Privacy Policy
- Introduction
1.1 This Privacy Policy applies to Vatee Pty Limited (“Vatee”) and governs the collection, use, disclosure, and protection of personal information in connection with its operations and services.
1.2 Vatee Pty Limited is a company incorporated in Vanuatu (Company No. 40097) and is regulated by the Vanuatu Financial Services Commission (VFSC).
1.3 By accessing Vatee’s website or using its services, users acknowledge that they have read and understood this Privacy Policy and agree to be legally bound by its terms. Continued use of the services constitutes ongoing acceptance.
1.4 Vatee may disclose personal information to third-party service providers that support its operations. Such entities are subject to strict confidentiality obligations and may be located outside of Vanuatu.
1.5 This Privacy Policy may be amended or updated at any time without prior notice. Any changes will take effect immediately upon publication on the official website. Users are advised to review the Privacy Policy periodically to remain informed of any revisions.
1.6 Vatee is committed to handling personal and sensitive information in accordance with applicable privacy laws and VFSC regulatory standards.
1.7 Personal and/or sensitive information is collected to provide requested products or services, and to inform users about related offerings either directly or through authorised partners. In certain cases, information collection may be required by law or regulatory obligations.
1.8 The legal basis for processing personal information includes, but is not limited to:
a. performance of contractual obligations
b. compliance with legal and regulatory requirements
c. explicit consent, where required
d. legitimate business interests, provided these do not override individual rights
1.9 This Privacy Policy is issued in English. Any translated versions are for reference only. In the event of inconsistency or conflict, the English version shall prevail.
- Purpose of Collecting Personal Information
2.1 Vatee collects personal information only where reasonably necessary to support its business operations, fulfil contractual obligations, or comply with applicable legal and regulatory requirements.
2.2 The purposes for which personal information may be collected and used include, but are not limited to:
a. providing access to requested products and services, and—unless opted out—offering information about related services provided directly or via authorised partners, including by electronic means
b. complying with legal, regulatory, or contractual obligations
c. monitoring and assessing the security, performance, and quality of services
d. compiling information for statistical, prudential, actuarial, or research purposes
e. responding to inquiries and providing client support
f. detecting and preventing fraud or unlawful conduct
g. conducting Know Your Customer (KYC), Anti-Money Laundering (AML), and Counter-Terrorism Financing (CTF) procedures in accordance with applicable policy
h. delivering marketing communications, where permitted
i. recording communications for training, quality assurance, or business analysis
2.3 Vatee is committed to collecting only information that is relevant and necessary for the purposes described above, and to handling such information in accordance with this Privacy Policy and applicable law.
- Categories of Personal Information Collected
3.1 For prospective and existing clients, the types of personal information collected may include, without limitation:
a. personal identifiers, such as full name, telephone number, and email address
b. identity verification documents, including passport, national ID, driver’s licence, and utility bills
c. financial details, such as bank account information and payment card data
d. information regarding income, assets, trading activity, tax status, and financial statements
e. employment information and professional history
f. transactional data associated with the use of services
g. usage data derived from the trading platform or website
h. technical data, including device type, operating system, browser type, IP address, and time zone
3.2 Verification of identity is a legal requirement when opening an account or appointing an authorised representative. Vatee is obligated to collect and retain specific documentation under applicable AML/CTF regulations.
3.3 Reasonable steps may be taken to verify the accuracy of submitted information, including cross-referencing with public records or confirming employment status with third parties.
3.4 Vatee does not knowingly collect personal information from individuals under the age of 18. Services are intended only for individuals who have reached the legal age of majority. If it is determined that data from a minor was collected without appropriate consent, such data will be promptly deleted.
3.5 Sensitive personal data will not be collected unless:
a. explicit consent has been provided
b. collection is required or authorised by law
c. collection is necessary in connection with suspected unlawful activity or serious misconduct
3.6 Failure to provide requested personal information may limit or prevent access to certain services or functionality.
- Use and Disclosure of Personal Information
4.1 Vatee may use and disclose personal information in the following circumstances:
a. where required by applicable laws or regulations
b. in response to legal obligations, such as court orders or administrative directions
c. upon formal request from regulatory, supervisory, or government authorities
d. where necessary to perform obligations under the Client Agreement, including disclosure to affiliates or related entities
e. with the individual’s prior and explicit consent
4.2 Vatee may share personal information with affiliated entities when necessary to deliver services or provide access to related products or solutions. Information may also be shared with trusted third-party partners engaged under strategic alliances or marketing arrangements. These third parties are contractually bound to use the data solely for the defined purpose and are prohibited from processing it for unrelated activities.
4.3 Personal information is not sold, rented, or licensed to unrelated third parties. However, disclosure may occur under limited conditions, including:
a. to comply with legal or regulatory requirements
b. in response to subpoenas or legal proceedings
c. to law enforcement or government bodies where mandated
d. to protect the legal rights, operations, clients, or property of Vatee
e. with the express consent of the data subject
4.4 In all cases of permitted disclosure, Vatee shall only share what is reasonably necessary and shall ensure that appropriate safeguards are in place to protect the confidentiality and security of the information disclosed.
- Retention of Personal Information
5.1 Vatee retains personal information only for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, accounting, or reporting requirements.
5.2 As a general rule, personal data will be retained for a minimum of seven (7) years following the termination of the trading account and the Client Agreement. This period aligns with prevailing industry standards and regulatory expectations.
5.3 In specific circumstances, personal information may be retained for longer periods, including where:
a. retention is required by applicable law
b. necessary for the establishment, exercise, or defence of legal claims
c. mandated by regulatory authorities or internal data governance policies
5.4 Deletion of personal information may not always be feasible if it would compromise Vatee’s ability to comply with contractual or legal obligations. In such cases, requests for deletion may result in termination of access to services or closure of the relevant account.
5.5 Once personal data is no longer required for legal, regulatory, or operational purposes, Vatee will take reasonable steps to securely delete, anonymise, or de-identify the information, unless continued retention is expressly permitted or required by law.
- Rights of Individuals
6.1 In accordance with applicable privacy laws and VFSC guidance, individuals have the right to:
a. request access to personal data held by Vatee, including information about how it is processed
b. request correction of inaccurate, incomplete, or outdated personal information
c. request restriction of processing in specific legal circumstances
d. object to the processing of personal data, including for direct marketing purposes
e. request the erasure of personal data, subject to legal and regulatory limitations
6.2 Requests to exercise any of the above rights must be submitted in writing to the Compliance Team using the contact details provided in Section 12. Vatee will respond within a reasonable timeframe, and in any event within thirty (30) calendar days, unless a permitted extension applies due to complexity.
6.3 No fee will be charged for exercising these rights unless the request is manifestly unfounded, excessive, or repetitive. In such cases, Vatee may:
a. charge a reasonable fee; or
b. decline to act on the request
6.4 In certain circumstances, requests may not be fulfilled due to overriding legal or contractual obligations. In such cases, Vatee will:
a. provide written justification; and
b. advise the individual of their right to lodge a complaint with the relevant authority
6.5 Vatee will take reasonable steps to ensure the accuracy and completeness of personal information and to uphold the rights of individuals as required under applicable law.
- Accuracy and Quality of Personal Information
7.1 Vatee is committed to maintaining the accuracy, completeness, and relevance of the personal information it holds. Reasonable steps are taken to ensure that collected, used, or disclosed data is current and reliable.
7.2 Individuals are encouraged to promptly notify Vatee of any changes to their personal information or if they believe the information held is incorrect or outdated. Timely updates help ensure that services remain appropriate and compliant.
7.3 Where permitted by law, Vatee may verify or update personal information using reliable external sources, such as:
a. public registers
b. official directories
c. electoral rolls
- Data Security
8.1 Vatee implements appropriate measures to protect personal information against misuse, interference, loss, unauthorised access, modification, or disclosure. Industry-standard technologies and internal protocols are employed to maintain data security.
8.2 Security controls include, but are not limited to:
a. employee training and awareness regarding privacy obligations
b. role-based access restrictions and secure password protocols
c. firewalls, intrusion detection systems, and anti-malware software
d. encrypted channels for transmitting sensitive information
e. secure physical storage and facility access control
f. regular review and testing of information security frameworks
8.3 While reasonable precautions are taken, transmission of information via the internet is inherently subject to risk. Vatee cannot guarantee the absolute security of data transmitted to its website. Any transmission is undertaken at the user’s own risk. Once received, strict controls are applied to safeguard the information.
8.4 When personal information is no longer required for legal or operational purposes, Vatee will take appropriate steps to securely delete or destroy the data in accordance with applicable standards.
8.5 In the event of a personal data breach, Vatee will act without undue delay and in accordance with legal obligations. This may include:
a. notifying affected individuals; and
b. reporting to relevant regulatory authorities, where required
- Use of Cookies
9.1 Vatee uses cookies to enhance website functionality, support secure access to trading platforms, and improve user experience. Cookies are small text files stored on the user’s device that help identify returning users and tailor services accordingly.
9.2 Cookies used by Vatee do not contain:
a. personal identifiers
b. account details
c. passwords
They simply allow the system to recognise that requests originate from a previously authenticated device.
9.3 Anonymous usage data, such as browsing patterns and behavioural metrics, may be shared with reputable analytics and advertising providers to facilitate:
a. delivery of targeted banner advertisements on Vatee’s website
b. display of relevant ads on third-party platforms
9.4 Users may manage cookie preferences through browser settings. Most browsers allow users to:
a. refuse cookies
b. delete cookies
However, disabling cookies may affect the functionality or accessibility of certain website features.
- Changes to This Privacy Policy
10.1 This Privacy Policy may be updated periodically to reflect:
a. changes in legal obligations
b. regulatory requirements
c. operational practices
d. the manner in which personal information is managed
10.2 In the event of a material change, Vatee will:
a. publish the updated version on its official website
b. provide additional notice via email or other appropriate channels, where required by law
10.3 Unless otherwise stated, the revised version becomes effective immediately upon publication.
10.4 Continued use of Vatee’s services following the publication of any updates constitutes acceptance of the revised terms.
10.5 Unless expressly stated, changes to the Privacy Policy will not apply retroactively to matters occurring prior to the effective date of the revision.
- Direct Marketing
11.1 Vatee may use personal information to inform individuals about products, services, offers, or promotions that may be of interest, provided the information was:
a. collected directly from the individual; and
b. the recipient has not opted out
11.2 Direct marketing communications may be delivered through:
a. email
b. SMS
c. telephone
d. other permitted methods
in accordance with applicable laws.
11.3 Individuals may opt out of receiving direct marketing communications at any time by:
a. sending an email to compliance@vateefx.com with the subject “Unsubscribe”; or
b. following the unsubscribe instructions included in each communication
11.4 Upon receiving an opt-out request, Vatee will take reasonable steps to ensure that the individual no longer receives direct marketing messages.
11.5 Individuals may also request to be informed of the source of their personal information used for direct marketing. Vatee will respond to such requests:
a. within a reasonable timeframe; and
b. at no charge, unless otherwise permitted by law
- Contact and Complaints
12.1 For any questions, concerns, or requests relating to this Privacy Policy or the handling of personal information, individuals may contact Vatee’s Compliance Team at:
Email: compliance@vateefx.com
12.2 Vatee provides an internal complaint resolution process for all clients at no cost. The firm is committed to:
a. addressing concerns promptly
b. resolving complaints transparently
c. meeting applicable regulatory requirements
12.3 To assist in resolving complaints efficiently, individuals are encouraged to:
a. gather all relevant documentation and factual details concerning the issue
b. submit the complaint via email to the Compliance Team using the contact details above
c. if the matter remains unresolved, request escalation to the Complaints Officer for formal review
12.4 Vatee aims to acknowledge and resolve all complaints in a timely and fair manner, in line with applicable legal and regulatory standards.
