PRIVACY POLICY

Effective Date: June 27, 2026

Data Controller: Empire Funding Limited, Hong Kong SAR ("Empire Funding," "we," "us"). Contact: admin@empirefundingprop.com

1. Introduction and Scope

This Privacy Policy explains how Empire Funding collects, uses, discloses, and protects personal data when you visit empirefundingprop.com or use our Challenge, Instant Funding, or related services (the "Services").

2. Personal Data We Collect

• Identifiers: name, email address, and (for payout verification) government-issued ID and proof of address.
• Account data: account credentials, Challenge/Funded Account configuration, trading activity and performance data generated on the TradeLocker platform.
• Payment data: transaction records; card details are processed directly by our payment processor and are not stored by us. Cryptocurrency payout addresses are retained for payout processing.
• Communications: support ticket content, waitlist signups, and any messages you send us.
• Technical data: IP address, browser/device information, and cookie identifiers collected automatically via the Site.

3. Sources of Data

We collect data directly from you (registration, checkout, support requests), automatically through the Site (analytics and cookies), and from the TradeLocker platform in connection with your Trading Account activity.

4. Purposes and Legal Basis for Processing

• Providing Challenge/Funded Account services and processing payouts — performance of a contract.
• Fraud prevention, rule-breach detection, and security — legitimate interest.
• Website analytics (Google Analytics) — legitimate interest or consent, depending on your cookie settings.
• Marketing emails — consent, which you may withdraw at any time.
• KYC/AML recordkeeping for payouts — legal obligation and legitimate interest in preventing financial crime.

5. Cookies and Tracking

We use cookies and similar technologies, including Google Analytics (GA4) for site analytics and hCaptcha for bot prevention on forms. Non-essential cookies are only set with your consent via our cookie banner. You can manage cookie preferences through that banner or your browser settings.

6. Third-Party Service Providers

We share personal data with the following categories of service providers solely to provide the Services:

• Analytics providers — to understand site usage and improve the Services.
• Hosting and database infrastructure providers — to store and process account and Services data.
• Bot and fraud prevention providers — to protect forms and accounts from abuse.
• Payment processors — to process Challenge/Instant Funding purchases.
• Cryptocurrency payout processors — to disburse Profit Split payments.
• The trading platform provider (TradeLocker) — which independently processes Trading Account activity data.
• Email, CRM, and support tools — to manage waitlist signups, support tickets, and communications.

These providers are contractually restricted to using data only as necessary to provide their services to us. The specific providers we use may change from time to time as our operations evolve.

7. International Data Transfers

Empire Funding is based in Hong Kong, which does not have an EU adequacy decision. Where personal data of EU or UK residents is transferred to Hong Kong, or onward to service providers based outside the EU/UK, we rely on Standard Contractual Clauses (or, for UK transfers, the UK International Data Transfer Addendum) as the transfer mechanism, and we have considered the circumstances of each transfer accordingly.

8. Data Retention

We retain account and transaction data for as long as needed to provide the Services and for a reasonable period afterward to meet legal, accounting, and dispute-resolution needs. KYC and payout-related records are retained for at least 5 years, consistent with standard anti-money-laundering recordkeeping practice. Waitlist and support data is retained until no longer needed for its original purpose or until you request deletion.

9. Your Privacy Rights

If you are in the EU or UK (GDPR), you have the right to access, correct, delete, restrict, or port your personal data, to object to certain processing, and to withdraw consent at any time. You may also lodge a complaint with your local data protection supervisory authority.

If you are a California resident (CCPA/CPRA), you have the right to know what personal information we collect, to request deletion or correction, to opt out of the sale or sharing of personal information, to limit use of sensitive personal information, and to not be discriminated against for exercising these rights. We do not sell personal information for monetary consideration. To the extent our use of analytics tools constitutes "sharing" under CPRA, you may opt out via our cookie settings or by submitting a request to admin@empirefundingprop.com. We honor Global Privacy Control browser signals.

To exercise any of these rights, contact admin@empirefundingprop.com. We may need to verify your identity before fulfilling a request.

10. Security

We use reasonable technical and organizational measures, including encryption in transit and access controls, to protect personal data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Children's Privacy

The Services are not directed to, and may not be used by, anyone under 18 years of age. We do not knowingly collect personal data from minors.

12. Affiliate Program Data

If you are referred to Empire Funding by an affiliate, limited data (such as the fact of a referral and resulting purchases) may be shared with the referring affiliate solely for commission tracking purposes.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by an updated effective date at the top of this page.

14. Contact

Questions or requests regarding this Privacy Policy can be sent to admin@empirefundingprop.com.