This Privacy Policy (the "Policy") describes how LTI Institute (referred to throughout as "the Company," "we," "us," or "our") collects, uses, stores, shares, and protects personal data in connection with our business activities, programs, and website located at ltiinstitute.com (the "Site").
The Company operates as an ecosystem partner that facilitates introductions, manages affiliate and referral networks, conducts lead prequalification, and administers program participation on behalf of its members and partners. The Company does not execute trades, hold or custody funds, provide financial or investment advice, or act as a regulated financial institution or broker in any capacity.
This Policy applies to all individuals who interact with the Company, including but not limited to:
Prospective and current participants in the Company's Institutional Program
Affiliates and referral partners enrolled in the Company's Affiliate Program
Individuals contacted through or who engage with the Company's Retail Outreach Program
Visitors to the Company's website and digital platforms
Event attendees, webinar participants, and direct contacts
By accessing the Site, submitting your information, or participating in any of the Company's programs, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, please do not provide your personal data or use our services.
This Policy has been prepared in accordance with the European Union General Data Protection Regulation ("EU GDPR"), the UK General Data Protection Regulation ("UK GDPR"), the Philippines Data Privacy Act of 2012 ("DPA") and its Implementing Rules and Regulations, and applicable global data privacy standards. Where more than one legal framework applies, we apply the standard most protective of your rights.
The Company is an independently operated business that provides introduction, affiliate management, lead qualification, and program administration services. The Company serves as a facilitating intermediary and ecosystem partner , it is not a financial institution, broker, dealer, investment advisor, fund manager, or licensed Forex trading entity.
The Company maintains a commercial relationship with a third-party Forex Trading Company for the purpose of facilitating introductions and warm handoffs of qualified individuals who may wish to explore opportunities offered directly by the Trading Company. This relationship is strictly referral and introductory in nature.
Important distinctions:
The Company and the Trading Company are separate and distinct legal entities.
The Company does not execute trades, manage trading accounts, or hold, transfer, or custody funds on behalf of any individual.
The Company does not provide financial, investment, tax, or legal advice.
Any trading activity, account opening, and financial services are conducted exclusively by, and are the sole responsibility of, the Trading Company.
The Company's privacy practices described in this Policy govern only the data processed by the Company. The Trading Company maintains its own separate privacy policy that governs data collected directly by the Trading Company.
For data controller purposes under the EU GDPR, UK GDPR, and applicable law, the Company is the data controller for personal data it collects and processes as described in this Policy.
The Company collects personal data only to the extent necessary for the lawful purposes described in this Policy. The categories of personal data we may collect include the following:
3.1 Personal Identification Data
Full name
Email address
Phone number (including mobile and direct lines)
Residential or business address
Company or organization name
Job title or professional role
Nationality and/or country of residence (where relevant for program eligibility)
3.2 Financial Qualification Data
For the Institutional Program and Retail Outreach Program, we may collect data relevant to prequalification, including:
Self-declared investment capacity or experience level
Accredited or qualified investor status declarations (where applicable under relevant law)
General financial background information as voluntarily provided
The Company does not collect bank account details, trading account credentials, payment card information, or other sensitive financial instruments. Any such data is handled exclusively by the Trading Company.
3.3 Call Recordings
Where applicable and where permitted or required by law, the Company may record telephone conversations for quality assurance, training, compliance verification, and accurate record-keeping purposes. You will be notified of any call recording prior to or at the commencement of a recorded call. Recordings are stored securely and retained only for the period necessary for the stated purpose.
3.4 Website Usage Data
IP address and approximate geographic location derived from IP address
Browser type, version, and operating system
Pages visited, time spent on pages, and navigation paths
Referring URLs and exit pages
Device type and screen resolution
Analytics and performance metrics collected via third-party analytics tools
3.5 Affiliate and Referral Performance Data
For individuals and entities enrolled in the Affiliate Program, we collect and process:
Affiliate account information and registration data
Referral links, unique tracking codes, and campaign identifiers
Lead submission records and referral volumes
Commission calculations, payment instructions, and payout records
Marketing material usage and engagement metrics
Program compliance records
3.6 Communications Data
Email correspondence and inquiry records
Contact form submissions
Webinar and event registration and attendance data
Notes and records from consultations or introductory calls
4.1 Website Forms and Online Submissions
When you complete any form on our Site , including inquiry forms, program registration forms, affiliate sign-up forms, event registration pages, or contact forms , we collect the information you voluntarily provide. Submission of a form constitutes your acknowledgment that the data will be processed in accordance with this Policy.
4.2 Outreach Communications
The Company conducts outbound and inbound telephone communications as part of its Retail Outreach Program. Personal data may be collected when our representatives contact individuals via telephone for the purposes of lead qualification and program introduction, or when individuals contact the Company through its telephone lines. Where calls are recorded, you will be informed at the outset of the call.
4.3 Affiliate Referrals
When an individual is referred to the Company by an enrolled affiliate or referral partner, the referring affiliate may provide us with basic personal information (such as name, email, and phone number) to facilitate the introduction. In all cases, the affiliate is responsible for ensuring that such referrals are made with the referred individual's knowledge and in compliance with applicable law.
4.4 Direct Communications
We collect data when you contact us directly by email, telephone, or postal mail, or when you respond to communications we initiate. This includes responses to outreach emails, inquiries about our programs, and follow-up communications.
4.5 Events and Webinars
When you register for or attend an event, webinar, workshop, or online seminar hosted or co-hosted by the Company, we collect registration data, attendance records, and any information you voluntarily share during or in connection with the event.
The Company processes personal data only where it has a valid legal basis for doing so. The applicable legal bases under the EU GDPR, UK GDPR, and equivalent provisions of the Philippines Data Privacy Act are as follows:
5.1 Consent (Article 6(1)(a) GDPR / Section 13(a) DPA)
Where we rely on your consent as a legal basis, for example, for marketing communications, we will request your consent clearly and explicitly prior to processing. You have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. See Section 13 for opt-out instructions.
5.2 Performance of a Contract (Article 6(1)(b) GDPR / Section 13(b) DPA)
We process personal data where it is necessary to perform our obligations under a contract with you, including your enrollment in and participation in the Affiliate Program, Institutional Program, or Retail Outreach Program.
5.3 Compliance with Legal Obligations (Article 6(1)(c) GDPR / Section 13(c) DPA)
We process personal data where we are required to do so by applicable law, regulation, or legal process, including anti-money laundering screening, fraud prevention, and retention obligations imposed by regulatory authorities.
5.4 Legitimate Interests (Article 6(1)(f) GDPR / Section 13(f) DPA)
We process personal data where it is necessary for our legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include: operating and improving our referral and affiliate programs; preventing fraud and maintaining the integrity of our operations; ensuring call center quality and compliance; website analytics and security; and record-keeping and audit trail management. We conduct a Legitimate Interests Assessment (LIA) where we rely on this basis.
Legitimate Interests Assessment - Accessible Summary
A summary of our Legitimate Interests Assessment is set out below. In each case, we have considered whether your interests or fundamental rights override our legitimate interests and concluded that they do not, given the nature of the data processed, the reasonable expectations of data subjects, and the safeguards in place.
| Processing Activity | Legitimate Interest Pursued | Necessity & Proportionality | Balancing Assessment |
|---|---|---|---|
| Referral & affiliate program operations | Operating and growing our core business | Limited to contact and performance data necessary to manage relationships | Low privacy impact; data subjects have an existing business relationship with us |
| Fraud prevention & operational integrity | Protecting the Company and its partners from fraudulent activity | Minimal data used; processing is targeted at risk indicators only | Risk of harm from fraud outweighs the minimal intrusion on data subjects |
| Call centre quality & compliance monitoring | Ensuring staff compliance and resolving disputes | Call recordings are limited in scope and retention period | Data subjects are notified prior to recording; impact is minimal |
| Website analytics & security | Maintaining and improving the Site; preventing unauthorised access | Aggregated or pseudonymised data used where possible | Low impact; standard industry practice with opt-out available |
| Record-keeping & audit trail management | Maintaining accurate business records for accountability | Retained only for the period necessary to satisfy legal and business requirements | Minimal intrusion; supports data subject interests in dispute resolution |
The full LIA is maintained as an internal record forming part of our Records of Processing Activities (RoPA) under GDPR Article 30, and is available to supervisory authorities upon request. You have the right to object to processing based on legitimate interests at any time — see Section 11.5.
The Company uses personal data collected for the following specific, lawful purposes:
6.1 Lead Prequalification
We use personal data including contact information, professional background, and self-declared investment capacity to assess whether an individual may be eligible or appropriate for introduction to the Trading Company's programs. This process involves reviewing the information you provide against program criteria and does not constitute financial advice or a financial services assessment.
6.2 Warm Handoff to the Third-Party Forex Trading Company
Upon successful prequalification and with your knowledge, we facilitate a structured introduction , or "warm handoff" , of your contact information and qualification summary to the Trading Company. You will be informed before your data is shared with the Trading Company, and this transfer is governed by a data sharing agreement between the Company and the Trading Company. Once your data is transferred to the Trading Company, its privacy policy governs the further processing of your data by the Trading Company.
6.3 Affiliate and Referral Tracking
For Affiliate Program participants, we use personal data to manage affiliate accounts, track referrals and conversions, calculate commissions, process payments, and administer the Affiliate Program in accordance with applicable terms and conditions.
6.4 Program Participation and Administration
We use personal data to manage your enrollment and participation in the Company's programs (Institutional, Affiliate, or Retail Outreach), communicate program updates, send administrative notices, and provide program-related support.
6.5 Marketing and Communications
Subject to your consent where required, we may use your contact information to send you information about the Company's programs, updates, events, and relevant opportunities. You may opt out of marketing communications at any time. See Section 13 for details.
6.6 Compliance and Fraud Prevention
We use personal data to fulfill our legal and regulatory obligations, including anti-fraud screening, identity verification where required, anti-money laundering (AML) checks, and record-keeping mandated by applicable law. We may use automated or manual review processes for this purpose.
6.7 Website Operations and Improvement
We use technical and usage data collected from the Site to operate, maintain, secure, and improve our website and digital platforms, and to monitor for unauthorized access, technical faults, or security incidents.
6.8 Call Quality and Compliance
Where calls are recorded, recordings are used for quality assurance, staff training, compliance monitoring, and dispute resolution purposes.
The Company does not sell, rent, trade, or otherwise commercially exploit your personal data to any third party. Personal data is shared only in the circumstances described below, and only to the extent necessary for the stated purpose.
7.1 Third-Party Forex Trading Company
The Company shares personal data with the Trading Company for the purpose of facilitating introductions and warm handoffs as described in Section 6.2. Data shared typically includes your name, contact information, and prequalification summary. Such sharing is governed by a written data sharing agreement that requires the Trading Company to process your data in accordance with applicable data protection law. The Trading Company's own privacy policy governs the use of your data once received by the Trading Company.
7.2 Service Providers and Technology Partners
The Company engages trusted third-party service providers to support our operations. These providers act as data processors on our behalf and are contractually prohibited from using your data for any purpose other than the services they provide to us. Categories of service providers include:
Customer relationship management (CRM) platform providers
Email communication and marketing automation tools
Cloud hosting and data storage providers
Website analytics and performance monitoring tools
Affiliate tracking and commission management platforms
Payment processing and disbursement services (for affiliate commissions)
Document management and e-signature tools
All service providers are required to implement appropriate technical and organizational security measures and are subject to binding data processing agreements.
7.3 Legal, Regulatory, and Compliance Authorities
The Company may disclose personal data to governmental authorities, law enforcement agencies, regulatory bodies, or courts where required by applicable law, court order, or lawful regulatory request. We will notify you of such disclosure where legally permissible and practicable to do so.
7.4 Corporate Transactions
In the event of a merger, acquisition, asset sale, or restructuring, your personal data may be transferred to the successor entity as part of the transaction, subject to confidentiality obligations and the continued application of this Privacy Policy.
7.5 No Sale of Personal Data
The Company explicitly confirms that it does not sell, lease, rent, or otherwise transfer your personal data to any third party for such party's own marketing, commercial, or business purposes. Any sharing of data is strictly limited to the purposes described in this Policy.
The Company may transfer personal data to countries outside your home jurisdiction, including countries that may not provide the same level of data protection as your home country. Where such transfers occur, the Company implements appropriate safeguards to ensure that your data remains protected to the standard required by applicable law.
Safeguards we rely on for international transfers include:
Standard Contractual Clauses (SCCs) approved by the European Commission or the UK Information Commissioner's Office, as applicable
Adequacy decisions issued by the relevant supervisory authority confirming that the recipient country provides an adequate level of data protection
Binding Corporate Rules or other approved transfer mechanisms where applicable
Data sharing and processing agreements incorporating appropriate technical and organizational security requirements
You may request further information about the specific safeguards in place for international transfers of your personal data by contacting us using the details provided in Section 16.
The Company retains personal data only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory retention obligations, and to resolve disputes or enforce agreements.
The following retention periods apply as a general guide, subject to applicable legal requirements:
Lead and prequalification data: Retained for a period of up to 3 years from the date of last interaction or the date the lead is disqualified, whichever is later.
Warm handoff records: Retained for a minimum of 5 years from the date of handoff for compliance and audit trail purposes.
Affiliate account data: Retained for the duration of the affiliate relationship and for a period of 7 years following termination of the affiliate agreement, to comply with financial record-keeping obligations.
Call recordings: Retained for a period of 12 months from the date of the call, unless a longer period is required for an ongoing dispute, compliance review, or legal hold.
Website and analytics data: Retained in identifiable form for up to 26 months, after which it is anonymized or deleted.
Legal and compliance records: Retained for the minimum period required by applicable law, which may extend to 7 years in certain jurisdictions.
Upon expiry of the applicable retention period, personal data is securely deleted, anonymized, or rendered irreversibly de-identified. Requests for early deletion are handled in accordance with Section 11 of this Policy.
The Company implements appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security measures include, but are not limited to:
Encryption of personal data in transit using industry-standard Transport Layer Security (TLS) protocols
Encryption of personal data at rest on our systems and with our service providers
Access controls and role-based permissions limiting access to personal data to authorized personnel on a need-to-know basis
Multi-factor authentication (MFA) for access to systems containing personal data
Regular security assessments, vulnerability testing, and system audits
Staff training on data protection obligations and information security best practices
Physical security measures for facilities where personal data is processed or stored
Incident response procedures for detection, reporting, and remediation of data security incidents
Data processing agreements with all third-party service providers imposing equivalent security standards
While we take all reasonable precautions to protect your personal data, no data transmission over the internet or electronic storage system is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority in accordance with applicable legal requirements and within the timeframes prescribed by law.
Depending on your country of residence and the applicable legal framework, you may have the following rights with respect to your personal data:
11.1 Right of Access
You have the right to request confirmation of whether the Company processes your personal data and, if so, to receive a copy of that data along with information about how it is used, retained, and shared.
11.2 Right to Rectification
You have the right to request the correction of inaccurate or incomplete personal data we hold about you. Please inform us promptly of any changes to your personal information.
11.3 Right to Erasure ("Right to be Forgotten")
You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn your consent (and no other legal basis applies), where you have successfully exercised your right to object, or where processing is unlawful. This right is subject to applicable legal retention requirements and may be limited in certain circumstances.
11.4 Right to Restriction of Processing
You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data, where processing is unlawful and you oppose erasure, or where we no longer need the data but you require it for the establishment or defense of legal claims.
11.5 Right to Object
You have the right to object to the processing of your personal data where we rely on our legitimate interests as the legal basis for processing. You also have an absolute right to object to the processing of your data for direct marketing purposes at any time, without providing justification.
11.6 Right to Data Portability
Where processing is based on your consent or the performance of a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit that data directly to another controller where technically feasible.
11.7 Right to Withdraw Consent
Where processing is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. You may withdraw consent by contacting us at the details provided in Section 16.
11.8 Rights Under the Philippines Data Privacy Act
In addition to the rights described above, data subjects in the Philippines have the right to be informed of the processing of their personal data, the right to object to automated processing, the right to lodge a complaint with the National Privacy Commission (NPC), and the right to damages where their rights have been violated. For complaints, you may contact the NPC at www.privacy.gov.ph.
11.9 How to Exercise Your Rights
To exercise any of the rights described above, please submit a written request to us using the contact details in Section 16. We will respond to your request within the timeframe prescribed by applicable law (ordinarily within 30 days, or 72 hours for urgent requests under the DPA). We may require verification of your identity before processing your request. There is no fee for exercising your rights unless requests are manifestly unfounded or excessive.
11.10 Right to Lodge a Complaint
You have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction if you believe the Company has processed your personal data in a manner that violates applicable law. In the EU, you may contact your national Data Protection Authority. In the UK, you may contact the Information Commissioner's Office (ICO) at www.ico.org.uk. In the Philippines, you may contact the National Privacy Commission at www.privacy.gov.ph.
The Company may send you marketing communications about our programs, events, and related updates where you have provided consent, enrolled in one of our programs, or where we have a legitimate interest in contacting you and you have not opted out.
You may opt out of receiving marketing communications from the Company at any time by:
Clicking the "Unsubscribe" link in any marketing email you receive from us
Sending a written opt-out request to [email protected]
Updating your communication preferences in your account profile (if applicable)
Please allow up to 5-10 business days for your opt-out request to be processed. Please note that even if you opt out of marketing communications, we may continue to send you administrative, transactional, or legally required notices relating to your participation in our programs or your contractual relationship with us.
The Company does not make automated eligibility decisions that produce legal or similarly significant effects based solely on your personal data without human review. Where automated tools are used to assist with lead scoring or prequalification, such tools are supported by human oversight.
The Company's programs, services, and website are intended solely for individuals who are 18 years of age or older. The Company does not knowingly collect, solicit, or process personal data from individuals under the age of 18.
If you are under 18 years of age, please do not submit any personal data to us, participate in any of our programs, or use our Site. If the Company becomes aware that it has inadvertently collected personal data from a person under the age of 18, it will take immediate steps to delete such data from its records.
If you believe that the Company may have collected personal data from a minor, please contact us immediately at [email protected]
The Company reserves the right to update, modify, or revise this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. All changes will be posted on this page with an updated effective date indicated at the top of the Policy.
Where changes are material , meaning they significantly affect your rights or how we process your personal data , we will provide you with advance notice through reasonable means, which may include a prominent notice on the Site, an email notification to your registered address, or a pop-up notification upon your next visit to the Site.
Your continued use of the Site or participation in our programs following the posting of a revised Policy constitutes your acknowledgment of and agreement to the updated Policy. We encourage you to review this Policy periodically to remain informed of how we protect your personal data.
We maintain an archive of prior versions of this Privacy Policy, which is available upon request.
For questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the Company's designated privacy representative using the details below:
Company Name: LTI Institute
Email: [email protected]
Website: ltiinstitute.com
We are committed to resolving all data privacy inquiries in a timely, transparent, and professional manner. If you feel your concern has not been adequately addressed, you retain the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction as described in Section 11.10.
This Privacy Policy was prepared for publication on the Company's website and is intended to be read in conjunction with any applicable Terms of Use and Affiliate Program Agreement. This Policy does not constitute legal advice.
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