Privacy Policy

Funded.Guru (referred to herein as “Funded.Guru”, “we”, “our”, or “us”) is the trading name of Funded Guru Services - FZCO, a company registered under the laws of the United Arab Emirates. We offer Access Passes that grant entry to simulated trading evaluation programmes and simulated funded account programmes. Funded.Guru is not a licensed financial institution, investment firm, brokerage, broker-dealer, custodian, asset manager, payment institution, deposit-taking entity, or regulated financial services provider, and our Services do not constitute investment services, investment advice, or the trading of real financial assets. All trading conducted through our Services takes place in a simulated environment, and any monetary amounts paid by us to users are discretionary Performance Rewards as defined in our Terms and Conditions, not investment returns, profits from real trading, salary, or guaranteed compensation.

We are committed to protecting and respecting your privacy. This Privacy Policy describes how we collect, use, store, share, and protect your personal data when you access or use our website, platform, dashboard, evaluation programmes, simulated funded accounts, Access Passes, and related features and services (collectively, the “Services”).

This Privacy Policy is issued in compliance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“UAE PDPL”), and, where applicable, the EU General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), and other applicable data protection laws.

This Privacy Policy forms part of, and should be read together with, our Terms and Conditions, KYC/AML Policy, Cookie Policy, and any programme-specific rules or supplementary documents published on our website or dashboard (collectively, the “Policies”). In the event of any conflict between this Privacy Policy and our Terms and Conditions on matters relating to personal data, this Privacy Policy shall prevail in respect of data protection matters; on all other matters, the Terms and Conditions shall prevail.

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the collection and use of your personal data as described in this Privacy Policy. If you do not agree, please discontinue use of our Services.

1. Eligibility and Geographic Restrictions

Our Services are not directed at, nor intended for distribution to, residents or citizens of any Restricted Jurisdiction or Excluded Jurisdiction as defined in our Terms and Conditions. By accessing or using our Services, you represent and warrant that you are not a resident or citizen of a Restricted Jurisdiction or Excluded Jurisdiction and that you are at least eighteen (18) years of age. The list of Restricted Jurisdictions and Excluded Jurisdictions may be updated from time to time and the current list is set out in our Terms and Conditions.

2. Data Controller and Privacy Contact

The data controller responsible for your personal information is:

Funded Guru Services - FZCO
Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates
General contact: support@funded.guru
Privacy and data protection enquiries: support@funded.guru

For all privacy-related inquiries, requests, complaints, or to exercise any of the rights described in this Policy, please contact us at the email address above. Privacy enquiries are handled by our internal compliance function.

3. Definitions

For the purposes of this Privacy Policy:

• “Personal Data” means any information relating to an identified or identifiable natural person.
• “Processing” means any operation performed on Personal Data, whether automated or not, including collection, recording, storage, alteration, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
• “Services” means all products, Access Passes, simulated evaluation programmes, simulated funded account programmes, tools, dashboards, and resources offered by Funded.Guru, in each case as further described in our Terms and Conditions.
• “Trading Data” means data generated by your simulated trading activity through platforms made available via our Services, including instruments simulated, simulated trade times, simulated position sizes, simulated performance metrics, and strategy patterns. Trading Data does not represent trades in real financial markets and does not reflect real profits or losses of the User.
• “User”, “you”, or “your” means any natural person who accesses or uses our Services.
• “Access Pass” has the meaning given in our Terms and Conditions and refers to the non-refundable digital pass granting entry to a specific simulated evaluation programme tier or simulated account type.
• “Performance Reward” has the meaning given in our Terms and Conditions and refers to the discretionary monetary amount paid by Funded.Guru based on simulated trading performance, subject to programme rules. Performance Rewards do not constitute investment income or financial returns.

4. Information We Collect

We may collect the following categories of personal data from you, either directly, automatically, or through third parties:

4.1 Information You Provide Directly

• Full name, email address, phone number, date of birth, and nationality
• Government-issued identification documents (passport, national ID) collected for KYC/AML verification purposes
• Proof of address and other verification documents
• Payment information (processed securely by third-party payment providers – we do not store full card details)
• Communications you send to us, including support tickets, emails, and feedback
• Account registration details, preferences, and settings

4.2 Information Collected Automatically

• IP address, browser type, device identifiers, operating system, and device fingerprint data
• Usage data, including pages visited, time spent, click patterns, and session information
• Cookies and similar tracking technologies (see Section 13 below)
• Behavioural data used for fraud detection, including login patterns, mouse and keyboard behaviour, and session anomalies
• Trading Data associated with your simulated evaluation or simulated funded account

4.3 Information From Third Parties

• Identity verification data from KYC/AML service providers
• Data from third-party trading platform providers whose platforms are made available through our Services
• Sanctions, watchlist, and politically exposed persons (PEP) screening results
• Wallet risk and blockchain analytics data from blockchain analytics providers
• Payment, settlement, and chargeback data from our payment processors and merchants of record
• Information lawfully obtained from public sources, commercial databases, credit reference agencies, fraud-prevention networks, and other regulated information providers for compliance, fraud-prevention, and verification purposes (which may, where permitted by applicable law, be obtained without prior notice to you)
• Social media data if you choose to link or authenticate via a third-party social account (username, profile picture, email)
• Affiliate and referral tracking data

4.4 Wallet, Crypto-Asset, and Travel Rule Data

Where you receive or make payments in crypto-assets in connection with our Services, our authorised payment partners, crypto-asset service providers, and virtual asset service providers (“VASPs”) may collect, process, retain, and transmit the originator and beneficiary information required under applicable Travel Rule and AML/CFT obligations — including your name, address, date of birth, wallet address(es), transaction identifiers, and identification details — to counterparty VASPs and competent authorities. Funded.Guru is not itself a crypto-asset service provider or VASP. To support these obligations and to comply with our own AML/CFT and sanctions obligations, we collect, retain, and share the same information with our authorised payment partners and competent authorities as required by applicable law.

5. How We Use Your Information

We use your personal data for the following purposes:

• To create and manage your account on our platform
• To process your purchase of evaluation programmes and related services
• To verify your identity and conduct KYC/AML compliance checks
• To provide, operate, and improve our Services and platform features
• To communicate with you regarding your account, transactions, programme updates, and support queries
• To assess your simulated trading performance against programme rules and administer discretionary Performance Rewards
• To detect, investigate, and prevent fraud, abuse, account manipulation, multi-accounting, collusion, and other prohibited trading activity
• To comply with applicable laws, regulations, and legal obligations
• To send marketing communications and promotional offers where you have consented
• To conduct analytics and improve our platform's features, performance, and user experience
• To administer affiliate commissions and referral tracking
• To process Performance Reward payments and verify wallet addresses, including blockchain analytics screening, Travel Rule transmissions, and source-of-funds verification where required under AML/CFT laws
• To enforce our Terms and Conditions and protect our legal rights

6. Legal Bases for Processing

We process your personal data on the following legal grounds:

• Contractual necessity: processing required to fulfil the agreement between you and Funded.Guru (e.g., account management, programme delivery, rewards processing).
• Legal obligation: processing required to comply with applicable laws and regulations, including AML/KYC obligations.
• Legitimate interests: processing in our legitimate interests to maintain security, prevent fraud, improve our Services, develop new products, and manage our business, where such interests are not overridden by your rights.
• Consent: processing based on your explicit consent, including for marketing communications (which you may withdraw at any time).

7. Trading Data and Performance Analytics

Trading Data generated through your simulated activity on our Services is fundamental to the operation of our business and to the assessment of your eligibility for Performance Rewards. By using our Services, you acknowledge and agree that we may:

• Process Trading Data to evaluate your simulated performance against the rules of any simulated evaluation programme or simulated funded account
• Analyse Trading Data to detect rule violations, prohibited strategies, latency arbitrage, copy-trading, group trading, hedging across accounts, and other forms of abuse defined in our Terms and Conditions
• Use aggregated and anonymised Trading Data for internal analytics, risk modelling, product development, statistical research, and the training and improvement of our automated systems, including machine learning and artificial intelligence models
• Share aggregated, anonymised, or de-identified Trading Data with third-party trading platform providers, liquidity providers, technology partners, and other service providers for risk management, execution quality analysis, and operational purposes
• Publish aggregated or anonymised performance statistics, benchmarks, and industry insights derived from Trading Data
• Retain Trading Data following the closure or termination of your account for fraud prevention, dispute resolution, regulatory compliance, and historical analysis

We do not sell raw, identifiable Trading Data. Aggregated and anonymised Trading Data is not considered personal data under applicable law. For the avoidance of doubt, Trading Data does not reflect trading in real financial markets and Performance Rewards are not investment returns.

8. Fraud Prevention and Account Integrity

To protect our business, our community of traders, and the integrity of our Services, we operate a comprehensive fraud and abuse prevention programme. This may include:

• Linking and cross-referencing accounts that appear to be operated by the same individual or coordinated group, using identifiers such as IP address, device fingerprint, payment instruments, behavioural patterns, and trading patterns
• Behavioural biometrics and device fingerprinting to detect automation, bots, account sharing, and identity manipulation
• Monitoring trading activity for indicators of prohibited strategies, including but not limited to latency arbitrage, news trading violations, copy trading, hedging across accounts, and exploitation of pricing or platform errors
• Sharing fraud signals, identifiers, and risk indicators with other proprietary trading firms, industry bodies, fraud-prevention networks, and service providers where permitted by law
• Retaining records relating to banned, suspended, or terminated accounts for the periods set out in Section 12 below to prevent re-registration and recurrence of abusive conduct
• Reporting suspected fraud, money laundering, or other unlawful activity to competent authorities

Where an account is suspended, terminated, or denied a payout on the basis of suspected fraud or rule violation, we may retain all associated personal data, Trading Data, and verification records for the duration necessary to defend our legal interests and comply with regulatory obligations.

9. Automated Decision-Making

We use automated processing, including algorithmic and rule-based systems, to support a number of operational decisions. This may include:

• Automated assessment of simulated performance against the rules of our evaluation and simulated funded account programmes
• Automated detection of prohibited trading patterns, rule violations, and suspected fraud
• Automated KYC and AML screening, including sanctions, watchlist, and PEP checks
• Automated risk scoring and account flagging

Where an automated decision produces legal or similarly significant effects on you (for example, denial of a payout, account suspension, or termination), you have the right to request meaningful human review of that decision, to express your point of view, and to contest the decision. Requests for human review should be sent to support@funded.guru and will be reviewed by a qualified member of our compliance function.

10. KYC / AML Compliance

In accordance with applicable regulations and international anti-money laundering (AML) standards, we are required to verify the identity of our users. This process, commonly referred to as Know Your Customer (KYC), may involve:

• Collection and verification of government-issued identification documents
• Screening against international sanctions lists, watchlists, and politically exposed persons (PEP) databases
• Adverse media and background checks
• Verification of payment integrity and source of funds where required

KYC verification is performed by authorised third-party service providers. Raw KYC documents (such as identity document images and selfie verifications) are processed and stored by our verification provider in accordance with their own security and data protection standards. We receive and retain only the verification outcome, summary metadata, and audit records necessary for compliance. KYC verification is a prerequisite for the payment of any Performance Reward and may be required at any stage of the relationship.

11. Sharing Your Personal Data

We do not sell your personal data. We may share your information in the following circumstances:

11.1 Service Providers

We engage trusted third-party service providers who process data on our behalf, including:

• Payment processors, merchants of record, financial institutions, and banking partners
• Crypto-asset service providers and virtual asset service providers used for Performance Reward payouts
• Blockchain analytics and wallet risk-screening providers
• KYC/identity verification and fraud-prevention providers
• Third-party trading platform providers, liquidity providers, and data feed providers in connection with platforms made available through our Services
• Cloud hosting and infrastructure providers
• Analytics and performance monitoring tools
• Customer support and communication platforms
• Marketing, advertising, and email service providers

All service providers are contractually bound to process your data only on our instructions and in compliance with applicable privacy laws, including by way of data processing agreements and, where relevant, Standard Contractual Clauses. Funded.Guru may change, add, or replace service providers from time to time without notice. The identity of the applicable provider for any given transaction may be disclosed during the payment process or within your dashboard.

We may also grant temporary, monitored access to authorised third parties (including subcontractors and technology providers) for the purpose of troubleshooting, maintaining, or supporting our website, dashboard, database, or infrastructure. Such access is logged, supervised, and removed once the relevant work is completed.

11.2 Affiliates and Referral Partners

Where you sign up through an affiliate or referral link, we share limited information with the relevant affiliate strictly for the purpose of attribution, commission calculation, and programme administration. Affiliates may see the following information about their referred users:

• Link clicks and conversion events
• Sign-up confirmations
• Conversions and recurring referral activity
• Average and total referred trader lifetime value (LTV)
• Referral geography (country level)
• Identification of top-performing referrals
• Eligible commission and total commission earned

Affiliates do not receive your name, contact details, identity documents, payment details, individual Trading Data, or any other personal data beyond what is set out above. Affiliates themselves may be subject to KYC verification, attribution review, and other compliance requirements as set out in our affiliate programme terms, and we process Affiliate personal data accordingly.

11.3 Legal and Regulatory Disclosure

We may disclose your personal data to regulatory authorities, law enforcement, courts, or other government bodies where required by law, court order, or to protect the rights, property, or safety of Funded.Guru, our users, or third parties.

11.4 Industry Fraud Prevention

As described in Section 8, we may share fraud signals and risk indicators with other proprietary trading firms, industry bodies, and fraud prevention networks where permitted by law and necessary to protect against fraud and abuse.

11.5 Business Transfers

In the event of a merger, acquisition, restructuring, financing, or sale of assets, your personal data may be transferred to the successor entity, subject to the same privacy commitments described in this Policy.

11.6 With Your Consent

We may share your data with third parties in any other context where you have given your explicit opt-in consent.

12. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. In particular:

• Account data is retained for the duration of your relationship with us and for a reasonable period thereafter
• AML/CFT compliance retention: personal data, KYC/AML documentation, transaction records, and trading activity logs are retained for a minimum of five (5) years from the date of account termination or the date of the last transaction (whichever is later), in accordance with UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and its implementing regulations, or for such longer period as may be required by applicable law
• Tax and accounting records: retained for the period required under UAE Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses, the UAE Commercial Companies Law, and any other applicable tax and accounting legislation (typically up to seven (7) years)
• Trading Data: may be retained indefinitely in aggregated and anonymised form, and in identifiable form for fraud prevention, dispute resolution, and regulatory purposes for the periods set out above
• Banned, suspended, or terminated accounts: records (including the minimum identifiers necessary to maintain a re-registration block) are retained for the longer of (a) the AML/CFT retention period set out above, (b) any applicable limitation period during which legal claims may be brought by or against Funded.Guru, and (c) the period reasonably necessary to detect and prevent recurrence of abusive conduct; retention under this paragraph is reviewed at intervals of no more than five (5) years, and personal data not required for the purposes above is securely deleted, further anonymised, or archived
• Legal claims and defence: retained for the duration of any applicable limitation period during which legal claims may be brought by or against Funded.Guru
• Sanctions, fraud, and regulatory cooperation: retained for so long as necessary to comply with sanctions monitoring, fraud prevention, counter-terrorism financing obligations, and lawful requests from competent authorities
• Marketing consent records are retained until you withdraw consent or as otherwise required
• Where a User is deceased, legally incapacitated, or insolvent, personal data is retained and processed in accordance with the retention periods above; rights to Performance Rewards are not transferable to heirs, estates, beneficiaries, or assigns as set out in our Terms and Conditions

Termination of your account does not result in the immediate deletion of all personal data. The obligations and rights of the parties incurred prior to termination shall survive termination of the relationship. When personal data is no longer required for any of the purposes above, we will securely delete, anonymise, or archive it in accordance with applicable law.

13. Cookies and Tracking Technologies

We use cookies and similar technologies (e.g., pixels, web beacons, local storage) to operate and improve our Services. Cookies may be used for:

• Essential functionality: required for our platform to function properly (e.g., session authentication).
• Performance and analytics: to understand how users interact with our platform and improve its performance.
• Marketing and retargeting: to deliver relevant communications and measure the effectiveness of our campaigns.
• Affiliate tracking: to attribute referrals and track commissions for our affiliate programme.

Where required by applicable law, we obtain your consent for non-essential cookies via our cookie banner, where you can grant or refuse consent on a granular basis (essential, analytics, marketing). You may manage your cookie preferences at any time through our cookie banner or your browser settings. Disabling certain cookies may affect the functionality of our Services.

14. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (SSL/TLS) and at rest where appropriate
• Access controls and authentication mechanisms, including multi-factor authentication for sensitive systems
• Regular security assessments, vulnerability monitoring, and penetration testing
• Employee training on data handling and privacy obligations
• Network segregation and least-privilege access for systems containing personal data

While we take reasonable precautions, no system is completely secure. We cannot guarantee absolute security. Our liability in respect of any security incident is subject to the limitation of liability provisions set out in our Terms and Conditions and, where applicable, the protections available to you under applicable data protection law.

15. Data Breach Notification

In the event of a personal data breach likely to result in a risk to the rights and freedoms of affected individuals, we will:

• Notify the competent supervisory authority without undue delay, and where feasible within seventy-two (72) hours of becoming aware of the breach, in line with applicable UAE PDPL, GDPR, and UK GDPR requirements
• Notify affected users without undue delay where the breach is likely to result in a high risk to their rights and freedoms
• Take reasonable steps to contain, investigate, and remediate the breach
• Maintain internal records of all personal data breaches, regardless of whether external notification is required

16. International Data Transfers

Funded.Guru operates in the UAE and engages service providers and infrastructure located in various jurisdictions. Your personal data may be transferred to, processed in, and stored in countries outside of your country of residence, including jurisdictions that may not provide the same level of data protection as your home jurisdiction.

Where personal data is transferred internationally, we ensure appropriate safeguards are in place, which may include:

• Transfers to jurisdictions recognised as providing an adequate level of protection
• Standard Contractual Clauses approved by the European Commission or other competent authorities
• Contractual safeguards consistent with UAE PDPL requirements
• Binding corporate rules, certifications, or other approved transfer mechanisms

You may request information about the specific safeguards applied to a transfer by contacting support@funded.guru. By using our Services, you consent to such transfers to the extent permitted by applicable law.

17. Your Rights

Subject to applicable law, you may have the following rights in relation to your personal data:

• Right of access: to request confirmation of whether we process your data and to obtain a copy.
• Right to rectification: to request correction of inaccurate or incomplete data.
• Right to erasure: to request deletion of your data in certain circumstances.
• Right to restriction: to request that we limit processing of your data in certain circumstances.
• Right to data portability: to receive your data in a structured, machine-readable format.
• Right to object: to object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: where processing is based on consent, to withdraw it at any time without affecting prior lawful processing.
• Right to human review of automated decisions: as described in Section 9.
• Right to lodge a complaint: with the competent supervisory authority in your jurisdiction.

To exercise any of these rights, please contact us at support@funded.guru. We will respond within thirty (30) days of receiving a verified request, extendable by a further sixty (60) days where the request is complex or where we receive a high volume of requests. We may require identity verification before processing your request. You acknowledge that these rights are not absolute and that we may refuse, restrict, or defer compliance with such requests to the extent necessary to comply with our legal obligations (including AML/CFT, sanctions, and tax retention obligations), to establish, exercise, or defend legal claims, or where another exemption under applicable data protection law applies.

18. Marketing Communications

Where you have provided consent, we may send you marketing communications about our Services, promotions, and offers. You may withdraw your consent at any time by clicking the unsubscribe link in any marketing email or by updating your preferences within your account dashboard. Withdrawal of marketing consent does not affect our ability to send you transactional, security, or service-related communications.

In order to improve our Services and measure the effectiveness of our communications, we may receive notifications when you open emails from us or click on links contained within them. This data is used to understand engagement, optimise content, and ensure deliverability. You can limit email tracking by configuring your email client to block remote images, or by unsubscribing from marketing communications as described above.

19. Minors

Our Services are not directed at, and are not available to, persons under the age of eighteen (18). We do not knowingly collect personal data from minors. Our KYC process is designed to verify that users are of legal age. If you believe we have inadvertently collected data from a person under 18, please contact us immediately at support@funded.guru and we will take appropriate steps to delete such information.

20. Third-Party Links and Services

Our platform may contain links to third-party websites, platforms, social media services, third-party trading platforms, affiliate networks, or other services. We are not responsible for the privacy practices or content of such third parties. We encourage you to review the privacy policies of any third-party platforms you interact with through our Services.

21. Confidential Communications

Certain communications and information exchanged between you and Funded.Guru — including compliance investigations, risk assessment correspondence, internal review communications, settlement and dispute-resolution discussions, and any communications relating to suspected rule violations or fraud — are treated as confidential under our Terms and Conditions and are processed and retained accordingly. Personal data contained in such communications is processed for the purposes of compliance, dispute management, and the establishment, exercise, or defence of legal claims.

22. Governing Law and Jurisdiction

This Privacy Policy and any dispute or claim arising out of or in connection with it (including non-contractual disputes) shall be governed by and construed in accordance with the laws of the United Arab Emirates as applicable in the Emirate of Dubai. Any dispute, controversy, or claim arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the Dubai Courts.

23. Severability

If any provision of this Privacy Policy is held by a court or other tribunal of competent jurisdiction to be invalid, illegal, or unenforceable for any reason, such provision shall be modified to the minimum extent necessary to make it valid and enforceable, or, if it cannot be so modified, shall be severed from this Privacy Policy. The remaining provisions shall continue in full force and effect.

24. Language

This Privacy Policy is issued in English. Where it is translated into any other language, the English version shall prevail in the event of any conflict, inconsistency, or discrepancy between versions.

25. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. When we make material changes, we will notify you by email or through a prominent notice on our platform prior to the change becoming effective. Material changes include, without limitation, changes affecting the categories of personal data we collect, the purposes of processing, the recipients of personal data, or your rights. Your continued use of our Services after the effective date of any update constitutes your acceptance of the revised Policy.

Material changes from the previous version (April 2026) include: identification of Funded Guru Services - FZCO as data controller; alignment of Restricted Jurisdictions with our Terms and Conditions (v4); expanded disclosures regarding Trading Data, fraud and abuse prevention, automated decision-making, crypto-asset Travel Rule data, wallet risk screening, and blockchain analytics; enhanced provisions on international data transfers, data breach notification, and retention with reference to UAE Federal Decree-Law No. 20 of 2018 and UAE Federal Decree-Law No. 47 of 2022; clarification of affiliate data sharing; addition of a Confidential Communications section; the addition of governing law, severability, and language provisions; and the addition of email engagement tracking disclosures in Section 18.

A current version of this Privacy Policy is always available on our website and within your client dashboard.

26. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: support@funded.guru
Website: https://funded.guru
Address: Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates

This Privacy Policy was last updated on 14 May 2026 and supersedes all prior versions.