Privacy Policy

1. Who We Are

River Valley Capital is the trading name under which Xaura Evaluation Limited (company no. 17020979, registered in England and Wales) provides its evaluation programmes, trading education and related services. Xaura Evaluation Limited is the company you contract with for those services.

River Valley Capital Ltd (company no. 17020034) is a separate company under common ownership with Xaura Evaluation Limited. It is not responsible for the funded programme. However, under common ownership, it may access and process trader data for the purpose of inviting traders to its proprietary trading desk, acting as a controller for that purpose and under its own responsibilities.

Where relevant, these entities are together referred to as the River Valley Capital Group of Companies.

Registered Business Address: Apartment 84, Berkeley Tower 48 Westferry Circus London E14 8RP United Kingdom

Website: https://rivervalleycapital.co.uk/

Privacy Contact: support@rivervalleycapital.co.uk

River Valley Capital's trading services also involve Prop Account LLC, the entity with which traders enter into the applicable trading agreements.

The River Valley Capital Group of Companies and the Prop Account Group of Companies act as data controllers in relation to their respective services and processing activities.

2. Scope of This Privacy Policy

This Privacy Policy applies to personal information processed in connection with:

• The River Valley Capital website.
• Trading programme enquiries and participation.
• Account registration and administration.
• Customer support.
• Identity verification.
• Programme purchases and payments.
• Payout requests.
• Trading account and programme administration.

Certain account and trading services are provided through systems operated by Prop Account LLC and the Prop Account Group of Companies.

Where personal information is processed through those services, the privacy terms of the relevant Prop Account entity may also apply.

3. Personal Information We May Process

The personal information processed depends on the services you use and how you interact with River Valley Capital.

This may include:

Personal and Contact Information

• Name.
• Email address.
• Contact information.
• Address information.
• Information provided when contacting support.

Account Information

• Account registration details.
• Account identifiers.
• Selected trading programme.
• Account status.
• Account-related communications.

Trading Programme Information

Information associated with participation in a trading programme may include:

• Trading account activity.
• Programme progress.
• Trading performance.
• Compliance with applicable trading rules.
• Account breach or review information.

Identity Verification Information

Identity verification may require personal information necessary to complete Know Your Customer (KYC) checks.

Identity verification services associated with River Valley Capital are provided through the Sumsub Group of Companies.

The information required depends on the applicable verification process.

Payment and Transaction Information

Information associated with purchases and payouts may include:

• Purchase information.
• Transaction references.
• Payment status.
• Payout instructions.
• Information required to process or verify a transaction.

Payment and payout services associated with River Valley Capital include Rise and Columis.

Technical Information

When you access online services, technical information may be processed in connection with website functionality, security, and operation.

This may include information such as:

• IP addresses.
• Browser information.
• Device information.
• Activity associated with the relevant website or platform.

4. How We Collect Personal Information

Personal information may be provided directly when you:

• Contact River Valley Capital.
• Register for a trading programme.
• Purchase a programme.
• Use an account or trading platform.
• Complete identity verification.
• Submit a payout request.
• Communicate with customer support.

Information may also be generated through account activity or received from organisations involved in providing the relevant service.

5. How Personal Information Is Used

Personal information may be processed for purposes connected with operating and administering River Valley Capital's services.

These purposes may include:

• Responding to customer enquiries.
• Managing account registration and administration.
• Administering trading programmes.
• Reviewing compliance with trading rules.
• Processing programme purchases.
• Administering payout requests.
• Completing identity verification.
• Providing customer support.
• Maintaining service and account security.
• Detecting or investigating suspected misuse or fraud.
• Maintaining appropriate business and transaction records.
• Complying with applicable legal obligations.
• Establishing, exercising, or defending legal rights.
• Inviting eligible traders to the proprietary trading desk operated by River Valley Capital Ltd.

Personal information will not be used for purposes that are incompatible with the reason it was collected unless permitted or required by applicable law.

6. Legal Basis for Processing

Where UK data protection law applies, personal information is processed using an appropriate lawful basis.

Depending on the relevant activity, this may include:

Contractual Necessity

Processing may be necessary to provide a requested service, administer an account, process a transaction, or perform an applicable agreement.

Legal Obligations

Personal information may be processed where necessary to comply with applicable legal requirements.

Legitimate Interests

Information may be processed where reasonably necessary for legitimate operational purposes, including:

• Providing customer support.
• Protecting services and accounts.
• Preventing fraud and misuse.
• Maintaining business records.
• Investigating potential breaches of trading or account conditions.

These interests are considered alongside the rights and interests of the individuals concerned.

Consent

Where applicable law requires consent for a particular activity, processing will be based on the consent provided.

Consent may be withdrawn where applicable.

7. Trading Accounts and Prop Account

River Valley Capital's trading services involve Prop Account LLC.

Traders enter into their applicable trading agreements with Prop Account LLC.

Personal information required for account registration, trading programme administration, trading account activity, and related services may therefore be processed by Prop Account LLC or other relevant entities within the Prop Account Group of Companies.

Where Prop Account processes personal information through its own systems and services, its applicable privacy documentation may also apply.

8. Identity Verification and KYC

River Valley Capital uses services provided by the Sumsub Group of Companies in connection with identity verification.

Where verification is required, information necessary to complete the applicable KYC process may be collected or processed.

The information required depends on the verification procedure applicable to the account or service.

Successful completion of applicable identity verification requirements may be necessary before certain payouts can be approved.

Sumsub may process personal information in accordance with its own role and privacy obligations.

9. Payments and Payouts

River Valley Capital's payment and payout arrangements include services provided by Rise and Columis.

Information necessary to process a purchase or payout may be shared with the provider responsible for the relevant transaction.

The information processed depends on the payment method and transaction involved.

Payment service providers may process personal information in accordance with their own legal obligations and privacy policies.

River Valley Capital does not require users to send complete payment card details through customer support communications.

10. Sharing Personal Information

Personal information may be shared where reasonably necessary to provide, administer, secure, or support the relevant services.

Recipients may include:

• Xaura Evaluation Limited.
• River Valley Capital Ltd.
• Prop Account LLC and relevant Prop Account Group entities.
• Sumsub Group of Companies.
• Rise.
• Columis.
• Relevant technology and service providers.
• Professional advisers where necessary.
• Government bodies, regulators, courts, or other competent authorities where disclosure is required by law.

Information should only be shared where there is an appropriate purpose and legal basis for doing so.

11. Cookies and Website Technologies

The River Valley Capital website and associated third-party platforms may use cookies or similar technologies required for website functionality, security, user preferences, or service operation.

Additional technologies may be used by external platforms or service providers according to their own services and privacy practices.

Where applicable law requires consent for non-essential technologies, the relevant consent requirements apply.

Users can also manage certain cookies through their browser settings.

12. Data Security

River Valley Capital takes reasonable measures to protect personal information against:

• Unauthorised access.
• Loss.
• Misuse.
• Alteration.
• Unauthorised disclosure.

Access to personal information should be limited to individuals and service providers that require the information for legitimate operational purposes.

However, no internet-based service, electronic communication method, or data storage system can be guaranteed to be completely secure.

13. Data Retention

Personal information is retained only for as long as reasonably necessary for the purposes for which it is processed and in accordance with applicable legal, contractual, operational, and recordkeeping requirements.

The appropriate retention period may depend on factors including:

• The duration of an account or service relationship.
• Payment and transaction record requirements.
• Identity verification requirements.
• Customer support enquiries.
• Account or trading-related disputes.
• Fraud or security investigations.
• Applicable legal requirements.
• The establishment, exercise, or defence of legal claims.

Where information is processed by an external provider, that provider may also retain information according to its applicable obligations and privacy practices.

14. International Processing

River Valley Capital's services involve companies and service providers that may operate in different countries.

Personal information may therefore be processed, accessed, or transferred across jurisdictions where necessary to provide the relevant services.

Where applicable data protection law requires safeguards for international transfers, the organisation responsible for the relevant processing must use the protections required by applicable law.

15. Your Data Protection Rights

Depending on the applicable data protection law and the circumstances of the processing, you may have rights concerning your personal information.

These may include the right to:

• Request access to your personal information.
• Request correction of inaccurate information.
• Request deletion where legally applicable.
• Request restriction of certain processing.
• Object to processing in applicable circumstances.
• Request data portability where the applicable requirements are satisfied.
• Withdraw consent where processing is based on consent.

These rights may be subject to legal limitations or exceptions.

To submit a privacy-related request concerning River Valley Capital, contact:

support@rivervalleycapital.co.uk

The relevant organisation may request information necessary to verify your identity before responding to a request involving personal information.

16. Marketing Communications

Where River Valley Capital sends optional marketing communications, applicable consent and direct marketing requirements will be followed.

You may object to the use of your personal information for direct marketing at any time.

Service-related communications concerning an account, transaction, programme, verification requirement, or payout are separate from optional marketing communications.

17. Privacy Complaints

If you have concerns about how your personal information is handled, please contact:

support@rivervalleycapital.co.uk

Where UK data protection law applies, you may also have the right to lodge a complaint with the Information Commissioner's Office (ICO).

ICO Website: https://ico.org.uk/

Individuals located in other jurisdictions may also have rights to contact the relevant data protection authority.

18. Age Requirements

River Valley Capital's trading programmes are intended for individuals who are at least 18 years old, or who meet a higher applicable minimum legal age in their jurisdiction.

Individuals who do not meet the applicable age requirement are not eligible to participate in the trading programmes.

19. Third-Party Services

River Valley Capital's website and trading services may include links to or integrations with third-party platforms.

Third-party organisations may process personal information under their own privacy policies and legal responsibilities.

Users should review the applicable privacy information provided by any external service they use.

20. Changes to This Privacy Policy

River Valley Capital may update this Privacy Policy where necessary to reflect changes in:

• Services.
• Business operations.
• Service providers.
• Data processing activities.
• Applicable legal requirements.

The latest version will be published on this page.

Where required by applicable law, material changes affecting personal information will be communicated appropriately.

21. Contact Us

For questions regarding this Privacy Policy or the handling of personal information, please contact:

River Valley Capital Group of Companies

Xaura Evaluation Limited doing business as River Valley Capital

River Valley Capital Ltd

Business Address: Apartment 84, Berkeley Tower 48 Westferry Circus London E14 8RP United Kingdom

Email: support@rivervalleycapital.co.uk

Website: https://rivervalleycapital.co.uk/

Contact Page: https://rivervalleycapital.co.uk/contact-us