNIL (www.cnil.fr).