Last Updated: 1 December 2025

This privacy notice for Two Funded Limited ("we", "us" or "our") explains how and why we collect, store, use and/or share your information when you use our services. These services include visiting our website, taking part in evaluation programmes for funded trading accounts and other related activities.

If you have any questions or concerns, please contact us at info@twofunded.com or by post at Two Funded Limited, Unit 2A, 17/F, Glenealy Tower, No. 1 Glenealy, Central, Hong Kong.

Summary of Key Points

• What personal information do we collect? We collect information you provide to us (such as your name, email address, billing address and payment details) when you register for an account or purchase an evaluation; we also automatically collect certain technical data like IP address and device information when you use our services.

• Do we process sensitive personal information? No, we do not intentionally process sensitive personal data.

• Do we receive information from third parties? We may receive limited data from public databases, marketing partners and social media platforms.

• How do we use your information? We process your data to provide, improve and administer our services, communicate with you, safeguard our platform and comply with legal obligations.

• What are your rights? Depending on your location, you may have rights to access, rectify or delete your personal data and to withdraw consent or object to certain processing.

1. What information do we collect?

1.1 Personal information you disclose to us

We collect personal information that you voluntarily provide when you register on our platform, sign up to the waiting list or purchase a funded account evaluation. The type of information depends on how you interact with us, but may include:

• Contact information (name, email address, phone number);

• Credentials (usernames and passwords) for account creation;

• Billing information such as billing address and payment card details; these details are required to process evaluation fees;

• Any other information you choose to provide, such as preferences or enquiries.

All personal information you provide must be true, complete and accurate, and you should notify us of any changes.

1.2 Information automatically collected

Certain information is collected automatically when you visit, use or navigate our services. This data does not reveal your specific identity but may include device and usage information such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name and information about how and when you use our services. We collect this data primarily to maintain the security and operation of our platform and for internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can learn more in our Cookie Notice.

1.3 Information collected from other sources

To enhance our ability to provide relevant marketing and offers and to update our records, we may obtain information about you from public databases, marketing partners, social media platforms and other external sources. If you interact with us on a social network using your account (e.g. Facebook or X/Twitter), we will receive personal information from the social media provider such as your name and email address. The data we receive depends on your privacy settings with the provider.

2. How do we process your information?

We process your personal information for various reasons depending on how you interact with our services:

• Account creation and authentication: To set up, log in and maintain your user account.

• Service delivery: To provide and administer evaluation accounts and related services, including customer support.

• Administrative communications: To send you important information about our products and services, changes to our terms and policies and other notices.

• Fulfilment and order management: To process payments, manage returns or exchanges and issue invoices.

• User‑to‑user communications: To enable communications between users where applicable.

• Security and fraud prevention: To protect our services, investigate suspicious activity and prevent fraud.

• Vital interests: To save or protect an individual’s vital interest such as preventing harm.

3. What legal bases do we rely on?

We rely on the following legal bases to process your personal data, as required by the General Data Protection Regulation (GDPR) and similar laws:

• Consent: We may process your information if you have given us permission for a specific purpose. You can withdraw your consent at any time.

• Contractual necessity: We process your information when necessary to perform our contractual obligations to you or to take steps at your request before entering into a contract.

• Legitimate interests: We process your data when it is reasonably necessary to achieve our legitimate business interests and those interests do not override your fundamental rights and freedoms, for example to diagnose problems or prevent fraud.

• Legal obligations: We may process your information to comply with legal obligations such as cooperating with law enforcement, defending legal claims or retaining tax records.

• Vital interests: We may process your information to protect your vital interests or those of another person.

4. When and with whom do we share personal information?

We only share information in specific circumstances:

• Service providers: We engage third‑party vendors (e.g. payment processors or IT providers) to perform services on our behalf. These vendors are authorised to use your personal information only as necessary to provide these services.

• Business transfers: We may share or transfer your information in connection with, or during negotiations of, a merger, sale of company assets, financing or acquisition of all or a portion of our business.

• Affiliates: We may share information with our affiliates, in which case we will require them to honour this privacy notice.

• Legal requirements: We may disclose information if required by law or to respond to valid requests by public authorities.

We do not sell your personal information.

5. Do we use cookies and other tracking technologies?

Yes. We use cookies and similar technologies (such as web beacons and pixels) to collect or store information[31]. Our Cookie Notice provides details about the types of cookies we use, their purposes and how you can control your cookie preferences.

6. How do we handle your social logins?

If you choose to register or log into our services using a social media account, we receive certain profile information from your social media provider. This may include your name, email address, friends list and profile picture. We use this information only for the purposes described in this notice. We recommend you review your social media provider’s privacy policy to understand how they handle your data.

7. How long do we keep your information?

We retain your personal information only for as long as necessary to fulfil the purposes described in this privacy notice unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your information, we will either delete or anonymise it, or, if deletion is not possible (e.g. because backup archives are involved), securely store and isolate your information until deletion is possible.

8. How do we keep your information safe?

We have implemented appropriate technical and organisational security measures designed to protect your personal information. However, no electronic transmission or storage can be guaranteed to be 100 % secure, so we cannot promise or guarantee that hackers or other unauthorised third parties will not be able to defeat our security and improperly collect, access or modify your information. You should access our services only within a secure environment.

9. What are your privacy rights?

Depending on where you are located, you may have the following rights:

• Access: Request a copy of the personal information we hold about you.

• Rectification: Ask us to correct or update your information if it is inaccurate or incomplete.

• Erasure: Request deletion of your personal data in certain circumstances (the right to be forgotten).

• Restriction: Ask us to restrict the processing of your information.

• Portability: Request to receive your data in a structured, commonly used format and transfer it to another controller.

• Object: Object to our processing of your personal data for reasons relating to your particular situation.

• Withdraw consent: If we rely on your consent, you may withdraw it at any time; this will not affect the lawfulness of processing before the withdrawal.

• Lodge a complaint: If you believe we are unlawfully processing your personal data, you have the right to complain to a data protection authority.

To exercise any of these rights, please contact us at info@twofunded.com. We will respond to your request in accordance with applicable data protection laws.

9.1 Controls for “Do‑Not‑Track” features

Most browsers and some mobile operating systems include a Do‑Not‑Track (DNT) feature that signals your preference not to be tracked online. No uniform standard has been finalised, and therefore we do not currently respond to DNT browser signals. If a standard is adopted in the future, we will revise this notice.

9.2 Region‑specific rights

Residents of certain jurisdictions (such as the United States, Australia, New Zealand or South Africa) may have additional rights under local laws. We comply with all applicable regional privacy laws and will provide you with information relevant to your jurisdiction upon request.

10. Do we make updates to this notice?

Yes. We may update this privacy notice from time to time to remain compliant with relevant laws. The updated version will be indicated by an updated “Last Updated” date and will be effective as soon as it is accessible. If we make material changes, we may notify you by posting a prominent notice on our site or by sending you an email.

11. How can you contact us about this notice?

If you have questions or comments about this notice, you may contact us by email at info@twofunded.com or by post at:

Two Funded Limited
Unit 2A, 17/F, Glenealy Tower
No. 1 Glenealy
Central, Hong Kong

You also have the right to request review, update or deletion of the personal data we collect from you.