Privacy Policy & Cookie Policy

1. Introduction and Controller

Hitomorrow Assessment Data Classification and Analysis L.L.C and its related group entities (“we”, “us”, “our”, or “Hi2morrow”) are committed to protecting your privacy. This document explains how we collect, use, store, process, and protect your personal data when you visit our website, register for or participate in our qualification programs, use our platforms, communicate with us, or engage with any of our services.

By using our services or website, you agree to the terms of this Privacy Policy and Cookie Policy.

2. Scope

This policy applies to:

• Visitors to our Website (www.hi2morrow.com and related platforms)
• Individuals who register for, purchase, or participate in our Qualification Programs or educational services
• Affiliates, partners, and referrers
• Any person who contacts us by email, live chat, support ticket, or other communication channels
• Individuals whose data we process in connection with KYC/AML, suitability assessment for real capital allocation, or compliance monitoring

3. What Information We Collect and How We Collect It

3.1 Information You Provide to Us

To register, open an account, or use our Services, you will be asked to provide:

• Account & Contact Information: Full name, email address, phone number, date of birth, nationality, country of residence, billing address.
• Identification & Verification Information (KYC/AML): Government-issued ID (passport, national ID, driver’s license), proof of address, liveness/biometric verification data (where permitted), occupation, source of funds, source of wealth, and other supporting documentation required for regulatory compliance.
• Profile & Credentials: Username, password, and other login details for the Client Section.
• Payment Information: Credit/debit card details or other payment method information (processed securely via third-party gateways — we do not store full card details).
• Additional Information: Any information you voluntarily provide in communications, feedback, support requests, or trading journals.

3.2 Information We Collect Automatically When You Use Our Website or Platforms

• Device & Technical Information: IP address, device identifiers, browser type and version, operating system, screen resolution, and device type — collected for security, fraud prevention, and analytics.
• Usage & Behavioral Information: Pages visited, time spent, login times, navigation patterns, product engagement, and interaction data.
• Simulated Trading & Performance Data: All simulated trading activity during Qualification Programs, including orders, positions, P&L, drawdown metrics, consistency metrics (e.g., 30% rule compliance), session data, and behavioral patterns used to assess skill, discipline, and detect prohibited practices.
• Cookies & Tracking Technologies: See the dedicated Cookies section below for full details.

3.3 Information from Third Parties

We may receive information about you from:

• KYC/AML and identity verification providers (including biometric/liveness checks where permitted)
• Sanctions and watch-list screening services
• Credit reference or fraud prevention agencies
• Payment processors and financial institutions
• Publicly available sources
• Group entities (for shared compliance, onboarding, or capital allocation purposes)

3.4 Communications

All calls, emails, live chat sessions, and other correspondence with Hi2morrow may be recorded, monitored, or retained for quality control, training, evidentiary, regulatory, and dispute resolution purposes.

4. How We Use Your Information

We use your personal data for the following purposes:

• To register, verify, and manage your account and Client Section
• To deliver Qualification Programs, simulated trading assessments, educational content, and related services
• To process payments and manage billing
• To conduct KYC/AML verification, sanctions screening, and regulatory compliance checks
• To assess your suitability, risk profile, and eligibility for real firm capital allocation or Trader’s Elevator progression (where applicable)
• To monitor trading behavior, detect prohibited practices, fraud, or abuse of the platform
• To communicate with you about your account, programs, updates, and support requests
• To improve our services, platform security, user experience, and product development
• To comply with legal, regulatory, tax, and reporting obligations
• To protect our legitimate interests, including defending legal claims and preventing harm

5. Legal Basis for Processing

We process your personal data on one or more of the following legal grounds under the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and applicable international standards (including GDPR where relevant):

• Your consent (where required and obtained)
• Performance of a contract with you (provision of Qualification Programs and Services)
• Compliance with legal obligations (KYC/AML, sanctions, regulatory reporting)
• Our legitimate business interests (platform security, fraud prevention, service improvement, assessment for capital allocation, protection of our business and users)
• Vital interests or public task in limited circumstances

Where we process sensitive data (e.g., biometric data for verification), we do so only where permitted by law and with appropriate safeguards or consent.

6. Who We Share Your Information With

We do not sell your personal data. We limit sharing to parties with a genuine need to know and only for the purposes set out in this Policy. We may share your information with:

• Group Entities: Neoway Trading LTD (Cyprus), Hitomorrow Securities LTD (Cyprus), and other group companies for onboarding, compliance, KYC/AML, suitability assessment for real capital allocation, and operational purposes.
• Service Providers: Platform providers, hosting, IT support, payment processors, KYC/AML verification providers, analytics providers, and customer support tools — all under data processing agreements with confidentiality and security obligations.
• Professional Advisers: Lawyers, auditors, insurers, and consultants bound by confidentiality obligations.
• Regulatory & Law Enforcement: Government authorities, regulators (including CySEC where applicable), courts, or law enforcement when required by law or to protect our rights.
• Corporate Transactions: Potential buyers or successors in the event of a merger, acquisition, or sale of assets (data usually anonymized where possible).

All third parties are required to handle your data securely and only for the specific purposes we authorize.

7. International Transfers of Your Information

Your personal data may be transferred to and processed in countries outside your country of residence, including the United Arab Emirates, Republic of Cyprus, Mauritius, and other jurisdictions where our group entities or service providers are located.

Where such transfers occur, we implement appropriate safeguards in accordance with applicable data protection laws (including PDPL mechanisms such as adequacy decisions, standard contractual clauses, consent, or other recognised safeguards). We provide transparency on these protections as required.

8. Data Retention

We retain your personal data only for as long as necessary to:

• Fulfill the purposes for which it was collected (including delivery of Qualification Programs and any related assessment for real capital)
• Comply with legal, regulatory, tax, accounting, or reporting obligations (including KYC/AML record-keeping requirements)
• Protect our legitimate interests (including defending or pursuing legal claims)

When data is no longer required, it will be securely deleted or anonymized. In some cases we may retain aggregated or anonymized data indefinitely for research, statistical, or product improvement purposes.

9. Security of Personal Information

We store personal information electronically (and where applicable physically) using appropriate technical and organizational measures designed to ensure confidentiality, integrity, and availability. These include secure servers, firewalls, encryption in transit, access controls, regular security reviews, and staff training.

While no system is 100% secure and transmission over the internet carries inherent risks, we take reasonable and appropriate steps to safeguard your data. You are responsible for maintaining the confidentiality of your login credentials.

10. Your Rights

Subject to applicable law (including UAE PDPL and GDPR where it applies to you), you have the right to:

• Access your personal data and obtain a copy
• Request correction of inaccurate or incomplete data
• Request deletion of your data (subject to legal retention obligations)
• Restrict or object to certain processing activities
• Request data portability (where technically feasible and applicable)
• Withdraw consent at any time (where processing is based on consent) — note that this may affect our ability to provide some or all Services
• Object to direct marketing and certain automated processing

We do not rely solely on automated decision-making that produces legal or similarly significant effects without meaningful human involvement.

To exercise any of these rights, please contact us at the details in Section 18. We will respond in accordance with applicable timelines and may request verification of your identity.

11. Cookies and Tracking Technologies (Full Cookie Policy)

11.1 Introduction

This Website and associated platforms use cookies and similar tracking technologies to support core functionality, enhance your browsing and qualification experience, enable security features, and improve performance.

If you prefer to block or restrict cookies, you can do so through your browser settings. Please note that blocking all cookies — including essential cookies — may prevent you from accessing certain parts of the Website, the Client Section, or completing Qualification Programs.

11.2 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They may store information about your device type, operating system, browsing behaviour, connection details, and IP address. Cookies used by Hi2morrow do not, by themselves, collect or store personally identifiable information in a way that directly identifies you without additional data. However, when combined with other information we hold, certain cookies may contribute to identifying you for the purposes described in this Policy.

11.3 Types of Cookies We Use

We use different categories of cookies for specific purposes:

Essential Cookies — Strictly necessary for the Website and platforms to function properly. They enable core features such as secure login and session management for the Client Section, payment processing, security and fraud prevention, and basic navigation. Without these cookies, key parts of the site (including access to Qualification Programs) may not work. Essential cookies are always active and do not require consent under applicable law.

Functional Cookies — Enable enhanced functionality and personalisation, such as remembering your language, region, or display preferences, maintaining your session, supporting smooth navigation, and remembering qualification progress or dashboard settings (where applicable).

Analytics and Performance Cookies — Help us understand how visitors interact with the Website and platforms. They allow us to distinguish between users, measure visit frequency and time spent, identify navigation patterns, and improve Website performance and the qualification experience. Analytics data is typically aggregated and anonymised. We may use third-party analytics providers subject to their own privacy policies and our data processing agreements.

Security and Risk Monitoring Cookies / Similar Technologies — We may use cookies and related technologies (including device fingerprinting or session tracking) to support security, fraud prevention, and detection of prohibited trading practices or abusive behaviour during Qualification Programs. These help protect the integrity of our assessment process and the platform.

11.4 Legal Basis and Consent for Cookies

Our use of cookies is based on the following legal grounds under the UAE PDPL and applicable international standards:

• Essential cookies: Legitimate interest in operating a secure and functional website / necessity for contract performance.
• Functional, analytics, and security cookies: Your consent (where they involve processing that identifies or tracks you) or our legitimate interests in improving services, security, and preventing abuse.

You provide consent by clicking “Accept” or accepting the cookie banner/prompt when first visiting the Website, or by continuing to use the Website after being informed of our cookie practices. You may withdraw your consent at any time by contacting support@hi2morrow.com or adjusting your browser settings. Once consent is withdrawn, we will disable cookies that rely on consent and remove associated identifiers from our systems where technically feasible.

11.5 Why We Use Cookies

We use cookies to enable core Website and Client Section functionality, support secure login, payments, and qualification processes, understand Website traffic and usage patterns, improve performance and user experience, support analytics and diagnostics, enhance security, and help detect prohibited practices or fraudulent activity, and remember your preferences where possible.

11.6 Cookie Duration and Expiry

Cookies may remain on your device for different periods: Session cookies expire when you close your browser. Persistent cookies remain until they reach their expiry date or are manually deleted. We do not retain cookie data longer than necessary.

11.7 How to Manage or Block Cookies

You can manage or block cookies at any time through your browser settings. Most browsers allow you to block all cookies, block only third-party cookies, delete existing cookies, or receive a notification when a cookie is being set.

Common browser settings:

• Chrome: Settings → Privacy and security → Cookies and other site data
• Safari: Preferences → Privacy → Manage Website Data
• Firefox: Options → Privacy & Security → Cookies and Site Data
• Edge: Settings → Cookies and site permissions → Cookies and site data

Blocking essential cookies may limit or prevent your ability to use key features of the Website, including access to the Client Section and Qualification Programs.

11.8 Your Rights Regarding Cookie Data

In addition to the rights set out above, you have the following rights in relation to data collected via cookies (subject to applicable law):

• Request information about how we process cookie-related data
• Request correction of inaccurate cookie identifiers or associated data
• Request deletion of cookie identifiers and associated data (“right to erasure”)
• Restrict processing of cookie-related data where permitted
• Request cookie-related data in a structured, machine-readable format (data portability, where applicable)
• Object to processing of cookie data for certain purposes
• Lodge a complaint with the relevant supervisory authority

11.9 Third-Party Cookies

We may allow trusted third-party providers (e.g., analytics platforms, payment processors, or security services) to set cookies on our Website. These third parties have their own privacy and cookie policies. We do not control their use of cookies and encourage you to review their policies. Third-party cookies are used only where necessary and under appropriate agreements.

11.10 Updates to Cookie Practices

We may update our cookie practices from time to time. If changes expand our ability to collect or process cookie identifiers in ways that require additional consent, such changes will apply only after you provide fresh consent. All other updates take effect immediately upon publication on the Website.

12. Data Breach Notification

In the event of a personal data breach, we will notify the relevant supervisory authority (UAE Data Office or equivalent) without undue delay and, where required, without undue delay after becoming aware of it. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify affected individuals without undue delay, providing information on the nature of the breach, likely consequences, and measures taken to address it.

13. Automated Decision-Making and Profiling

We do not rely solely on automated decision-making that produces legal or similarly significant effects without meaningful human involvement. Where we use automated processing or profiling (for example, in risk or prohibited practice monitoring), appropriate safeguards are in place, including the right to obtain human intervention and to contest decisions.

14. Complaints and Disputes

If you are unhappy with how we handle your personal data or cookie-related data, please contact us first so we have the opportunity to resolve the issue. You also have the right to lodge a complaint with the relevant supervisory authority:

• For UAE-related matters: UAE Data Office (or designated authority under PDPL)
• For Cyprus or where Cyprus law applies: Office of the Commissioner for Personal Data Protection, Iasonos 1, Nicosia 1082, Cyprus — dataprotection.gov.cy

15. External Links

Our website may contain links to third-party websites or services. We are not responsible for their privacy practices or cookie policies. We encourage you to review their policies before providing any personal information.

16. Updates to This Policy

We may amend this combined Privacy Policy and Cookie Policy from time to time to reflect changes in law, our practices, or for legitimate business reasons. The current version will always be posted on this page with the “Last Updated” date. Where material changes are made that expand our processing or require additional consent, we may notify you by email or prominent notice on the Website. Continued use of our services after changes constitutes acceptance of the updated Policy.

17. Account Deletion

To request deletion of your account and associated personal data (including cookie identifiers where applicable), please contact us at the details below. We will process such requests in accordance with applicable law (including PDPL and GDPR principles), subject to any overriding legal or regulatory retention requirements (e.g., KYC/AML record-keeping).

18. Contact Us

For questions about this Privacy Policy and Cookie Policy, to exercise your data rights, or to request account deletion, please contact:

We will process requests in accordance with applicable timelines and may request verification of your identity.