This Privacy Policy explains how Blue Chip Origin ("we", "our", "us") collects, uses, and protects personal data when you use our website and investor portal. We act as the data controller for the information described below. This policy is intended to be consistent with the UK GDPR and the Data Protection Act 2018.
1. Data we collect
- Identity & contact: name, date of birth, address, email, mobile number.
- Onboarding & KYC: photo ID, proof of address, questionnaire answers, signed Participation Agreement.
- Account & transactional: deposits, withdrawals, unit balances, NAV history, communications with our desk.
- Technical: IP address, browser/device information, login timestamps, audit-log events.
2. Why we use your data and our lawful bases
- Performance of a contract — to administer your participation, process deposits and withdrawals, and provide the investor portal.
- Legal obligation — to comply with anti-money-laundering, counter-fraud, accounting, and tax record- keeping requirements.
- Legitimate interests — to keep the platform secure, prevent abuse, and improve our service. We balance this against your rights and only rely on it where it is proportionate.
- Consent — for any non-essential communications; you can withdraw consent at any time.
3. Who we share with
- Vantage Markets, for trade execution and brokerage administration.
- Sub-processors providing hosting, database, email, and identity verification (under written contracts).
- Professional advisers (accountants, lawyers) on a need-to-know basis.
- Regulators, courts, and law enforcement where required by law.
We do not sell your personal data.
4. International transfers
Some sub-processors may process data outside the UK. Where they do, we rely on UK-adequacy regulations or the International Data Transfer Agreement / Addendum to the EU Standard Contractual Clauses, together with additional safeguards where appropriate.
5. Retention
We retain identity, onboarding, and transaction records for the duration of your participation and for a minimum of five years after your final transaction, in line with UK anti-money-laundering record-keeping requirements. We may retain records longer where required by law or to defend legal claims.
6. Your rights
You have the right to:
- access the personal data we hold about you;
- have inaccurate data corrected;
- have data erased, subject to our legal retention obligations;
- restrict or object to certain processing;
- data portability where applicable;
- withdraw consent at any time where processing is based on consent;
- lodge a complaint with the UK Information Commissioner's Office (ico.org.uk).
7. Security
We apply technical and organisational measures appropriate to the risk, including encryption in transit, access controls, server-side row-level security on user data, and audit logging. No system is perfectly secure; we will notify affected users and the relevant authority in the event of a notifiable personal data breach.
8. Cookies
We use strictly necessary cookies and similar local-storage items to keep you signed in and to protect against abuse. We do not use advertising cookies.
9. Contact
To exercise your rights or to ask any privacy question, contact us via the investor portal or by email at the address we provide during onboarding.