Privacy Policy

This Privacy Policy explains how Energy Marketing and Trading Ltd (“EMT”, “we”, “us”, “our”) collects, uses, stores and protects personal data processed through the Fluyt website and Pilot trading programme (“Fluyt”). It applies to visitors, prospective Clients and participating counterparties (“you”).

We are committed to protecting your privacy and handling personal data in compliance with applicable data protection laws, including the UK GDPR and Data Protection Act 2018.

1. Who We Are

Fluyt is operated by Energy Marketing and Trading Ltd, a company incorporated in England and Wales. Our contact details are available on the Fluyt website.

For data protection purposes, EMT is the data controller for all personal data processed in connection with Fluyt.

2. What Personal Data We Collect

We collect only the minimum personal data needed to operate the Pilot and deliver trades. This may include:

  • Identity information – Your name, company name, job title, email address, phone number.
  • KYC documentation – Director names, beneficial owners, company registration documents, addresses, and other information required for regulatory compliance.
  • Contact history – Emails, form submissions, trade enquiries, messages and notes relating to onboarding or trades.
  • Technical information – IP address, browser type, device details and server logs automatically collected when you use our website.
  • Trade-related data – Details of certificates you enquire about, quotes, delivery instructions, and associated documents.

We do not collect or process payment card details. Bitcoin transactions are recorded as transaction hashes, not wallet balances or private keys.

3. How We Use Personal Data

We use your personal data solely for legitimate business purposes, including:

  • Responding to enquiries and managing Pilot participation.
  • Conducting KYC, AML and sanctions screening.
  • Issuing quotes and facilitating environmental certificate trades.
  • Providing delivery evidence, deal packs and audit documentation.
  • Maintaining internal records, compliance files and trade logs.
  • Improving website performance and operational processes.
  • Communicating important updates about the Pilot or your account.

We do not sell, rent, trade or otherwise monetise personal data.

4. Our Legal Basis for Processing

We process your personal data under one or more of the following legal bases:

  • Contractual necessity – Processing required to onboard you, provide quotes, execute trades or deliver Products.
  • Legal obligation – AML, sanctions screening and record-keeping requirements.
  • Legitimate interest – Communicating with Clients, maintaining security, and improving the Pilot.
  • Consent – Where explicitly requested (e.g., for optional communication channels).

5. How We Share Personal Data

We only share your personal data with third parties where necessary to operate the Pilot or comply with law. This may include:

  • Environmental certificate registries – For transfers, cancellations or account validation.
  • Compliance and verification providers – For sanctions screening and AML checks.
  • Technology and hosting partners – For website hosting, email systems and secure document storage.
  • Authorities and regulators – Where legally required (for example, to file a suspicious activity report).

We do not sell or broker data to third parties for marketing or commercial use.

6. International Transfers

Data may be processed in the UK, EU or Singapore, where our operational teams and service providers are based. Where we transfer personal data outside the UK or EU, we use appropriate safeguards such as contractual clauses or equivalent protections.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

  • KYC/AML data: Retained for at least 5 years after the end of the Client relationship, as required by law.
  • Trade records: Retained for 7 years for legal, audit and operational reasons.
  • Technical logs: Retained for a shorter operational period unless required for security or investigation.

Where data is no longer required, we securely delete or anonymise it.

8. Your Rights

Depending on your location, you may have certain rights regarding your personal data, including:

  • The right to access your personal data.
  • The right to correct inaccurate information.
  • The right to request deletion (subject to legal retention requirements).
  • The right to restrict processing.
  • The right to object to certain processing activities.
  • The right to request a copy of your data in portable format.

To exercise any rights, contact us using the details provided on the Fluyt website.

9. Security

We use appropriate technical and organisational measures to protect personal data, including secure data storage, restricted access, two-factor authentication where supported, and encryption during transmission.

No system is entirely risk-free. You acknowledge that data transmission over the internet cannot be guaranteed as completely secure.

10. Third-Party Links

The Fluyt website may contain links to third-party sites. We are not responsible for the content, security or privacy practices of third-party websites.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on the Fluyt website. Significant changes will be notified where appropriate.

12. Contact

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us using the contact information provided on the Fluyt website.

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