Vertex Capital & Tech Limited
1. INTRODUCTION
Vertex Capital & Tech Limited ("we", "us", "our", or "the Company"), trading as Vorum Capital, is committed to protecting the privacy and personal data of its clients and website visitors. This Privacy Policy explains how we collect, use, process, store, and share your personal information when you use our website (vorumcapital.com) or our services.
By using our website or opening a Trading Account, you acknowledge that you have read and understood this Privacy Policy.
Notice for Brazilian Residents: This Privacy Policy incorporates provisions designed to comply with the Lei Geral de Proteção de Dados (LGPD — Law No. 13.709/2018). Your rights under the LGPD are described in Section 9.
2. IDENTITY OF THE DATA CONTROLLER
Company Name: Vertex Capital & Tech Limited
Trading Name: Vorum Capital
Registration: IBC No. 2026-00522, Saint Lucia
Address: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia
Website: support@vorumcapital.com
3. PERSONAL DATA WE COLLECT
3.1 Data You Provide Directly
| Category | Data Points |
|---|---|
| Identity Data | Full legal name, date of birth, nationality, country of birth |
| Contact Data | Email address, phone number, residential address |
| Identification Data | Government-issued ID (passport, national ID card, driver's license), selfie/liveness check |
| Financial Data | Source of funds, employment status, annual income, estimated net worth |
| Banking Data | Bank account numbers (for withdrawal processing), payment method details |
| Trading Preferences | Experience level, investment objectives, risk tolerance |
| Tax Data | Tax Identification Number (CPF for Brazilian clients, or equivalent) |
3.2 Data Collected Automatically
| Category | Data Points |
|---|---|
| Device Data | IP address, device type, operating system, browser type and version |
| Usage Data | Pages visited, time spent, clicks, navigation paths |
| Transaction Data | Trading history, deposit/withdrawal records, order history, P&L records |
| Communication Data | Records of support chats, emails, and calls (where call recording is notified) |
| Cookies Data | Session cookies, preference cookies (see Cookie Policy) |
3.3 Data from Third Parties
We may receive data about you from:
- KYC/identity verification service providers (document verification results, watchlist screening)
- Payment processors (payment confirmation, chargeback information)
- Sanctions and PEP screening databases
- Credit reference or fraud prevention agencies
- Introducing Brokers or affiliates who refer you to us
4. LEGAL BASIS FOR PROCESSING
| Purpose | Legal Basis |
|---|---|
| Account opening and management | Performance of a contract |
| Identity verification (KYC) | Legal obligation (AML compliance) |
| Prevention of fraud and money laundering | Legal obligation + Legitimate interest |
| Regulatory reporting | Legal obligation |
| Marketing communications (with consent) | Consent |
| Improving our services and website | Legitimate interest |
| Detecting and preventing system abuse | Legitimate interest |
| Processing transactions | Performance of a contract |
For Brazilian Clients (LGPD): The legal bases above correspond to: execução de contrato, cumprimento de obrigação legal, legítimo interesse, and consentimento under the LGPD framework.
5. HOW WE USE YOUR DATA
We use your personal data to:
(a) Open and manage your Trading Account;
(b) Process transactions: deposits, withdrawals, and trade execution;
(c) Comply with legal and regulatory obligations including AML/CTF screening and record-keeping;
(d) Prevent and detect fraud and unauthorized access;
(e) Provide customer support;
(f) Send service communications (account alerts, security notifications, policy updates);
(g) Send marketing communications (only with your explicit consent; opt-out available at any time);
(h) Improve our services through usage analysis;
(i) Enforce our legal rights in connection with actual or potential disputes.
6. DATA SHARING AND RECIPIENTS
We do not sell your personal data. We may share your data with:
6.1 Service Providers (Processors)
- KYC/AML providers: Sumsub or equivalent — for identity verification
- Payment processors: PayRetailers, AstroPay, and equivalent — for transaction processing
- Trading platform providers: Leverate — for platform operation
- Cloud infrastructure: For secure data storage and platform hosting
- Email service providers: For transactional and marketing communications
- Analytics providers: For website analytics (anonymized data only)
6.2 Regulatory and Legal Authorities
We may disclose your personal data to regulatory authorities, law enforcement agencies, courts, or other government bodies where required by law or in response to valid legal process.
6.3 Business Transfers
In the event of a merger, acquisition, or sale of all or part of our business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.
6.4 Introducing Brokers
If you were referred to us by an Introducing Broker, we may share your account status information (but not detailed trading data) with that Introducing Broker for commission calculation purposes.
7. INTERNATIONAL DATA TRANSFERS
The Company is based in Saint Lucia. Your data may be transferred to and processed in countries other than your country of residence. Where we transfer data internationally, we implement appropriate safeguards including contractual clauses obligating recipients to protect data to the same standard as we do.
8. DATA RETENTION
| Data Type | Retention Period |
|---|---|
| Account information | 5 years after account closure |
| KYC documents | 5 years after the end of the business relationship |
| Transaction records | 5 years after the transaction date |
| Communication records | 3 years after the communication |
| Marketing consent records | Until consent is withdrawn + 1 year |
| Website analytics | 13 months (anonymized after 6 months) |
Retention periods may be extended where required by law or in connection with actual or potential legal proceedings.
9. YOUR RIGHTS
9.1 General Rights
You have the right to:
- Access: Request a copy of the personal data we hold about you;
- Correction: Request correction of inaccurate or incomplete data;
- Erasure: Request deletion of your data, subject to legal retention obligations;
- Restriction: Request that we restrict processing of your data in certain circumstances;
- Portability: Receive your data in a structured, machine-readable format;
- Object: Object to processing based on legitimate interests;
- Withdraw Consent: Where processing is based on consent, withdraw it at any time.
To exercise any of these rights, contact us at: compliance@vorumcapital.com. We will respond within 30 days.
9.2 Additional Rights for Brazilian Residents (LGPD)
Under the Lei Geral de Proteção de Dados (LGPD), Brazilian residents have the following additional rights:
- Confirmation: Confirm whether we process your personal data;
- Anonymization: Request anonymization, blocking, or deletion of unnecessary or excessive data;
- Information on sharing: Request information about which entities we share your data with;
- Portability: Request portability of your data to another service provider;
- Revocation of consent: Revoke consent at any time;
- Review of automated decisions: Request review of decisions made solely by automated processing.
Contact: vorumcapital.com or compliance@vorumcapital.com
10. COOKIES
Our website uses cookies and similar tracking technologies. See our Cookie Policy for full details. You can manage your cookie preferences via the cookie banner displayed when you first visit our website.
11. SECURITY
We implement technical and organizational measures to protect your personal data, including encryption in transit (TLS/SSL) and at rest, access controls, regular security assessments, and employee training. If you believe your account has been compromised, contact us immediately at compliance@vorumcapital.com
12. CHILDREN
Our services are not directed at persons under 18 years of age. We do not knowingly collect personal data from children.
13. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. Material changes will be notified to clients by email and posted on our website at least 14 days before taking effect.
14. CONTACT AND COMPLAINTS
support@vorumcapital.com