Integrated Equities Limited (“IEL”, “we”, “us”, or “our”), a licensed
securities broker and PSX Trading Right Entitlement Certificate (TREC)
holder, operates the IEL Mobile Trading App (marketed as “IEL Trade”)
(the “App”) for Android and iOS. This page outlines our policies
regarding the collection, use, and disclosure of personal data when
you use our Service and the choices you have associated with that
data.
Integrated Equities Limited is committed to protecting your privacy
and understands the importance of keeping your information private,
safe, and secure. This Privacy Policy is designed to help you decide
whether to use the Service and in what manner, and it describes how we
collect, store, and use information relating to individuals who use
the Service.
1. Consent to Use Information
This Privacy Policy serves as a legally binding agreement between you
(referred to as “you” or “user”) and Integrated Equities Limited. By
accessing or using our mobile app, or by providing information to us
in any other format, you acknowledge and agree to the terms outlined
in this Privacy Policy. You also consent to the collection and
utilisation of information as described in this Policy. This Policy
shall be read together with our Terms and Conditions and your Account
Opening Form, and is governed by the applicable laws of Pakistan,
including the Securities Act, 2015 and applicable directives of the
Securities and Exchange Commission of Pakistan (SECP) on
confidentiality of customer information.
We reserve the right to modify, remove, or add to this Privacy Policy
at any time. To stay updated on any changes, please refer to the
“Effective Date” section at the top of this document. Any revisions to
the Privacy Policy will take effect once we post the updated version.
In the case of material changes, we will provide reasonable advance
notice through the App, email, or SMS before such changes take effect.
Your continued use of our Services, or provision of personal
information after any changes, signifies your acceptance of the
updated Policy.
IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP
USING THE SERVICE IMMEDIATELY AND, WHERE RELEVANT, UNINSTALL THE APP.
ALONG WITH THIS POLICY, PLEASE REVIEW OUR TERMS AND CONDITIONS, AS
WELL AS ANY OTHER POLICIES WE MAY NOTIFY YOU ABOUT FROM TIME TO TIME.
2. Information Collection and Use
We collect different types of information for various purposes, in
order to provide and improve our Service to you.
2.1 Information We Collect
We collect the following types of data and information from you:
Personal and Identification Information
● Full name, CNIC / NICOP / Passport, date of birth, gender,
nationality
● Contact details: phone number, email address, residential and
mailing address
● Bank account details (IBAN, account title/number) and IP address for
fund transfers and settlements
● KYC/CRF information: source of income, occupation, net worth, tax
details, and financial history
● Login credentials and biometric data (fingerprint / face ID for
authentication)
Financial and Trading Data
● Portfolio holdings, order history, trade executions, balances, and
transaction records
● Credit-related data (via consented Tasdeeq integration for
onboarding/risk assessment), if required
Device, Technical, and Usage Data
● Device identifiers (IMEI, device ID, advertising ID), model, OS
version, and IP address
● App usage logs, session duration, screen views, crash reports, and
performance data
● Location data (only if enabled for features such as market alerts or
proximity-based services; can be disabled at any time)
Communication and Preference Data
● Support tickets, chat logs, and feedback
● Marketing and consent preferences (including for Tasdeeq-enabled
outreach)
We do not collect sensitive personal data (e.g., religion, health,
ethnicity) beyond regulatory necessities.
We collect and process the information referred to above, where
applicable, based on your consent, where processing is necessary for
the performance of a contract between you and the Company, or where
processing is necessary to fulfil a legitimate interest pursued by us.
2.2 How We Collect Information
This information is collected when you create an account (“Account”)
on the App, which is required to access and use our Services.
Depending on the services you use, we may collect information as
follows:
● Directly from you: account registration, KYC forms, trading
instructions, and support requests.
● Automatically: through app usage, device sensors, and analytics
tools (e.g., Firebase).
● From third parties: including regulatory entities (SECP, PSX, CDC,
NCCPL, banks, FBR); Tasdeeq (Pakistan’s SBP-licensed credit bureau),
only with your explicit consent; and Google Play Services and other
service providers.
● Third-party integrations: payment gateways, analytics providers, and
market data providers.
3. How We Use Your Information
Integrated Equities Limited may use the collected data for the
following lawful purposes:
● Service Delivery: account opening, order execution, portfolio
management, settlements, and app functionality.
● Regulatory Compliance: KYC/AML/CFT and reporting to SECP, PSX, CDC,
NCCPL, FBR, and SBP.
● Security & Fraud Prevention: authentication, monitoring suspicious
activity, and risk management.
● Personalisation & Improvement: tailored alerts, research and
education tools, and app enhancements.
● Customer Support: responding to inquiries and resolving issues.
● Marketing & Outreach: with your consent, including targeted
onboarding via our Tasdeeq partnership for financial inclusion.
● Analytics & Product Development: understanding usage patterns
(aggregated/anonymised where possible).
● Legal Obligations: responding to court orders, audits, or regulatory
requests.
Processing is based on: your consent, contract performance, legal
obligations, and legitimate business interests (e.g., security).
4. Transfer, Sharing, and Disclosure of Information
We do not sell, rent, or trade your personal data for commercial
purposes.
Disclosure of your information is limited to the following:
● Regulatory & Government Authorities: SECP, PSX, CDC, NCCPL, SBP,
FBR, FIA, or courts, when legally required.
● Service Providers & Partners: IT vendors, hosting providers,
analytics providers (e.g., Firebase), payment processors, and
custodians — under strict confidentiality and data processing
agreements.
● Tasdeeq Partnership: credit information is shared only with your
explicit, informed consent for onboarding, risk assessment, or
targeted outreach, and is fully compliant with the Credit Bureaus Act.
● Affiliates: within the IEL group, for operational purposes.
● Business Transfers: in the case of a merger, acquisition, or asset
sale (with notice where feasible).
● Legal Protection: to enforce our Terms, protect our rights, or
respond to emergencies.
We share only the minimum data necessary. Aggregated or anonymised
data may be used for industry reports or research.
If you are using our Services from another jurisdiction, your
information may be processed in Pakistan or other countries that may
not provide levels of data protection equivalent to those of your home
jurisdiction.
4.1 Further Disclosures of Information
Integrated Equities Limited may disclose your data in the good-faith
belief that such action is necessary. We share information about you
in the instances described below:
● Authorised third-party vendors and service providers: we share
information with third-party vendors and service providers who perform
services for us, such as identity verification, fraud prevention,
advertising, mailing services, tax and accounting services, contest
fulfilment, and analytics services.
● Integrated Equities Limited affiliates: where appropriate, we share
information with other companies owned or controlled by Integrated
Equities Limited. These companies process any shared information in
the same manner as described under this Privacy Policy.
● Substantial corporate transactions: we may share information in
connection with a substantial corporate transaction — a merger,
consolidation, reorganisation, financing, change in control, or
acquisition of all or a portion of our business by a third party, or
in the unlikely event of a bankruptcy or similar proceeding.
● Legal purposes: we disclose information if we believe disclosure is
required by applicable law or legal process, or to protect the rights,
interests, safety, and security of Integrated Equities Limited, our
users, or the public.
● With your consent: we share information for any other purposes
disclosed to you, with your consent.
We share information with others in an aggregated or otherwise
de-identified form that does not reasonably identify you.
5. Security of Information
We treat your information in strict confidentiality. The servers on
which this data is stored include industry-standard security measures
designed to prevent accidental or unlawful destruction, loss,
alteration, or unauthorised disclosure or access. While no method of
electronic transmission or storage is completely secure, we employ
encryption, access controls, and periodic security reviews to protect
your information. In the event of a data breach that is likely to
adversely affect you, we will notify you and the relevant regulatory
authorities as required under applicable law.
6. Service Providers
We may employ third-party companies and individuals to facilitate our
Service (“Service Providers”), to provide the Service on our behalf,
to perform Service-related services, or to assist us in analysing how
our Service is used. We may share your information with:
● third parties that provide services enabling us to deliver our
Service, including analytics providers, email service providers,
payment providers, and data verifiers;
● third parties that provide services relating to the operation of the
mobile App;
● auditors, contractors, or other advisers auditing the Company’s
business processes; and
● potential purchasers of, or investors in, the Company.
These third parties have access to your data only to perform tasks on
our behalf and are obligated not to disclose or use it for any other
purpose.
7. Links to Third-Party Sites
This Privacy Policy applies only to our Services and does not cover
any third-party websites or services linked through our App. Such
third parties operate under their own privacy policies, terms, and
conditions, which we recommend reviewing before use.
IEL does not endorse, control, or assume responsibility for the
content, security, privacy practices, or services provided by
third-party websites or services. Your use of such third-party
services is at your own risk, and IEL shall not be liable for any
loss, damage, or consequences arising from your interaction with them.
8. User Rights and Retention
You have the right to access, correct, update, or object to the use of
your information, or withdraw your consent (subject to applicable
legal and regulatory retention requirements), by submitting a
verifiable consumer request to our email address, Help@iel.net.pk, or
through the “Contact Us” section of our Website and App, or to our
physical address set out in the “Contact Us” section below. Your
requests will be dealt with in a prompt and professional manner and in
accordance with applicable law.
Data Retention: We retain your personal information for as long as
your Account remains active and thereafter for the minimum period
required under applicable law, including SECP and PSX record-keeping
requirements and the Anti-Money Laundering Act, 2010 (generally not
less than five years after the end of the business relationship). Upon
expiry of the applicable retention period, your information is
securely deleted or anonymised.
9. Children's Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from
children under 18 years of age. If we discover that a child under 18
has provided us with personal information, we will promptly delete it
from our servers, unless retention is required under applicable law.
If you are a parent or guardian and are aware that your child has
provided us with personal information, please contact us so that we
can take the necessary action.
10. Assignment
In accordance with applicable law, your information may be transferred
or assigned to a third party in the event of a change of control,
consolidation, merger, acquisition, or reorganisation. Where feasible,
we will provide you with prior notice of any such transfer, consistent
with Section 4 above. In situations such as bankruptcy, insolvency, or
receivership, we may not have control over the use and transfer of
your personal information.
11. Cookies, Tracking Technologies, and Analytics
The App uses cookies, local storage, and analytics tools (e.g.,
Firebase) to enhance functionality, analyse usage, and improve
performance. You can manage these via your device settings or App
preferences. We do not engage in cross-app behavioural advertising
without your explicit consent.
12. Changes to This Policy
We may update our Privacy Policy from time to time. When we do, we
will revise the “Effective Date” above and post the new Policy and, in
some cases, provide additional notice (such as a statement on our
website or a notification).
You are advised to review this Privacy Policy periodically for any
changes as you continue to use our Services. Changes to this Privacy
Policy are effective when posted on this page.
13. Contact Us
If you have any questions about this Privacy Policy, please contact us
at:
● Email: Help@iel.net.pk
● Address: Integrated Equities Limited, 30 Cricketers Colony, Netsol
Avenue, Ring Road Ghazi Interchange, Lahore Cantt.
● Phone: 0333-4298666
● Website: https://iel.net.pk
If your concern is not resolved to your satisfaction, you may lodge a
complaint with the Securities and Exchange Commission of Pakistan
(SECP) through its Service Desk Management System
(https://sdms.secp.gov.pk) or with the Pakistan Stock Exchange (PSX).