Privacy Policy

1. Who We Are

Memento Enterprises Limited, located at 55, Triq Ir-Ruzell, Attard, ATD 1500, Malta, is the data controller responsible for your personal data.

FundedFast is the trading name of Memento Enterprises Limited. FundedFast companies do not act as a broker and do not accept any deposits. The offered technical solution for the FundedFast platforms and data feed is powered by liquidity providers.

For all data protection inquiries, please contact us at support@fundedfast.com.

2. Information We Collect

We may collect the following types of information:

2.1 Personal Data

Name, email address, mailing address, phone number, date of birth, payment information, and other identifying details you provide when creating an account, purchasing a challenge, or entering a competition.

2.2 Technical Data

IP address, browser type, device type, operating system, and usage data (e.g., pages viewed, time spent on pages, referral source).

2.3 Trading Data

Account activity on the trading platform, including trade history, equity balance, challenge progress, and competition performance within our simulated environment.

2.4 Social Media Data

If you link your social media accounts, we may collect your username, profile picture, and other data available on those platforms.

2.5 Cookies & Tracking Data

We use cookies, web beacons, and other tracking technologies to collect information about your interactions with our service. For full details, see our Cookie Policy.

3. How We Use Your Information

Your data may be used for:

• Service Provision: To provide, manage, and improve our services, including the trading platform, challenges, and competitions.
• Account Management: To create and manage your account, including processing transactions, verifying identity (KYC), and administering challenge and competition entries.
• Communication: To contact you with updates, promotional offers, competition results, and information relevant to our services. You may opt out of marketing communications at any time.
• Legal Compliance: To comply with legal obligations, including anti-money laundering (AML), counter-financing of terrorism (CFT), and sanctions screening obligations.
• Fraud Prevention: To detect and prevent fraudulent, abusive, or manipulative trading behaviour, multiple account creation, and competition rule violations.
• Business Operations: For analytics, research, and service improvement.
• Risk Management: To monitor aggregate, cross-account trading and payout exposure by instrument, in order to manage the Company's payout obligations under Section 6.3 (Force Majeure and Abnormal Market Conditions) of our Terms & Conditions.

4. Legal Basis for Processing Personal Data (GDPR)

If you are an individual in the European Economic Area (EEA), we process your personal data based on the following legal grounds:

• Consent: Where you have given consent to the processing of your personal data for one or more specific purposes (e.g., marketing communications, non-essential cookies).
• Contract: Where processing is necessary for the performance of a contract to which you are a party (e.g., challenge purchase, competition entry) or to take steps at your request before entering into a contract.
• Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject (e.g., AML/CFT requirements, tax reporting).
• Legitimate Interests: Where processing is necessary for the purposes of legitimate interests pursued by us or by a third party (e.g., fraud prevention, platform security, service improvement), except where such interests are overridden by your interests or fundamental rights and freedoms.

5. How We Share Your Information

We may share your data with:

• Service Providers: Third-party vendors who assist in providing our services, such as payment processors, hosting services, email delivery providers, and customer support tools. These providers process data only on our instructions and are contractually bound to protect your data.
• Other Companies within our Group: We may share your personal data with other companies within our corporate group. These companies may contact you regarding products, services, or promotions that may be of interest to you, provided that they are similar to those you have already purchased or shown interest in.
• Business Partners: Partners with whom we collaborate to offer services or promotions.
• Legal & Compliance: Authorities or other parties as required by law, or to protect the rights and safety of our company and users.

6. Third-Party Service Providers

We use the following categories of third-party service providers to operate our platform:

All third-party providers are contractually required to process your data only for the purposes specified and in compliance with applicable data protection laws.

7. Cookies & Tracking Technologies

We use cookies and similar technologies to enhance your experience on our website. Cookies are categorised as follows:

• Strictly Necessary: Required for the website to function (e.g., session management, security). These cannot be disabled.
• Analytics: Help us understand how visitors interact with our website (e.g., pages visited, time on site). Used only with your consent.
• Marketing: Used to deliver relevant advertisements and track campaign effectiveness. Used only with your consent.

You can manage your cookie preferences through the cookie banner displayed on your first visit, or at any time through your browser settings. Disabling certain cookies may affect your ability to use some features of our service.

For a complete list of cookies we use, their purposes, and durations, please see our Cookie Policy.

8. Do Not Track Signals

Some web browsers include a "Do Not Track" (DNT) feature that signals to websites you visit that you do not want to be tracked. Our website does not currently respond to DNT signals. However, you can manage your cookie preferences through our cookie consent banner and your browser settings, and may also opt-out of certain tracking by following the instructions provided by third-party services we use.

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. The following retention periods apply:

After the applicable retention period expires, your data is securely deleted or anonymised. You may request earlier deletion by exercising your right to erasure (see Section 11).

10. Data Security

We implement industry-standard security measures to protect your data, including:

• Encryption of data in transit (TLS/HTTPS) and at rest
• Access controls limiting data access to authorised personnel only
• Regular security assessments and vulnerability testing
• Secure hosting infrastructure with redundancy and backup systems

However, please be aware that no method of transmission or storage is completely secure. We encourage you to use strong, unique passwords and to keep your account credentials confidential.

11. Your Rights Under GDPR

If you are a resident of the EEA, you have the following rights regarding your personal data:

• Right to Access: You can request access to your personal data and obtain a copy of it.
• Right to Rectification: You can request the correction of inaccurate or incomplete personal data.
• Right to Erasure: You can request that we delete your personal data under certain conditions.
• Right to Restrict Processing: You can request that we restrict the processing of your personal data under certain conditions.
• Right to Data Portability: You can request that we transfer your personal data to another organization, or directly to you, in a structured, commonly used, and machine-readable format.
• Right to Object: You can object to our processing of your personal data based on our legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where you have provided consent, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us at support@fundedfast.com. We will respond to your request within 30 days, as required by GDPR. We may require verification of your identity before we fulfil your request.

12. Automated Decision-Making & Profiling

We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you. Where automated systems are used for fraud detection or competition rule enforcement, a human review is always available upon request.

13. International Data Transfers

Your data may be transferred to and processed in countries other than your own, including countries outside the European Economic Area (EEA). Where such transfers occur, we ensure your data remains protected by relying on:

• Standard Contractual Clauses (SCCs) as approved by the European Commission under Decision 2021/914
• Adequacy decisions by the European Commission where available
• Other appropriate safeguards as permitted under GDPR Article 46

14. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a person under 18, we will take steps to delete that information promptly. If you believe a child has provided us with personal data, please contact us at support@fundedfast.com.

15. Right to Lodge a Complaint

If you believe that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority. For Malta, the competent authority is:

Office of the Information and Data Protection Commissioner (IDPC)
Floor 2, Airways House, High Street, Sliema SLM 1549, Malta
Website: idpc.org.mt
Email: idpc.info@idpc.org.mt

We encourage you to contact us first at support@fundedfast.com so we can address your concerns directly.

16. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the Last updated date at the top of this page and, where appropriate, by email. We encourage you to review this Privacy Policy periodically. Continued use of our services after any changes constitutes acceptance of the updated policy.

17. Contact Us

If you have any questions or concerns about this Privacy Policy or your personal data, please contact us at:

• Email: support@fundedfast.com
• Post: Memento Enterprises Limited, 55 Triq Ir-Ruzell, Attard, ATD 1500, Malta

Memento Enterprises Limited · C 109385 · Malta · fundedfast.com · support@fundedfast.com