Privacy Policy
This Privacy Policy (hereinafter referred to as the “Policy”) is effective from December 2025 and shall remain effective until a more recent version is released. Lepano Investments Limited may amend or supplement this Policy at any time and, in such event, will publish the updated version on this page together with the effective date of the said amendments.
Lepano Investments Limited (hereinafter referred to as the “Company”, “Lepano”, “we”, “us” or “our”) is a private company limited by shares, incorporated and registered in the Republic of Cyprus with Company Number ΗΕ 267520, having its registerd office situated at 10 Simonidi Str., CYPRESS TOWER, 1st floor, Strovolos, 2046, Nicosia, Cyprus.
Note: The English version of this Privacy Policy is the governing version and shall prevail whenever there is any discrepancy between the English version and the versions in any other language.
1. Introduction
The Company is committed to safeguarding privacy, security and online safety which are central to the Company’s mission to protect users of our products and services from risks such as theft, disruption, and unauthorized access to their personal information and online activities. This purpose of this Policy is to explain to you:
• what Personal Data of yours we collect;
• how we use your Personal Data;
• how, with whom and when your Personal Data is shared;
• your rights; and
• other useful privacy and security related matters.
When collecting, processing and storing Personal Data provided by you, we are subject to the provisions of the General Data Protection Regulation (the “GDPR”), the Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018), as amended from time to time, as well as applicable Personal Data Protection Laws and regulations of the Republic of Cyprus (collectively referred to herein as “Applicable Law”).
We strongly encourage you to read this Policy in full. If you have any questions regarding this Policy or the processing of your personal information, please contact us at privacy@markets.com.
By using our website, you acknowledge and consent that Lepano will process your Personal Information in accordance with this Policy, including for the purposes described in paragraph 3 below.
If you do not wish to provide your Personal Information on the terms set out in this Privacy Policy, you should refrain from entering such information into website forms or otherwise providing it to us. Please note that if you do not provide your Personal Information, we may not be able to respond to or support your queries.
2. Collection of Personal Data
In the course of operating the Website, we collect and process Personal Information the exhaustive list of which are set out in paragraph 3 below.
We collect Personal Information that you provide to us directly, including when you register your interest or communicate with us. We also collect information relating to your use of the Website, as well as any other information necessary for the purposes described in this Policy.
2.1. Collection of Information through Cookies and Similar Technologies
We collect information through Cookies as well as pixel tags and tracking links (“Similar Technologies”) to recognize you when you visit the website and to enhance your user experience.
We also use information collected through Cookies and Similar Technologies to detect and prevent misuse of our website and services and to assist in verifying your age when accessing the site.
For more information regarding Cookies and Similar Technologies, please refer to paragraph 11 of this Policy and our Cookie Policy available through our website.
Collection of Information from third parties and how we use it
We do not use information from any third-party service providers.
3. Use of Personal Information
In accordance with the Applicable Law, we will only process your Personal Information where we have a lawful basis to do so.
The table below sets out the purposes for which we process your Personal Information, together with the corresponding lawful bases for such processing:
Purpose | Retention Period | Lawful Basis | Geographic Locations where data is internally used |
Enquiry Forms è Interest in forming an agreement with Lepano. | Retained for 1 year from the date of form submission. If no agreement is formed within this period, the data will be deleted from our systems. | Consent | UK, EU, Israel, Australia, Singapore |
Enquiry Forms è Interest in forming an agreement with Lepano. | Retained for 1 year from the date on which you notify us that you no longer wish to receive updates on promotions or services, after which the data will be securely deleted from our systems. | Consent | UK, EU, Israel, Australia, Singapore |
4. Disclosure of Personal Information
We may disclose your Personal Information for the purposes identified in this Policy, to the following recipients:
1) Any company within our group (including its employees and subcontractors) that assists the group in fulfilling the stated purposes or otherwise has a legitimate need to access such information. For clarity, the group currently consists of the following entities:
a) Safecap Investments Limited
b) Clear Consulting Services Limited
2) Third parties that assist the Company in fulfilling the stated purposes, including (but not limited to) teams providing support through Human Resources, Commercial, Compliance, or Information Security functions. For clarity, the group currently consists of the following entities:
a) Reel Fintech Limited
b) Planex Technology SDN. BHD
3) Any law enforcement authority that has a lawful and reasonable need to access your Personal Information.
4) Any regulatory body or other authorized entity (including law enforcement agencies) that has a lawful and reasonable requirement to access your Personal Information.
5) Any potential purchaser of our business, any prospective investor, or any investor in any company within our group (including in the event of insolvency).
6) We may also collect and process Personal Information when you request technical assistance or customer support.
If you wish us to stop processing your Personal Information for the purposes set out in paragraph 3, you may contact us at privacy@markets.com and will take appropriate steps to cease such processing, provided no legal or regulatory obligations require us to continue.
5. Marketing Preferences
The Company will not send you any unsolicited information regarding third party’s products or services.
Any marketing and advertising communication we send will always include clear instructions on how you can to opt out of receiving further such communications.
6. Transfer of your Personal Information outside of the UK and EEA
Your Personal Information may be transferred outside the European Economic Area (“EEA”) or the United Kingdom (“UK”), both to us and to our group. Please refer to paragraph 3 for a detailed list of the geographic locations relevant to each processing purpose.
Where we transfer your Personal Information outside the EEA or the UK, we implement appropriate safeguards to ensure that it remains protected. These safeguards may include:
(i) transfers to jurisdictions that the European Commission has determined provide an adequate level of data protection; and
(ii) the use of standard contractual clauses adopted by the European Commission for the lawful transfer of personal data.
7. Updating your Personal Information
You may request an update or deletion of your Personal Information at any time by contacting us at privacy@markets.com.
8. Your Rights
Under Applicable Law, you may exercise the following rights with respect to your Personal Information:
8.1. The Right to Access your Personal Information held by us, also known as a Subject Access Request. You have a right to request a copy of the personal information that we hold about you.
Ø You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible in accordance with the timeframes provided under the Applicable Law.
8.2. The Right to Receive certain Personal Information in a machine-readable format.
8.3. The Right to Object to Processing where the lawful basis is our legitimate interests. However, please note that we may continue to process your Personal Information where other lawful bases exist, or where we have compelling legitimate grounds to do so that are not overridden by your rights, interests, or freedoms.
8.4. The Right to correction of Personal Information. You can request us to rectify and correct any Personal Data that we are processing about you which is incorrect.
8.5. The Right to have certain Personal Information erased where:
8.5.1. it is no longer necessary for the purposes for which it was collected;
8.5.2. you have withdrawn consent pursuant to paragraph 5.8;
8.5.3. you have objected pursuant to paragraph 5.3;
8.5.4. the Personal Information has been unlawfully processed; or
8.5.5. erasure is required by law.
8.6. The Right to Request an explanation of the logic involved in decisions made about you solely through automated processing.
8.7. The Right to lodge a complaint to a Data Protection Authority, such as the Office of the Commissioner for Personal Data Protection.
8.8. The Right to Withdraw Consent at any time, where we have relied on your consent to process Personal Information and have no other lawful basis.
8.9. The Right to object to direct marketing at any time, which can be exercised by opting out via the marketing communication itself. You also have the right to object to any profiling to the extent it relates to direct marketing.
If you are unsure about your rights or have concerns regarding the processing of your Personal Information, you may contact your National Data Protection Authority.
To exercise any of your rights, please contact us as at privacy@markets.com.
While we will make reasonable efforts to accommodate your request, these rights are not absolute and we may be unable to comply fully or partially in certain circumstances.
When you make a request regarding your rights, we will require proof of identification and may request further clarification of your request. Following this step, we will aim to respond to your request within one month of verifying your identity. If we receive repeated or manifestly unreasonable requests, we reserve the right not to respond.
9. Retention of your Personal Information
We will retain your Personal Information only for as long as necessary to provide our Services and to comply with our legal and regulatory obligations. Please refer to paragraph 3 for the specific retention periods.
Where it is no longer necessary to process your Personal Information, we will delete it in accordance with the timeframes set out in paragraph 3.
10. Contact us
If, at any time, you have any questions or believe that we have not adhered to this Privacy Policy, please contact our privacy team at privacy@markets.com.
11. Advertising and our use of Cookies
12. Security
We are committed to protecting your Personal Information. To prevent unauthorised access or disclosure, we have implemented appropriate physical, electronic and managerial safeguards to secure the Personal Information we collect.
All Personal Information you provide is stored in a secure computing environment, protected by firewalls and other security measures to prevent unauthorised access. Access is restricted to individuals who require it for their role and all staff receive security training and are required to comply with comprehensive security policies, procedures, and standards.
When you access any part of our website, information transmitted between your device and our servers is encrypted in line with industry standards, ensuring it cannot be read in transit.
Where Personal Information is disclosed to our service providers, we require them to process and protect it in a manner consistent with this Policy and the Applicable Law.
13. Testing
Occasionally, we may share limited Personal Information with third-party service or software providers to test new services or enhance our capabilities to comply with regulatory requirements. Any Personal Information shared will be restricted solely for the purposes of testing and evaluating these services or software. This testing is an essential part of our ongoing efforts to improve the services we provide to our clients and users.
All Personal Information shared for testing purposes will be securely deleted promptly at the conclusion of the testing period.
14. Agreement
By accessing and using this website, you acknowledge that you have read and understood this Policy and confirm that you have full power and authority to be bound by its terms.
For any queries or further information in relation to this Privacy Policy please contact us by sending an email to privacy@markets.com.
