ELT — European Loan Trading Privacy Policy & Data Protection Notice Last updated: 1 March 2025
1. Who We Are
European Loan Trading, incorporated as Secondary Loan Trading - FZCO in Dubai, United Arab Emirates. We operate the ELT Client Portal ("the App"), a secure platform for European leveraged loan trading, market intelligence, and client communication. For data protection purposes, ELT acts as the Data Controller.
Registered Office: IFZA Business Park, DDP, PO Box 342001, Dubai, United Arab Emirates Data Protection Contact: enquiries@europeanloantrading.com
2. Data We Collect
We collect and process the following personal data:
Account Information: Full name, work email, username, password (encrypted), financial institution name, work address, work telephone, mobile/WhatsApp number.
Trading Activity: Buy/sell enquiries, indicative bids and offers, watchlist selections, market listing interactions.
Communications: All messages sent and received via the App's messaging system are recorded and retained for regulatory compliance and audit purposes.
Technical Data: Device information, login timestamps, IP addresses, and app usage analytics.
Meeting Data: Scheduled meeting details, calendar entries, and venue information.
3. Why We Process Your Data
We process personal data on the following legal bases:
Contractual Necessity: To provide you with access to the ELT Client Portal, facilitate loan trading enquiries, and deliver market intelligence services.
Legitimate Interest: To maintain platform security, prevent fraud, improve our services, and facilitate business communications between counterparties.
Legal Obligation: To comply with applicable financial services regulations, anti-money laundering (AML) requirements, and record-keeping obligations.
Consent: Where required, we obtain your explicit consent before processing your data, which you may withdraw at any time by contacting us.
4. Data Storage & Security
Your data is stored securely using Google Firebase infrastructure, hosted in the europe-west2 (London, UK) data centre. All data is encrypted in transit (TLS 1.2+) and at rest (AES-256). Firebase Authentication handles credential management with industry-standard security protocols. Access to personal data is restricted to authorised ELT personnel only.
5. Data Sharing & Transfers
We do not sell your personal data to third parties. Data may be shared with:
Google LLC (Firebase): As our data processor for hosting, authentication, and database services, governed by Google's Data Processing Terms.
Other ELT Users: Your name, institution, and trading activity are visible to authorised ELT administrators to facilitate trading. Your contact details are shared with ELT team members for legitimate business communication.
Regulatory Authorities: Where required by law or regulation in the UAE, UK, EU, or other applicable jurisdictions.
International Transfers: As a UAE-incorporated entity serving international clients, your data may be transferred between the UAE, UK, and EU. We ensure all transfers comply with applicable data protection laws, including UAE PDPL, UK GDPR, and EU GDPR where applicable. Google Firebase's London data centre serves as the primary data storage location.
6. UAE Personal Data Protection Law (PDPL)
ELT complies with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL) and its implementing regulations. We process personal data lawfully, fairly, and transparently, collect data only for specified and legitimate purposes, and implement appropriate technical and organisational safeguards. Cross-border data transfers are conducted in accordance with Article 22 of the UAE PDPL.
7. UK & EU GDPR Compliance
For clients based in the UK or European Economic Area (EEA), we comply with the UK GDPR (Data Protection Act 2018) and EU General Data Protection Regulation (Regulation 2016/679). Under these regulations, you have the right to:
Access — Request a copy of all personal data we hold about you. Rectification — Request correction of inaccurate or incomplete data. Erasure — Request deletion of your data ("right to be forgotten"), subject to legal retention obligations. Restriction — Request restriction of processing in certain circumstances. Portability — Request your data in a structured, machine-readable format. Objection — Object to processing based on legitimate interest. Withdraw Consent — Where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.
8. Message Retention & Compliance
All messages exchanged through the ELT Client Portal are recorded, stored, and retained in compliance with financial services regulatory requirements. This includes direct messages between users and group communications. Messages are retained for a minimum of seven (7) years from the date of creation, in line with industry standards for financial communication record-keeping. Users are notified of this policy within the messaging interface.
9. Data Retention
Account data is retained for the duration of your active relationship with ELT and for a period of seven (7) years thereafter to satisfy regulatory and legal requirements. Trading activity records are retained for a minimum of seven (7) years. You may request account deletion at any time; however, certain records may be retained as required by law.
10. Cookies & Analytics
The App uses Firebase Analytics and local session storage for authentication persistence. No third-party advertising cookies or tracking pixels are used. We do not share analytics data with advertisers.
11. Children's Privacy
The ELT Client Portal is a professional financial services platform. We do not knowingly collect or process data from individuals under the age of 18. If we become aware that a minor has provided personal data, we will take steps to delete such information.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. Material changes will be communicated via the App. Continued use of the platform after notification constitutes acceptance of the revised policy.
13. Contact & Complaints
To exercise your data rights, make a complaint, or ask questions about this policy:
Email: enquiries@europeanloantrading.com Post: Secondary Loan Trading - FZCO, IFZA Business Park, DDP, PO Box 342001, Dubai, UAE
If you are based in the UK and are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk. If you are based in the EU, you may contact your local Data Protection Authority.
By creating an account, you confirm that:
You have read and understood this Privacy Policy & Data Protection Notice.
You consent to ELT collecting, processing, and storing your personal data as described above.
You understand that all communications via the App are recorded for compliance purposes.
You acknowledge that your data may be shared with authorised ELT personnel and, where required, regulatory authorities.