We at London City Trading (LCT, us) value your privacy and are committed to protecting your personal data. This Privacy Policy outlines how we collect, use, and safeguard your information when visiting our websites, and and our software applications.

If you have any questions regarding this Privacy Policy, please do not hesitate to contact us via email at You may also find the General Data Protection Regulation ((EU) 2016/679) (GDPR) online for further reference.
In the event of any issues, we ask that you first reach out to us; however, you have the right to file a complaint with the Information Commissioner’s Office (ICO), the UK's data protection authority (

Our contact information is available below, and if you require additional assistance, simply email us.

Thank you for taking the time to review our Privacy Policy.
We abide by the principles of data protection law and ensure that your data is:

Handled in a lawful, fair, and transparent manner.
Collected for clearly defined and legitimate purposes and not used in any manner inconsistent with those purposes.
Relevant and limited to the purposes for which it was collected.
Accurate and kept up-to-date.
Retained only as long as necessary for the intended purposes.
Stored securely.

This Privacy Policy will detail how we collect and process your data, including the information you provide and any updates we make. Please note that if you are under 18 years of age, we will not collect or process any of your data.

Per the data protection law, we become a data controller whenever you visit our website. This means that we are responsible for determining how we collect and utilise personal information about you.

Therefore, it's crucial that you are aware of our identity and details, which are outlined below:
Legal entity name: London City Trading, ℅ Engima Fintech Ltd.
Postal address: 124 Kemp House, City Rd, EC1V 2NX, London, UK.

We regularly review our Privacy Policy to ensure its accuracy and relevancy. You can inform us of any changes to your personal data during your relationship with us. Please contact us using the contact information provided above to update us promptly. Keeping us informed of any changes to your personal data is a responsibility on your part, and it helps us to serve you better. Thank you for your cooperation.

We gather personal information about you from the following sources:
Direct interactions: This refers to the information (including Identity, Contact, Financial, Marketing, and Communications Data) you voluntarily provide us with through forms on our website or other service sites, or through correspondence with us (e.g. email or chat). This includes information you provide when registering to use our sites, subscribing to any of our services, searching for a service, and reporting a problem with our services or sites. We keep a record of all correspondence if you contact us.

Automated technologies and interactions: As you interact with our sites, we may automatically collect technical data about your equipment, browsing patterns, and actions. We collect this personal data through the use of cookies, server logs, and other similar technologies.
Information from other sources: We may receive personal data about you from various third-party and public sources, including:

Technical Data: from analytics providers such as Google located outside the EU, advertising networks, and search information providers.
Contact, Financial, and Transaction Data: from providers of technical, payment, and delivery services.
Identity and Contact Data: from data brokers or aggregators, as well as from publicly available sources.

We may gather, utilize, store, and transfer various types of personal information about you. This includes, but is not limited to, the following categories of data:

Identity Data - First name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
Contact Data - Billing address, delivery address, email address, and telephone numbers.
Financial Data - Bank account and payment card details.
Transaction Data - Details of payments made by you, information about products and services purchased from us, and details related to any legal services we provide or plan to provide to you.
Technical Data - Internet protocol (IP) address, login information, browser type and version, time zone setting, location, browser plugin types and versions, operating system, platform, and other technology used on the devices you use to access our website.
Usage Data - Details of your use of our websites or services or your visits to any of our sites, including traffic and communication data, whether for billing purposes or otherwise, and the resources you access.
Profile Data - Your username and password, interests, preferences, feedback, and survey responses.
Marketing and Communications Data - Your preferences for receiving marketing from third parties and us and your communication preferences.

In this policy, "personal data" or "personal information" refers to any information that can identify an individual. It does not include data with the identity removed (anonymous data). We do not collect any special categories of personal data such as race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, trade union membership, health information, genetic, or biometric data. Furthermore, this website and our business are not intended for anyone under the age of 18, so if you are under 18, please log out. We also do not collect information about criminal convictions and offences.

Your consent allows us to share your personal information with our third-party service providers for the purposes outlined in this privacy policy.
These third parties, known as External Third Parties, are service providers located outside of our jurisdiction who provide IT and system administration services.
In the event that we decide to sell, transfer, or merge parts of our business or assets, your personal information may also be transferred to the new owners. Conversely, if we choose to acquire another business, your personal information may be used as described in this privacy policy.

We take the security of your personal information very seriously and require all third parties to handle it with the same care and respect. These third parties are not permitted to use your personal information for their own purposes and must only process it as instructed by us and for the specified purposes.

We will only use your personal data in accordance with applicable laws. The most common reasons for using your personal data are outlined below, but this is not an exhaustive list:
When you have provided your consent prior to the processing.

To fulfill the contract we are either about to enter into or have already entered into with you.
When it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not outweigh these interests.

When it is required to comply with a legal or regulatory obligation.

It's important to note that we do not typically rely on consent as a legal basis for processing your personal data, except in the case of sending third-party marketing communications to you via email or text message. However, you have the right to withdraw your consent for marketing at any time by contacting us.

To understand the reasons for using your personal data, please see the table below, which outlines our intended uses and the legal basis for each use, as well as our legitimate interests where applicable. It's possible for us to process your personal data for more than one lawful reason, and in such cases, we will consider the specific purpose for which we are using your data. If you need more information on the specific legal basis we are relying on for processing your personal data, please do not hesitate to contact us

To register you as a new customer
Type of data:
Lawful basis for processing:
Your consent.

To process and deliver your order, including managing payments, collecting money owed to us and delivering our software application services to you.
Type of data:
Financial Transaction;
Marketing and Communications.
Lawful basis for processing:
Your consent;
Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you including notifying you of changes to any services.
Type of data:
Marketing and Communications.
Lawful basis for processing:
Your consent;
Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services);
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To administer and protect our business and our Sites and the services including troubleshooting, data analysis and system testing.
Type of data:
Lawful basis for processing:
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data:
Lawful basis for processing:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

If we are legally required or contractually obligated to collect your personal data and you do not provide it when requested, it may impact our ability to fulfill the contract we have with you or are trying to enter into. In such cases, we may be forced to cancel a product or service, but we will promptly inform you if this occurs. To ensure that your contracts are carried out smoothly, it is important to provide us with the necessary information and to keep us informed of any changes.

We may use your Identity, Contact, Technical, Usage, and Profile Data to understand your preferences and offer you products, services, and promotions that may be of interest to you. This is known as marketing. Unless you opt out of receiving marketing communications from us (which is easy and can be done by following the opt-out instructions), we will send you marketing messages if you have previously requested information from us or purchased our services and have not opted out of such communications. Note that we respect your privacy and will not overwhelm you with excessive marketing efforts.

We prioritize your privacy and will not share your personal information with any third parties for marketing purposes. Rest assured that your personal data will be kept confidential with us.

You have the power to control the marketing communications you receive from us. Simply reach out to us at any time to request to opt out of receiving future marketing messages

It's a personal preference, whether you like cookies or not. You have the option to control the use of cookies on your browser by choosing to either accept or reject them. However, please note that some features on our website may not be fully available if you decide to disable or block cookies.

We will only use your personal data for the specific reasons we collected it, unless there is a valid reason that is compatible with the original purpose. If you need more information on how the new purpose aligns with the original reason, feel free to reach out to us at If we need to use your personal data for a different purpose, we will inform you and provide a legal basis for the use. Note that in rare cases, we may process your personal data without your knowledge or consent in accordance with the rules and when legally required or permitted.

Your personal data may be transferred or stored in locations outside the European Economic Area (EEA) or the country where you and your authorized users are located, but such transfers may only be made to countries with an adequacy decision under GDPR Article 45, such as the United States of America. If you require further information about this, please let us know and we will be happy to provide additional details.

Your personal information is securely stored on our servers, but it's important for you to keep your password confidential. If you have been given, or have chosen, a password to access certain parts of our sites or platforms, it's your responsibility to keep it protected. We take security seriously and implement strict procedures and features to prevent unauthorized access, use, or loss of your personal data. In the event of a suspected data breach, we will take appropriate action, including notification to you and relevant authorities as required by law.
For legal and regulatory purposes, we may retain basic client information, including identity, contact, financial, and transaction data, for six years after our clients are no longer active. In some cases, we may anonymize your personal data for research or statistical purposes, in which case we may use it indefinitely without further notice to you.

You have the power to take control of your personal information under specific circumstances, as provided by law. This gives you the following rights:
The right to access your personal information by making a data subject access request. This allows you to receive a copy of the personal information we hold about you and verify its lawful processing.

The right to correct any incomplete or inaccurate information we hold about you.
The right to request the deletion of your personal information where there is no valid reason for us to continue processing it, or if you have exercised your right to object to processing.
The right to object to the processing of your personal information if we rely on a legitimate interest (or a third party's interest) and if your specific situation calls for it. You also have the right to object if we process your personal information for direct marketing purposes.
The right to request a restriction on the processing of your personal information, for example, if you want to verify its accuracy or understand the reason for its processing.
The right to request a transfer of your personal information to another party.
To review, verify, correct, or request the deletion of your personal information, object to its processing, or request a transfer of your personal information to another party, please contact the data privacy manager in writing. You may also call us to make arrangements.

There is no cost for you to access or exercise your rights regarding your personal information. However, if your request is found to be baseless, excessive, or repetitive, we may charge a fee or decline to comply with your request.

In order to protect your personal information and ensure that only you or those authorized have access, we may require additional information from you to confirm your identity. This is a precautionary measure to avoid accidental disclosure to unauthorized parties. To help us process your request efficiently, we may also reach out to you for additional information related to your request.

We aim to respond to all valid requests within one month's time. In rare cases, it may take us longer than a month to fulfill your request, especially if it is complex or if you have made multiple requests. If this is the case, we will keep you informed and updated on the progress