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Privacy Policy

Last updated: 18 October 2026

ALH TRADEAUTOMATIONFX LTD ("we", "us", or "our") operates the SmartBotScalper platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our service.

1. Data Controller

The data controller responsible for your personal data is:

ALH TRADEAUTOMATIONFX LTD
Lord Byron Street 61-63, 6th Floor, Flat / Office 602
6023 Larnaca
Cyprus

Registration number: HE 470513
Email: [email protected]

2. Data We Collect

Account Data

When you register, we collect your name, email address, and password (stored in hashed form). If you subscribe, payment information is processed through Mountain Wolf (MWPay).

MT5 Account Data

When you connect an MT5 account, we store your MT5 server, login ID, and encrypted credentials. We access your account through MetaApi to execute automated trading operations.

Trading Data

We collect and store data about trades executed through our automated trading service, including symbols, lot sizes, entry/exit prices, and profit/loss figures.

Usage Data

We automatically collect information about how you interact with our platform, including IP address, browser type, pages visited, and timestamps.

3. How We Use Your Data

  • To provide and maintain our automated trading service
  • To process your subscription payments
  • To send transactional emails (account verification, trade notifications)
  • To monitor and improve service performance
  • To comply with legal obligations
  • To detect and prevent fraud or abuse

4. Third-Party Services

We share data with the following third-party service providers:

  • MetaApi - MT5 account connection and trade execution. MetaApi processes your MT5 credentials and trading data. See MetaApi Privacy Policy.
  • Mountain Wolf (MWPay) - Payment processing. Mountain Wolf handles payment and billing information. See Mountain Wolf.
  • Resend - Transactional email delivery. See Resend Privacy Policy.
  • AVO Markets - partner broker. When you register with our partner broker AVO Markets Ltd (Saint Lucia), AVO Markets sends us a pseudonymised (hashed) form of your email address at that moment to check whether you are a SmartBot Scalping user. If you are, we tell AVO Markets only your own referral code, whether your SmartBot Scalping account is active, the referral code of the partner who referred you and how many users you have referred (as a number only, without any details about them), so that your referral relationship is kept and your referrer can be credited and paid a commission at AVO Markets. We do not share your name, your email address in plain text, trading data or payment data. AVO Markets processes this information as an independent controller under its own Privacy Policy. We do this on the basis of our legitimate interest in running our partner and referral programme; you can object at any time by contacting [email protected].

4a. Opening an account at AVO Markets

Controller. ALH TRADEAUTOMATIONFX LTD ("SmartBot", "we"), Lord Byron Street 61-63, 6th Floor, Flat / Office 602, 6023 Larnaca, Cyprus, [email protected].

Purpose. If you choose to open a trading account at our partner broker AVO Markets Ltd. (IBC No. 2026-00779, Saint Lucia) from our registration form, we transfer your registration data to AVO Markets so that AVO can open your account, and so that your AVO account is linked to the SmartBot user who referred you (your sponsor).

Data we transfer to AVO. First and last name, e-mail address, phone number, country of residence, date of birth, preferred language, your SmartBot user ID, your own referral code and your sponsor's referral code, your marketing choice, and a record of your acceptance of AVO's documents (document, version, time, IP address and browser). Your password is passed on once, encrypted in transit, so that AVO can set up your login; we do not keep it for AVO.

Data we receive back from AVO. Your AVO client ID, the status of your AVO account (registered, verification pending, verified or rejected – no identity documents or reasons), your AVO accounts and their balances, deposits, withdrawals and internal transfers, your Copy Trading positions, daily results and the profit share charged, and the referral commissions AVO has paid out on our instruction. We use this to show you your AVO status in SmartBot, to calculate and pay referral commissions in our partner programme, and to answer your requests.

Legal basis. The transfer to AVO is necessary to carry out your request to open an AVO account (Art. 6(1)(b) GDPR) and is based on your consent in the registration form (Art. 6(1)(a) GDPR). Receiving and using the data from AVO is based on your consent and on our legitimate interest in running our partner programme correctly (Art. 6(1)(f) GDPR).

Separate controller. AVO Markets processes your data as a separate controller under its own privacy policy: https://www.avomarkets.com/legal/privacy-policy. For your AVO account (including identity verification) please contact AVO Markets at [email protected].

Your rights. You can withdraw your consent at any time with effect for the future by writing to [email protected]; we will then stop receiving data from AVO and delete the AVO data we hold, except where we must keep it by law (e.g. records of commissions paid).

4b. Accounts prepared through AVO Markets

Who this concerns. People who opened an account at AVO Markets with the referral code of a SmartBot partner, or of a client of that partner, without registering at SmartBot themselves.

What we do. AVO Markets tells us about such clients so that our partner programme reflects the team correctly. We then prepare a SmartBot account for you in the team of the partner who referred you. This account cannot be used to log in, receives no e-mails or other messages from us, and is marked in the team views as "no SmartBot account yet". It lets the partners above you receive the referral commissions on your AVO activity that our partner programme provides for.

Data we receive from AVO. First and last name, e-mail address, phone number, country, preferred language, your AVO client ID, the time of your AVO registration, the referral code you used or the AVO client who referred you, the status of your AVO account, and the account and Copy Trading figures listed in section 4a. Partners see you in their team with your first name and the initial of your last name.

Activating the account. If you choose "Create my SmartBot account" in the AVO portal, AVO Markets passes your name, e-mail address, phone number and language to us, and we provide a one-time link, valid for 15 minutes, with which you set your password. From then on the account is a normal SmartBot account in the same place in your team, and this privacy policy applies to it in full.

Legal basis. Preparing the account and using the data from AVO is based on our legitimate interest, and that of the partners in your team, in running the partner programme correctly and completely (Art. 6(1)(f) GDPR). Activating it is based on your request in the AVO portal (Art. 6(1)(b) GDPR) and your consent there (Art. 6(1)(a) GDPR).

Your rights. You can object to the prepared account at any time or ask us to delete it by writing to [email protected]. We will then delete it, except for the records we must keep by law (e.g. of commissions already paid). Your AVO account is not affected; for it, please contact AVO Markets.

5. Data Retention

We retain your personal data for as long as your account is active or as needed to provide our services. Trade history data is retained for up to 2 years after account closure. We may retain certain information as required by law or for legitimate business purposes.

6. Your Rights (GDPR)

Under the General Data Protection Regulation, you have the right to:

  • Access - Request a copy of the personal data we hold about you
  • Rectification - Request correction of inaccurate personal data
  • Erasure - Request deletion of your personal data ("right to be forgotten")
  • Data Portability - Request your data in a structured, machine-readable format
  • Restriction - Request that we restrict processing of your data
  • Objection - Object to the processing of your personal data
  • Withdraw Consent - Withdraw consent at any time where processing is based on consent

To exercise any of these rights, write to [email protected] or to ALH TRADEAUTOMATIONFX LTD, Lord Byron Street 61-63, 6th Floor, Flat / Office 602, 6023 Larnaca, Cyprus. We will respond within one month of receiving your request.

7. Cookies

We use strictly necessary cookies required for the functioning of our platform: session management, authentication, language preference, and your cookie-consent record itself. These cannot be disabled.

With your explicit opt-in consent, we additionally set a marketing cookie namedsbs_ref when you arrive via an affiliate referral link. This cookie stores an 8-character referral code for up to 30 days so that, if you sign up within that window, we can attribute the referral to the affiliate and pay them their commission. The cookie contains no personal data and is not used for advertising or behavioural profiling.

You can change or withdraw your consent at any time via the “Cookie settings” link at the bottom-left of any page. Withdrawing consent will delete the affiliate-tracking cookie immediately.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including encryption of data in transit (TLS) and at rest, secure credential storage, and regular security assessments.

9. Contact

For questions about this Privacy Policy or to exercise your data rights, contact us at [email protected] or by post at:

ALH TRADEAUTOMATIONFX LTD
Lord Byron Street 61-63, 6th Floor, Flat / Office 602
6023 Larnaca
Cyprus

You also have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated. You may contact the authority in your country of residence or place of work, or the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus, which supervises us as the controller.