1. Overview
This Privacy Policy explains how [Operator Legal Name] (“Mettle”, “we”) collects, uses, shares and protects personal data when you use our Platform. We act as the data controller for the personal data described here. If you have questions, contact [[email protected]].
2. Information we collect
- Account data — name, email, password (hashed), country, referral code.
- Verification (KYC) data — identity documents and related details you submit, processed by us or our verification providers.
- Transaction data — purchases, payout requests, payment method and references. We do not store full card numbers; these are handled by our payment processors.
- Trading and usage data — your evaluation activity, account states, device and log data, and analytics events.
- Communications — messages you send us and notification preferences.
3. How we use your data
- to provide the Platform — run evaluations, fund accounts, process payouts;
- to verify your identity and meet anti-money-laundering obligations;
- to process payments and prevent fraud and abuse;
- to communicate service messages, receipts and (with consent) marketing;
- to improve and secure the Platform; and
- to comply with law and enforce our terms.
4. Legal bases
Where applicable data-protection law (such as the GDPR) applies, we rely on: performance of a contract (to provide the Platform), legal obligation (KYC/AML, tax), legitimate interests (security, fraud prevention, product improvement), and consent (marketing, certain cookies). You may withdraw consent at any time.
5. How we share data
We share personal data with:
- Service providers — payment processors, KYC/identity providers, email, hosting and analytics, under contract and only as needed.
- Authorities — where required by law, regulation, or valid legal process.
- Successors — in connection with a merger, acquisition, or sale of assets, subject to this Policy.
We do not sell your personal data.
6. International transfers
Your data may be processed in countries other than your own. Where we transfer personal data internationally, we use appropriate safeguards (such as standard contractual clauses) as required by applicable law.
7. Retention
We keep personal data for as long as needed to provide the Platform and to meet legal, accounting and regulatory requirements (KYC and transaction records are typically retained for several years after your last activity). When no longer required, data is deleted or anonymised.
8. Your rights
Depending on your location, you may have the right to access, correct, delete, restrict, or port your personal data, and to object to certain processing. You may also lodge a complaint with your supervisory authority.
To exercise your rights, contact [[email protected]]. We may need to verify your identity first.
9. Security
We use technical and organisational measures to protect personal data, including encryption in transit, hashed credentials, access controls and audit logging. No method of transmission or storage is completely secure; please use a strong, unique password and keep it confidential.
10. Cookies
We use cookies and similar technologies as described in our Cookie Policy.
11. Children
The Platform is not directed to anyone under 18. We do not knowingly collect data from children. If you believe a child has provided us data, contact us and we will delete it.
12. Changes and contact
We may update this Policy; the “last updated” date will change and material changes will be notified. Contact us at [[email protected]] or via our contact page.
This document is a template provided to operators of the platform and is not legal advice. Replace the bracketed placeholders (operator name, jurisdiction, contact details) and have it reviewed by qualified counsel before going live.