Privacy Policy

1. Introduction

Welcome to NorthcrestCapital. We are committed to protecting your privacy and ensuring the integrity of your personal data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you access or use any of our platforms, websites, mobile applications, services, or products (collectively, the “Services”).

By accessing or using our Services, you agree to the terms outlined in this Privacy Policy. If you do not agree with any part of this Policy, you should discontinue the use of our Services immediately.

This Policy is designed in accordance with applicable global data protection regulations, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other relevant financial privacy laws.

Scope of This Policy

This Privacy Policy applies to all users, including individuals and institutional clients, who interact with NorthcrestCapital through online or offline means. It governs the data practices concerning:

Information we collect directly from you

Information we collect automatically as you interact with our systems

Information received from third-party partners or verification services

Key Definitions

For the purposes of this Policy:

“Personal Data” refers to any information relating to an identified or identifiable individual.

“Processing” means any operation or set of operations performed on personal data, whether or not by automated means.

“You” or “User” refers to any individual who accesses or uses our Services.

“We,” “Us,” or “NorthcrestCapital” refers to the entity responsible for determining the purposes and means of the processing of personal data.

We may update this Privacy Policy from time to time. Any changes will be communicated through our platform or other appropriate channels. Continued use of our Services after such updates constitutes acceptance of the revised Policy.

2. Types of Data Collected

NorthcrestCapital collects various categories of data to operate effectively, provide high-quality financial services, and comply with legal and regulatory obligations. The types of data we collect include, but are not limited to, the following:

A. Personal Identification Information

Collected during registration, identity verification, or when required for regulatory compliance:

Full name

Date of birth

Nationality and residency status

Government-issued identification numbers (e.g., passport, driver’s license)

Verification documents (e.g., ID scans, utility bills)

B. Financial and Transactional Data

Collected when users engage in investment activities or use the platform’s financial services:

Account balances and portfolio information

Transaction history, order types, and execution records

Bank account or payment method details (where applicable)

Historical performance and trade frequency

C. Technical and Device Information

Automatically collected to optimize user experience and platform security:

IP address and geolocation (approximate)

Browser type and version

Operating system and device information

Login timestamps and session duration

Clickstream behavior and page navigation paths

D. Behavioral and Engagement Data

Collected to enhance service personalization and model refinement:

Usage frequency, interaction preferences, and session activity

User-generated feedback, survey responses, and support inquiries

Behavioral analysis derived from engagement with educational content, dashboards, or AI tools

E. Third-Party and External Data

Received from identity verification providers, partners, or institutional intermediaries:

KYC/AML compliance data

Risk ratings and credit information (if applicable)

Affiliate referral data

Publicly available data from financial news or regulatory filings associated with user activity

F. Optional Marketing Preferences

Collected only with your consent:

Newsletter subscription choices

Communication and notification settings

Engagement with promotions or special campaigns

We only collect data that is necessary, lawful, and relevant to the services we provide. Sensitive information is collected only when required and handled with the highest standards of confidentiality and encryption.

3. How We Collect Data

At NorthcrestCapital, we collect data through a combination of direct interactions, automated technologies, and third-party integrations. Each method is designed to ensure accuracy, transparency, and user control. Below are the primary ways we gather your information:

A. Direct Interactions

We collect personal data when you:

Register for an account or complete onboarding procedures

Submit documents for identity verification (KYC/AML)

Fill out forms, questionnaires, or feedback surveys

Contact our support team or communicate with us via platform messaging

Participate in promotional events, webinars, or referral programs

B. Automated Technologies

When you interact with our digital platforms, we automatically collect certain technical and behavioral information using:

Cookies and tracking pixels: Small data files stored on your device to recognize repeat visits and personalize content

Log files: Records of website activity, system diagnostics, and error tracking

Device fingerprinting: Identification of devices using hardware and software characteristics to enhance security

Usage analytics: AI-driven tools to monitor navigation patterns, response times, and content engagement

Users may modify their browser settings to block cookies or limit tracking, although this may affect platform functionality.

C. Third-Party Integrations and Partners

We may receive and process your information through secure integrations with:

KYC/AML verification services for identity, sanctions, and fraud screening

Payment processors to facilitate deposits, withdrawals, and billing

Affiliated brokers, custodians, or liquidity providers for trade execution and reconciliation

Analytics providers to improve user experience and system performance

Social media or ad platforms if you interact with our content via those channels

D. Consent-Based Collection

In certain cases, we collect data only after obtaining your explicit consent. These include:

Subscriptions to newsletters or market alerts

Participation in surveys, beta features, or research studies

Opt-in data sharing for personalized financial recommendations

We ensure that all third parties handling data on our behalf comply with strict privacy and data protection standards.

4. Use of Collected Data

NorthcrestCapital processes your data for specific, legitimate purposes aimed at delivering reliable, secure, and intelligent financial services. We use collected data to operate effectively, enhance user experience, meet regulatory obligations, and support long-term investment success.

A. Service Delivery and Account Management

To verify user identity and fulfill onboarding requirements

To provide access to investment tools, trading platforms, dashboards, and financial products

To enable deposits, withdrawals, transaction processing, and account reconciliation

To maintain user preferences, settings, and platform configurations

B. Risk Management and Security Monitoring

To monitor market exposure and user portfolio volatility

To detect and prevent fraud, suspicious behavior, unauthorized access, or policy violations

To support real-time alerts, access control, and behavioral anomaly detection

To comply with internal audit standards and legal obligations (e.g., anti-money laundering laws)

C. AI-Driven Insights and Personalization

To enhance predictive investment analytics using machine learning models

To deliver personalized dashboards, recommendations, or risk assessments

To refine algorithmic strategies based on aggregated, anonymized user behavior

To enable data-informed decision-making while maintaining user privacy

D. Research and Development

To evaluate platform performance and identify technical improvements

To train and validate proprietary AI models and trading algorithms

To conduct internal testing and develop new features, services, or financial products

To generate statistical reports for internal use and strategic planning

E. Regulatory and Legal Compliance

To fulfill regulatory reporting obligations to financial authorities

To retain records for tax, audit, and compliance reviews

To support dispute resolution, investigations, and legal processes

To cooperate with law enforcement or judicial orders, when legally required

F. Marketing and Communications (only if consented)

To send market updates, newsletters, or promotional materials

To inform users about platform updates, webinars, or events

To offer tailored content or advertising based on user interests and activity

Users can manage their preferences or opt out at any time

We never use personal data for purposes inconsistent with this policy without notifying you or obtaining required consent.

5. Legal Basis for Data Processing

NorthcrestCapital processes personal data in compliance with applicable data protection laws. Depending on your jurisdiction and the specific context in which data is collected, we rely on the following legal bases to process your information:

A. Performance of a Contract

We process your data when it is necessary to:

Provide services that you have requested (e.g., account setup, investment execution)

Fulfill contractual obligations related to financial products or platform features

Communicate important information about your account, trades, or service status

B. Compliance with Legal Obligations

Certain data must be collected and processed to comply with laws, regulations, and government requirements. This includes:

Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures

Tax reporting and financial record retention

Cooperation with court orders, subpoenas, or regulatory investigations

C. Legitimate Interests

We process data when it supports the efficient, secure, and lawful operation of our services and systems, provided that such use does not override your rights. This includes:

Detecting fraud, preventing abuse, and maintaining platform integrity

Improving user experience and functionality through analytics

Ensuring cybersecurity and protecting proprietary systems

Offering strategic investment tools to enhance your performance

We assess the balance between our interests and your privacy rights and implement safeguards where necessary.

D. Consent

In certain situations, we rely on your explicit consent to collect and process data. For example:

When subscribing to newsletters or receiving promotional messages

When participating in beta programs, marketing events, or surveys

When enabling third-party integrations or personalized investment tools
You can withdraw your consent at any time via account settings or notification preferences.

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E. Protection of Vital Interests

In rare cases, we may process data to protect an individual’s vital interests or the public interest. This could include:

Responding to cybersecurity threats or data breaches

Notifying users of potentially harmful or unauthorized account activity

Assisting with legal claims involving financial crime or regulatory risk

6. Data Sharing and Third Parties

NorthcrestCapital respects your privacy and limits the sharing of personal data to only what is necessary, lawful, and secure. We do not sell your personal information. When data must be shared, we ensure all third parties uphold the same standards of confidentiality, compliance, and security.

A. Within the NorthcrestCapital Group

We may share information with affiliated entities for the following purposes:

Centralized compliance and risk management

Platform enhancements and shared infrastructure

Unified customer support and user experience consistency
All internal data transfers are governed by strict access controls and internal agreements.

B. Service Providers and Partners

We engage trusted third parties who perform essential services on our behalf. These include:

Cloud computing and data storage providers

Identity verification (KYC/AML) and regulatory compliance vendors

Payment and banking service partners

Trading technology and infrastructure vendors

Analytics and performance monitoring tools
These providers may only process your data for the specific purposes agreed upon and are contractually bound by confidentiality and data protection agreements.

C. Legal and Regulatory Disclosures

We may disclose your personal data to government agencies, courts, or regulators when:

Required by law, subpoena, or legal process

Necessary for tax compliance, financial audits, or licensing obligations

Responding to legitimate requests related to criminal investigations or regulatory examinations
We carefully validate the legitimacy of all such requests before sharing any data.

D. Business Transfers

In the event of a merger, acquisition, asset sale, or corporate restructuring:

Your data may be transferred as part of the transaction

Any acquiring entity will be bound by the same privacy commitments

You will be notified of any material change in data handling or privacy practices

E. Aggregated or Anonymized Data

We may share non-personal, aggregated, or anonymized data with partners or researchers to:

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Analyze platform usage trends

Improve service offerings and investment strategies

Support academic or industry studies without identifying individuals

Every third-party relationship is subject to rigorous due diligence and data protection safeguards.

7. Data Storage and Retention

NorthcrestCapital stores and retains your personal data in accordance with strict security protocols and legal obligations. Our goal is to safeguard your data while ensuring that it is retained only for as long as necessary for legitimate business, regulatory, and operational purposes.

A. Storage Infrastructure

All personal data is stored on secure, encrypted servers located in jurisdictions with robust data protection standards.

We utilize industry-leading cloud service providers with certifications such as ISO 27001, SOC 2, and GDPR compliance.

Data is encrypted both at rest and in transit using advanced cryptographic protocols (e.g., AES-256, TLS 1.2+).

Access is restricted by role-based controls, and activity is logged for audit and security review.

B. Retention Periods

The length of time we retain your data depends on the type and purpose of the data:

Data Type

Typical Retention Period

Account registration details

Retained for the duration of the account + 7 years (for legal compliance)

Transactional records

Minimum 7 years (as required by financial regulations)

Identity verification documents

Retained as long as required under KYC/AML laws

Usage logs and analytics

Typically retained for 1–3 years (anonymized after use)

Marketing preferences

Until consent is withdrawn or updated by the user

In all cases, we retain data only for as long as necessary to fulfill its purpose, unless a longer retention is required by law.

C. Data Disposal and Anonymization

Upon reaching the end of its retention period, data is securely deleted or anonymized.

Secure disposal methods include cryptographic erasure and deletion from backups.

Anonymized data may be retained for historical analysis or AI model development, ensuring no link to individual users.

D. User-Initiated Deletion

Users may request deletion of their personal data through the platform’s account settings.

We will honor such requests unless retention is required to comply with legal, tax, or regulatory obligations.

Deleted data will be promptly removed from active systems and scheduled for secure purge from backup archives.

8. User Rights

At NorthcrestCapital, we are committed to upholding your data protection rights. Depending on your jurisdiction and applicable laws, you may have the following rights regarding your personal data:

A. Right to Access

You have the right to request a copy of the personal data we hold about you, along with information on:

The purposes of processing

The categories of data processed

The recipients or categories of recipients with whom data may be shared

The retention period or criteria used to determine it

B. Right to Rectification

If any of your personal information is incorrect or outdated, you have the right to request corrections or updates. You may:

Edit certain details directly in your account dashboard

Contact support to update verification documents or contact preferences

C. Right to Erasure (“Right to Be Forgotten”)

You may request the deletion of your personal data in certain circumstances, such as when:

The data is no longer necessary for the purpose it was collected

You withdraw consent (where applicable)

You object to processing and there are no overriding legitimate grounds
Note: We may retain limited data where required by law (e.g., regulatory retention rules).

D. Right to Restriction of Processing

You can request a restriction on how your data is used if:

You contest the accuracy of the data

Processing is unlawful, but you oppose erasure

The data is no longer needed, but you require it for legal claims

E. Right to Data Portability

Where legally applicable, you can request your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider.

F. Right to Object

You may object to:

Processing based on legitimate interests (e.g., profiling for investment suggestions)

Use of data for direct marketing purposes (opt-out available at any time)

G. Right to Withdraw Consent

If you previously provided consent for optional data processing (e.g., receiving newsletters), you may withdraw it at any time via account settings or by following the opt-out links provided in communications.

We strive to respond to all rights requests within 30 days. Requests may be denied or limited where legally justified (e.g., preventing fraud or fulfilling legal obligations).

9. Data Security Measures

At NorthcrestCapital, protecting your data is a top priority. We implement a comprehensive, multi-layered security framework that combines advanced technology, organizational protocols, and human oversight to ensure the confidentiality, integrity, and availability of your information.

A. Technical Safeguards

Encryption: All personal data is encrypted both in transit (via HTTPS/TLS) and at rest (AES-256) to prevent unauthorized access.

Firewall and Intrusion Detection Systems (IDS): Our infrastructure is protected by industry-standard firewalls and AI-driven IDS that continuously monitor for anomalies or attacks.

Multi-Factor Authentication (MFA): Access to sensitive systems requires MFA and unique credentials.

Tokenization and Role-Based Access: Access to data is granted on a need-to-know basis, based on job function and data sensitivity.

B. Organizational Controls

Regular Security Audits: Independent third-party audits and internal assessments are conducted to identify and fix vulnerabilities.

Employee Training: All personnel undergo mandatory cybersecurity and data privacy training, including phishing simulations and access control policies.

Incident Response Plan: A formal response protocol is in place to handle any data breach, including containment, notification, and mitigation.

Vendor Risk Management: Third-party service providers are vetted for security compliance and required to meet contractual data protection standards.

C. AI and Behavioral Security Monitoring

We deploy machine learning models to detect unusual user activity or platform behavior in real-time.

Behavioral analytics allow us to preemptively block potential threats or compromised accounts based on risk scoring.

Automated alerts are triggered for any deviation from expected usage patterns, enabling proactive security actions.

D. Backup and Recovery

Daily encrypted backups are maintained across geographically distributed data centers.

Disaster recovery protocols ensure minimal downtime in case of infrastructure failure or cyberattack.

Redundant systems support business continuity and data preservation under adverse conditions.

While no system is entirely immune to threats, our security strategy is designed to detect, prevent, and mitigate risks to the fullest extent possible.

10. Policy Updates and Jurisdiction

A. Privacy Policy Updates

We may update this Privacy Policy from time to time to reflect changes in legal requirements, technology, our business practices, or user feedback. When changes are made, we will:

Post the revised version on our official platform(s)

Update the “Effective Date” at the top of this document

Notify users through in-app messages, email notifications, or website banners (if the changes are material)

Your continued use of our Services after any update to this Privacy Policy constitutes your acceptance of the changes.

We encourage all users to review this Policy periodically to stay informed about how we are protecting your information.

B. Governing Law and Jurisdiction

This Privacy Policy is governed by and interpreted in accordance with applicable data protection and privacy laws in the United States, with particular alignment to the standards outlined by:

The California Consumer Privacy Act (CCPA)

The Gramm-Leach-Bliley Act (GLBA)

The General Data Protection Regulation (GDPR), where applicable to international users

Financial regulatory requirements as enforced by relevant authorities (e.g., SEC, FinCEN, or other U.S. entities)

C. Dispute Resolution

In the event of a dispute relating to data privacy or your rights under this Policy:

We encourage users to contact our support team through the platform’s secure messaging center first.

If resolution is not achieved, the matter may be submitted to binding arbitration or to courts with jurisdiction as defined in our Terms of Service.

Nothing in this Policy limits your rights under applicable data protection laws or regulatory authorities in your region.