Masterlabs Limited as Elites Funding (“us”, “we”, or “our”) operates the website (the “Site”). Masterlabs Limited as Elites Funding is the controller and responsible for your personal data.

This webpage provides you with information about our policies concerning the gathering, utilization, and disclosure of personal data during your visit to our website and when using our services through our website. It also outlines the options and privileges you possess in relation to that data.

By utilizing the Site, you acknowledge and accept the gathering and utilization of information as described in this Privacy Policy. It is crucial that you thoroughly read this Privacy Policy along with any additional Privacy Policy or fair processing policy we may offer on specific occasions when we gather or process personal data about you. This will ensure that you have a complete understanding of how and why we employ your data. This Privacy Policy acts as a supplementary document to other notices and privacy policies and does not intend to supersede them.


We gather various types of personal data about you, which we have categorized as follows:

• Identity Data: This includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.

• Contact Data: This encompasses your billing address, delivery address, email address, and telephone numbers.

• Financial Data: This pertains to your bank account and payment card details.

• Transaction Data: This covers details about your trading and order activities, payments made by you or to you, and other information regarding services you have purchased from us.

• Technical Data: This includes your internet protocol (IP) address, login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technological details related to the devices you use to access our website.

• Profile Data: This incorporates your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.

• Usage Data: This involves information about your utilization of our trading platform, website, and services.

• Marketing and Communications Data: This refers to your preferences regarding receiving marketing materials from us and our third parties, as well as your communication preferences.

Additionally, we collect, use, and share Aggregated Data, such as statistical or demographic information, for various purposes. Aggregated Data may be derived from your personal data but does not legally qualify as personal data as it does not directly or indirectly disclose your identity. For instance, we may aggregate Usage Data to determine the percentage of users accessing a specific feature on our website. However, if we combine or connect Aggregated Data with your personal data in a manner that enables your direct or indirect identification, we treat the combined data as personal data and handle it in accordance with this Privacy Policy.

In cases where we are legally obligated to collect personal data from you or where it is required under a contractual agreement we have with you, failure to provide the requested data may result in our inability to fulfill the contract we have or are attempting to enter into with you. For example, this could mean that we cannot provide you with goods or services. If such a situation arises, we will inform you at the time and may need to cancel a product or service you have with us.


To monitor the activity on our website and retain specific information, we employ cookies and similar tracking technologies.

Cookies are files containing a small amount of data, including an anonymous unique identifier. These files are sent to your browser from a website and stored on your device. We also utilize beacons, tags, and scripts as tracking technologies to gather and track information, as well as to enhance and analyze our website.

You have the option to instruct your browser to reject all cookies or to notify you when a cookie is being sent. However, please note that if you decline cookies, you may not be able to access certain parts of our website.

Here are examples of the types of cookies we use:

• Session Cookies: We use session cookies to facilitate the operation of our website.

• Preference Cookies: Preference cookies are employed to remember your preferences and various settings.

• Security Cookies: Security cookies are used for security purposes.

Please note that the use of cookies and tracking technologies is subject to our overall Privacy Policy.


We utilize various methods to collect data from you and about you, including:

• Direct interactions: You may provide us with your Identity, Contact, and Financial Data by filling in forms or corresponding with us via postal mail, phone, email, or other means. This includes personal data you provide when you:

  • Apply for an evaluation account, funded trader account, or other services we offer.
  • Subscribe to our services or publications.
  • Request marketing materials to be sent to you.
  • Enter a competition, promotion, or survey.
  • Give us feedback or contact us.

• Automated technologies or interactions: As you interact with our site, we automatically collect Technical Data about your device, browsing actions, and patterns. We collect this personal data using cookies, server logs, and similar technologies. Additionally, if you visit other websites that employ our cookies, we may receive Technical Data related to your interactions.

• Third parties or publicly available sources: We receive personal data about you from various third parties and public sources, as outlined below:

  • Transaction Data from our partnered brokers and trading platform providers located outside Gibraltar.
  • Technical Data from analytics providers, such as Google, based outside Gibraltar, as well as from advertising networks and search information providers.
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.

Please note that this data collection process is subject to our overall Privacy Policy.



We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new trader

(a) Identity

(b) Contact

Performance of a contract with you

To process your registration as a trader, including:

(a) Manage payments, fees, and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you, which will include:

(a) Monitoring and evaluating your trading and order activity

(b) Notifying you about changes to our terms or privacy policy

(c) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)

To use data analytics to improve our Site, products/services, marketing, customer relationships, and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business, and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)



We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us, and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.



The security of your personal data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.



We may share your personal data with the parties set out below, located in Gibraltar, for the purposes set out in the table above.

• Service providers who assist us in delivering our Site and services to you, such as our partnered brokers, trading platform providers, payment service providers, and IT and system administration service providers.

• Service providers we utilize to support our business operations, such as website hosts and website analytics providers.

• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

• HM Revenue & Customs, regulators, and other authorities in Gibraltar who require reporting of processing activities in certain circumstances.

• Law enforcement agencies, courts, tribunals, and regulatory bodies in Gibraltar to comply with our legal and regulatory obligations.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you would like more information about who we share your data with and why, please contact us (see the ‘CONTACT US’ section below).



Many of our external third parties are based outside Gibraltar, so their processing of your personal data will involve a transfer of data outside Gibraltar.

Whenever we transfer your personal data out of Gibraltar, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use specific contracts approved for use in Gibraltar, which give personal data the same protection it has in Gibraltar.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Gibraltar.



We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. In such cases, we may use this information indefinitely without further notice to you.



Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.



Our Site may contain links to third-party sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.



Our Site is not intended for anyone under the age of 18 (“Children”). We do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.



We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will also inform you through email and/or by displaying a prominent notice on our Site before the changes take effect. The “effective date” at the top of this Privacy Policy will be updated accordingly.

We recommend that you review this Privacy Policy periodically to stay informed about any modifications. Changes to this Privacy Policy will become effective as soon as they are posted on this page.



If you have any questions about this Privacy Policy or if you would like to exercise your legal rights, please contact us:

• By email: [email protected]

Please note that this Privacy Policy is written in the English language. Any translations provided are for convenience purposes only. In the event of any inconsistency or discrepancy between the original English text and its translation into any other language, the original English version shall prevail.