Privacy Policy

1. About Us and the Controller

1.1 Controller details

The controller responsible for the personal information described in this Policy is:

SA Futures Limited, trading as Halow CapitalCompany number: 14219285Registered office: Martlet House E1 Yeoman Gate, Yeoman Way, Worthing, West Sussex, United Kingdom, BN13 3QZEmail: halow@halowcapital.comTelegram: @Halowhq

1.2 Our role

Halow Capital sells and licenses BASE, provides Software-related support and may introduce Customers to independent Developers of Third-Party Products. Halow Capital determines why and how it uses personal information for its own Website, contracts, licensing, payments, support, compliance and business administration and is therefore the controller for those activities.

1.3 Other organisations may also be controllers

Some organisations that receive or collect information in connection with our activities determine their own purposes and means of processing and may therefore act as separate or joint controllers. This may include Telegram, Google for certain Analytics settings, banks, crypto exchanges, wallet providers, professional advisers and independent Developers. Their own privacy notices may also apply.

1.4 Scope

This Policy applies to personal information processed through:

a. www.halowcapital.com and associated Base44 pages, forms and applications;b. email, Telegram, telephone, video calls and support channels;c. BASE invoice requests, Orders, licences, activation and support;d. invoices and direct payment instructions issued by SA Futures Limited, trading as Halow Capital;e. cryptoasset and bank-transfer payment records;f. Developer and Third-Party Product introductions;g. marketing subscriptions and preference records; andh. related legal, security, accounting and business records.

2. Information We Collect

2.1 Contact and identity information

We may collect:

a. full legal name;b. email address;c. telephone number;d. Telegram username;e. billing and postal address;f. country and jurisdiction;g. age or confirmation that you are at least 18;h. company name, company number, role and VAT or tax details where applicable; andi. identity or verification information where reasonably required for fraud prevention, sanctions, payment security or legal compliance.

2.2 Enquiry and communication information

We collect messages, enquiries, requests, complaints, feedback, support conversations, call notes and other information you provide when communicating with Halow Capital. Communications may take place through email, Website forms, Telegram, telephone, video call or another agreed channel.

2.3 Order, product and licence information

For BASE and other directly supplied products, we may collect:

a. the product and licence requested;b. the agreed price, currency and payment method;c. the Order, invoice and Order Confirmation;d. the exact legal name used for licence registration;e. broker names and relevant MT5 account-holder information;f. licence keys, activation identifiers, status and history;g. download, delivery, update and support records;h. immediate digital-supply acknowledgements and other contractual consents; andi. refund, cancellation, chargeback and dispute information.

2.4 Payment, invoice and cryptoasset information

Depending on the payment route, we may collect or receive:

a. invoice number and invoice status;b. payer name, email, billing address and transaction reference;c. contractual price in USD, GBP or another stated currency;d. payment method and payment-provider information;e. bank-transfer sender information visible to us;f. cryptoasset type, blockchain network, amount, wallet address and transaction hash;g. quotation source, exchange rate, timestamp, confirmations and network fees;h. underpayment, overpayment, refund and reconciliation records; andi. fraud, sanctions, source-of-funds or payment-ownership information where reasonably required.

We do not require or ask you to provide online-banking passwords, crypto private keys, seed phrases or wallet recovery information. Do not send those details to us.

2.5 Technical and support information

When providing activation or support, we may process:

a. MetaTrader and Software versions;b. broker, server, symbol and account-type information;c. VPS or device information;d. configuration and settings information;e. screenshots, logs, error messages and diagnostic files;f. IP address and security metadata associated with access or activation; andg. records of troubleshooting, updates and resolution.

Support material may accidentally contain additional information. Before sending a screenshot or log, remove balances, account numbers, passwords, private messages and other information that is not needed for support.

2.6 Website, device and analytics information

When you visit or interact with the Website, we and our providers may collect:

a. IP address and approximate location derived from it;b. browser, operating system, device type and screen information;c. pages viewed, buttons selected, session timing and referral source;d. form-submission, error, security and performance logs;e. cookie and consent preferences; andf. analytics identifiers and event information where the required consent has been obtained.

Further details about cookies, local storage, analytics and similar technologies appear in the Cookie Policy.

2.7 Developer referral information

If you ask us to introduce you to an independent Developer, we may collect and forward the information reasonably needed to progress that request, such as your name, email address, telephone number, Telegram username, country, product interest and enquiry. We do not send your details to a Developer for an unrelated purpose without an appropriate lawful basis.

2.8 Marketing and preference information

We may record whether you asked to receive marketing, the date and method of consent, the content or version of the consent wording, your communication preferences, unsubscribe requests and suppression-list status.

2.9 Information from other sources

We may receive information from:

a. banks, wallet providers, exchanges and public blockchain explorers;b. the BASE Developer or another Developer involved in an introduction, activation or support issue;c. Base44, analytics, security and communications providers;d. public company, sanctions, fraud-prevention and verification sources; ande. professional advisers, regulators, law-enforcement bodies or courts where lawful.

2.10 Special-category information and criminal-offence information

We do not intentionally request health, biometric, racial or ethnic, religious, political, trade-union, sexual-life or similar special-category information. Please do not provide it unless it is strictly necessary and we have specifically requested it with an appropriate legal basis.

Fraud-prevention or sanctions checks may occasionally involve allegations, offences or enforcement information. We process such information only where lawful, necessary and proportionate, with appropriate safeguards.

2.11 Children

Our products and paid Services are intended only for persons aged 18 or over. We do not knowingly collect personal information from children for the purpose of selling or licensing Software. If you believe a child has supplied information to us, contact halow@halowcapital.com.

3. How We Collect Information

We collect information:

a. directly from you when you complete a form, request an invoice, place an Order, make payment, register a licence, request support, subscribe to marketing or communicate with us;b. automatically through the Website, essential technical logs, cookies, consent tools and analytics where permitted;c. from banks, wallet providers or exchanges when a payment is processed;d. from public blockchains and blockchain explorers when confirming a cryptoasset transaction;e. from the BASE Developer or another Developer where necessary for activation, technical escalation or a requested introduction; andf. from public or professional sources where reasonably necessary for verification, legal compliance, security or claims.

4. Why We Use Information and Our Lawful Bases

We use personal information only where we have a lawful basis. Different lawful bases may apply to different activities. The main purposes and bases are set out below.

Purpose

Information involved

Lawful basis

Respond to enquiries, provide product information and take requested steps before a purchase.

Contact, enquiry, product-interest and communication information.

Contract or steps requested before entering a contract; legitimate interests in responding to business enquiries.

Accept, administer and perform BASE Orders and other direct contracts.

Identity, billing, Order, licence, activation, delivery and communication information.

Contract.

Issue and reconcile invoices and payments made directly to SA Futures Limited by bank transfer or cryptoasset payment.

Billing, invoice, payment, wallet, transaction and reconciliation information.

Contract; legal obligation for accounting, tax and record keeping; legitimate interests in payment security.

Register, activate, protect and administer licences.

Legal name, MT5 account-holder details, licence identifiers, activation and usage-security records.

Contract; legitimate interests in licence administration, preventing misuse and protecting intellectual property.

Provide support, updates and technical troubleshooting.

Communications, screenshots, logs, configuration and diagnostic information.

Contract; legitimate interests in improving support, security and product operation.

Introduce you to an independent Developer when you request it.

Contact details, country, product interest and enquiry information.

Steps requested before a potential contract; legitimate interests in operating the referral service.

Operate, secure and improve the Website and business systems.

Technical logs, IP address, device, security, error and usage information.

Legitimate interests in availability, security, fraud prevention, service improvement and business administration.

Measure Website use through non-essential analytics.

Cookie, device, session, event and analytics information.

Consent where required by law.

Send optional marketing and product updates.

Name, email, preferences, consent and engagement information.

Consent. You may withdraw consent at any time.

Prevent fraud, misuse, unauthorised access, sanctions breaches and unlawful payments.

Identity, payment, wallet, technical, security and verification information.

Legitimate interests; legal obligation where a specific law applies.

Maintain accounting, tax, corporate and legal records.

Order, invoice, payment, refund, contract and correspondence records.

Legal obligation; legitimate interests in demonstrating and enforcing legal rights.

Handle complaints, disputes, refunds, chargebacks and legal claims.

Order, payment, support, communication and evidence records.

Contract; legal obligation; legitimate interests in establishing, exercising or defending legal rights.

Manage a genuine business sale, restructuring, insurance or professional audit.

Relevant business, contract and customer records subject to confidentiality and necessity.

Legitimate interests in business administration, continuity and corporate transactions; legal obligation where applicable.

4.1 Consent

Where we rely on consent, you may withdraw it at any time. Withdrawal does not make earlier lawful processing unlawful. Refusing or withdrawing optional marketing or analytics consent does not prevent you from purchasing BASE or receiving necessary contractual communications.

4.2 Contract

Where information is necessary to enter into or perform a contract, failure to provide it may mean that we cannot issue an invoice, accept an Order, register or activate a licence, deliver Digital Content, provide support or process a requested refund.

4.3 Legitimate interests

Where we rely on legitimate interests, those interests may include operating and improving our business, protecting Software and licences, preventing fraud and abuse, securing systems, responding to enquiries, maintaining appropriate records, handling disputes and supporting Customers. We assess whether the processing is necessary and whether your rights and interests override our interests.

4.4 Legal obligations

We may process information to comply with company, accounting, tax, consumer-protection, data-protection, sanctions, fraud-prevention, court, regulatory and law-enforcement obligations that apply to us.

5. Payments and Public Blockchains

5.1 Direct payments to SA Futures Limited

SA Futures Limited, trading as Halow Capital, creates, issues, administers and reconciles its own invoices and payments. Payments are made directly to SA Futures Limited by bank transfer or to an official company-controlled cryptoasset wallet address. We process the invoice details, payer information, bank or wallet information, transaction status and related records needed to administer the payment and comply with our legal obligations.

5.2 Direct Halow Capital payment instructions

We issue invoices containing bank-transfer details or a Halow Capital-controlled cryptoasset wallet address. We retain the information needed to identify, verify, reconcile and account for the payment. Official payment instructions are supplied through our authorised invoice or communication process. Never send payment to details provided by an unsolicited or unverified social-media message.

5.3 Public blockchain information

Cryptoasset transactions are recorded on public distributed ledgers. Wallet addresses, transaction hashes, assets, amounts and timestamps may be visible publicly and may be analysed or copied by third parties. Blockchain records are generally permanent and are not controlled by Halow Capital. Even where we delete our internal copy, we cannot erase or modify the underlying public blockchain record.

5.4 No custody or wallet service

Halow Capital accepts cryptoassets only as payment for products or Services. We do not ask for or hold your private keys, seed phrases or wallet-recovery information and do not provide customer wallet custody, cryptoasset exchange or investment services.

5.5 Payment checks

We may request proportionate identity, payment-ownership, wallet-ownership, jurisdiction or source-of-funds information where reasonably necessary to investigate fraud, sanctions, security, chargebacks, incorrect payments or legal obligations. We will not use such information for unrelated purposes.

6. BASE Developer and Independent Developers

6.1 BASE Developer

BASE is developed by Øyvind Borgsø under the Relevant Trading name (“BASE Developer”). Halow Capital may share limited Customer or technical information with the BASE Developer where reasonably necessary for Software development, licence activation, security, defect investigation, technical escalation or support.

Where the BASE Developer processes information solely on Halow Capital’s documented instructions, the processing is governed by the applicable contractual data-protection obligations. Where the BASE Developer independently determines a separate purpose and means of processing, he may act as a separate controller and must provide appropriate privacy information for that processing.

6.2 Third-Party Product referrals

When you request an introduction to an independent Developer, we may disclose the information reasonably required to progress that request. The Developer will normally act as a separate controller for its own product, sales, licensing, support, payment and communication activities. You should read the Developer’s privacy notice before providing further information or making payment.

6.3 No unrelated disclosure

We do not provide Customer details to Developers for unrelated marketing merely because a Developer appears on the Website. Marketing by a Developer requires its own lawful basis and compliance with applicable direct-marketing rules.

7. Who We Share Information With

We may share personal information, where reasonably necessary and lawful, with:

a. Base44 and its approved subprocessors for Website hosting, databases, forms, authentication, logging, security, email transmission, platform operation and related infrastructure;b. banks, wallet providers, crypto exchanges and other transaction services involved in payments made directly to SA Futures Limited;c. Zoho and other email, communications, file-storage or business-administration providers;d. Google Analytics and consent-management technology where the required consent has been obtained;e. Telegram and other communication platforms when you choose to contact us through them;f. the BASE Developer for limited activation, development, security or technical-support purposes;g. an independent Developer when you request a Third-Party Product introduction;h. accountants, solicitors, insurers, auditors, consultants and other professional advisers bound by appropriate duties;i. fraud-prevention, cybersecurity, identity, sanctions or compliance providers where reasonably necessary;j. courts, regulators, tax authorities, law-enforcement bodies and public authorities where legally required or necessary to protect legal rights; andk. a genuine purchaser, investor, lender or successor in connection with a proposed or completed business sale, financing or restructuring, subject to appropriate confidentiality and data-protection safeguards.

7.1 No sale of personal information

We do not sell personal information to data brokers or third parties. We do not provide Customer order or licence information to third parties for their unrelated targeted advertising.

7.2 Data minimisation

We seek to disclose only the information reasonably necessary for the relevant purpose. A service provider does not receive an unrestricted right to use Customer information for its own unrelated purposes merely because it supplies technology to Halow Capital.

8. Key Technology and Communications Providers

8.1 Base44

The Website and associated forms and data are built and hosted on Base44. Base44 processes application-user information on our behalf under its Data Processing Addendum and uses subprocessors to provide hosting, storage, communication, logging, analytics, security and related platform functions. Base44 may separately process account, service, security and legal-compliance information under its own privacy terms.

8.2 Current Base44 data location

At the date of this Policy, the Halow Capital Base44 application is hosted in the United States. Our current plan does not provide Halow Capital with UK or EU application-data residency. Base44 may process requests through services and subprocessors in other locations as described in its legal documentation.

8.3 Google Analytics

We use Google Analytics 4 to understand Website use and improve the Website. Analytics may process device, browser, page, session, event and approximate-location information. Non-essential analytics storage is controlled through the Website consent mechanism. Depending on our Google settings, Google may act as a processor for Analytics data and may act as a controller for certain data-sharing or independent service purposes.

8.4 Zoho

We use Zoho services for business email and related communications. Zoho may process message content, sender and recipient details, attachments, security logs and service metadata under its contractual and privacy terms.

8.5 Telegram

If you contact us through Telegram, Telegram processes your username, profile information, messages and technical information under its own privacy terms. Telegram should not be used to send private keys, seed phrases, payment passwords, identity documents or unnecessary sensitive information.

9. International Transfers

9.1 Transfers outside the United Kingdom

Some providers and recipients are located outside the United Kingdom or use international infrastructure. This means personal information may be stored, accessed or processed in the United States, the European Economic Area, Israel and other countries.

9.2 Safeguards

Where a restricted transfer is made and an adequacy regulation does not apply, we seek to use an appropriate safeguard, such as the UK International Data Transfer Agreement, the UK Addendum to the European Commission Standard Contractual Clauses, or another legally recognised mechanism. Where required, we consider whether the destination provides protection that is not materially lower than the protection available in the United Kingdom and whether additional measures are necessary.

9.3 Provider arrangements

Base44 states that it uses contractual and other approved transfer mechanisms for transfers involving the United Kingdom and European Economic Area. Other providers may rely on adequacy decisions, contractual clauses, approved data-transfer frameworks or other lawful mechanisms described in their privacy documentation.

9.4 Copies of safeguards

You may ask for further information about the safeguards relevant to your information by emailing halow@halowcapital.com. We may redact confidential commercial or security information from any copy supplied.

10. How Long We Keep Information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, tax, contractual, security and dispute requirements. We review retention periodically and delete or anonymise information that is no longer needed, subject to technical backup cycles and legal restrictions.

Record category

Typical retention approach

Enquiries that do not become purchases

Normally up to 3 years after the last meaningful contact, unless a shorter period is appropriate or a dispute requires longer retention.

Customer, Order, invoice, payment, refund and accounting records

Normally 6 years from the end of the relevant financial year or the end of the Customer relationship, and longer where required for an open tax enquiry, investigation, legal claim or other legal obligation.

Lifetime Licence registration and core activation records

For the duration of the licence and normally for 6 years after the licence or contractual relationship ends, so that we can administer, verify and enforce the licence and resolve disputes.

Monthly Access Plan records

For the active plan and normally 6 years after it ends or converts, subject to legal and accounting requirements.

Support communications, screenshots and technical logs

Normally up to 3 years after the support matter closes, unless linked to the continuing licence, a defect, complaint, security issue or legal claim requiring longer retention.

Fraud, security, sanctions and payment-investigation records

For as long as reasonably necessary to investigate and protect against the relevant risk, normally up to 6 years after closure where a legal or contractual issue may arise.

Marketing consent and preference records

While marketing continues and for a reasonable period afterwards to demonstrate consent. Unsubscribe and suppression information may be retained for as long as necessary to ensure that we honour the opt-out.

Website analytics information

For the retention period configured in the relevant analytics service and described in the Cookie Policy. Aggregated or anonymised reports may be retained longer.

Cookie and consent records

For as long as reasonably necessary to remember and demonstrate the relevant choice, subject to the Cookie Policy and periodic renewal requirements.

Complaint, dispute and legal-claim records

For the duration of the matter and normally up to 6 years after final resolution, or longer where litigation, enforcement or law requires.

Public blockchain information

The underlying blockchain record may remain public indefinitely and is outside Halow Capital’s control. Our internal transaction records are retained under the payment and accounting periods above.

Backups

Deleted or overwritten according to the relevant provider’s backup cycle, unless preserved for security, disaster recovery or legal reasons.

10.1 Longer or shorter periods

A record may be kept for a longer period where required by law, tax, a regulator, litigation hold, fraud investigation, security incident, chargeback or unresolved dispute. We may use a shorter period where the information is no longer necessary or the privacy impact outweighs the need to retain it.

10.2 Anonymised information

We may retain genuinely anonymised or aggregated information that no longer identifies an individual. This Policy does not apply to information that cannot reasonably be linked to an identifiable person.

11. Security

11.1 Measures

We use reasonable technical and organisational measures designed to protect personal information, including access controls, authentication, secure provider accounts, limited permissions, encryption made available by our providers, software updates, backups, transaction verification and staff or contractor confidentiality controls where applicable.

11.2 No absolute security

No internet, email, messaging, cloud, payment or blockchain system is completely secure. We cannot guarantee that unauthorised access, loss, misuse or technical failure will never occur.

11.3 Your responsibilities

You should:

a. verify that emails and payment instructions genuinely come from Halow Capital;b. keep email, Telegram, device, broker, VPS, wallet and exchange accounts secure;c. use strong unique passwords and multi-factor authentication where available;d. remove unnecessary personal or financial information from screenshots and logs;e. never send private keys, seed phrases, wallet recovery details or broker withdrawal passwords; andf. notify us promptly if you suspect impersonation, unauthorised access or misuse of your information.

11.4 Personal-information breaches

We assess suspected personal-information breaches and take appropriate steps. Where the law requires, we will notify the Information Commissioner’s Office and affected individuals within the applicable timescales.

12. Marketing and Service Communications

12.1 Optional marketing

We send optional marketing emails or updates only where we have an appropriate lawful basis. Our current Website process asks for separate consent. Marketing consent is not a condition of purchasing BASE or using support.

12.2 Withdrawal and opt-out

You can withdraw marketing consent or unsubscribe at any time through the unsubscribe method in the message or by emailing halow@halowcapital.com. We may retain a minimal suppression record to ensure that your preference continues to be respected.

12.3 Necessary communications

An opt-out from marketing does not prevent us from sending necessary non-marketing communications about an enquiry, Order, payment, licence, activation, update, security matter, support request, complaint, legal notice or change that affects an existing contract.

12.4 Developer marketing

An independent Developer is responsible for establishing its own lawful basis before sending its own marketing. A requested introduction does not automatically authorise unrelated or indefinite marketing by the Developer.

13. Cookies, Analytics and Similar Technologies

13.1 Cookie Policy

The Cookie Policy explains the cookies, local storage, consent records, Base44 technologies, Google Analytics and similar storage or access technologies used on the Website.

13.2 Essential technologies

Strictly necessary technologies may be used without optional consent where they are required for security, form submission, consent management, network operation or another essential Website function.

13.3 Non-essential analytics

Where consent is required, non-essential analytics storage is activated only after the relevant consent choice. You may reject or withdraw analytics consent through the Website’s cookie settings. The technical configuration must be read together with the Cookie Policy because Google Consent Mode can behave differently depending on whether basic or advanced implementation is used.

13.4 Browser and provider controls

You may also control cookies through your browser and use provider opt-out tools. Blocking essential technologies may prevent forms, preferences or other Website functions from working correctly.

14. Your Data Protection Rights

14.1 Rights

Subject to applicable law and any relevant exemption, you may have the right to:

a. be informed about how your personal information is used;b. request access to your personal information;c. request correction of inaccurate or incomplete information;d. request erasure of information in certain circumstances;e. request restriction of processing in certain circumstances;f. object to processing based on legitimate interests;g. object at any time to direct marketing;h. request transfer of information that you provided where the right to portability applies;i. withdraw consent at any time where processing relies on consent; andj. complain to the Information Commissioner’s Office or another competent supervisory authority.

14.2 Exercising rights

Send requests to halow@halowcapital.com. Please identify yourself and explain the information or processing concerned. We may request proportionate information to verify identity and prevent disclosure to an unauthorised person.

14.3 Response times and fees

We normally respond within the period required by applicable law. In the United Kingdom this is generally one month, although the period may be extended where legally permitted for a complex or numerous request. We do not ordinarily charge a fee, but the law may permit a reasonable fee or refusal where a request is manifestly unfounded or excessive.

14.4 Rights are not absolute

Some rights are subject to exemptions and depend on the lawful basis and circumstances. We may retain information where necessary for legal obligations, payment and tax records, licence administration, fraud prevention or legal claims. We cannot erase or alter a record independently stored on a public blockchain.

14.5 Automated decision-making

Halow Capital does not currently make decisions about Customers based solely on automated processing that produce legal or similarly significant effects. We may use automated technical tools for security, analytics, spam filtering or fraud indicators, but material decisions are reviewed where appropriate.

15. Complaints

15.1 Contact us first

Privacy questions or complaints should be sent to halow@halowcapital.com. We will use reasonable efforts to investigate and respond.

15.2 Information Commissioner’s Office

You may complain to the Information Commissioner’s Office (“ICO”), the United Kingdom’s data-protection regulator. Information is available at ico.org.uk. You may also have the right to complain to a regulator in another country where applicable.

15.3 No effect on other rights

A privacy complaint does not remove any contractual, consumer or legal right available to you under the Terms & Conditions or applicable law.

16. Third-Party Websites and Platforms

The Website may link to Myfxbook, FX Blue, MetaTrader, brokers, Developers, Telegram, social platforms or other third-party websites and services. Halow Capital does not control their independent processing. Review the relevant privacy notice before submitting information or connecting an account.

A link, integration or introduction does not mean that Halow Capital accepts responsibility for the third party’s privacy, security or legal compliance, except to the extent that Halow Capital is legally responsible for its own selection, disclosure or conduct.

17. Changes to This Policy

We may update this Policy to reflect changes in law, official guidance, Website technology, providers, payment methods, Developer relationships, products or business operations. The updated version will be published with a revised “Last Updated” date.

Where a change materially affects how we use information already collected, we will take reasonable steps to bring the change to the attention of affected individuals before the new use begins where required by law. A Privacy Policy is not consent, and continued browsing does not replace consent where the law requires a positive choice.

18. Contact Details

SA Futures Limited, trading as Halow CapitalCompany number: 14219285Registered office: Martlet House E1 Yeoman Gate, Yeoman Way, Worthing, West Sussex, United Kingdom, BN13 3QZPrivacy email: halow@halowcapital.comTelegram: @HalowhqWebsite: www.halowcapital.com

For privacy and security, email is the preferred channel for formal data-protection requests. Do not send private keys, seed phrases, wallet recovery information, broker passwords or other unnecessary security credentials.

© 2026 SA Futures Limited, trading as Halow Capital. All rights reserved.