Last updated: May 2026
This policy is a working draft prepared for review. It is not legal advice. Before publication it should be reviewed by a qualified data-protection adviser to confirm it meets the EU General Data Protection Regulation (GDPR) and the Irish ePrivacy Regulations. Items marked [confirm] need a decision from Positive Equity.
1. Who We Are
Positive Equity is a proprietary trading firm building long-term careers in the markets, with offices in Dublin, London, Split, and Zagreb. For the purposes of data-protection law, Positive Equity is the data controller for personal data collected through this website. Our trading operations are conducted through our FCA-authorised partner, TTG Capital Ltd.
If you have any questions about this policy or about how we handle your personal data, please contact us via our Contact page. [confirm] a dedicated privacy contact address (for example, privacy@positive.ie) and, if one is appointed, the details of a Data Protection Officer.
2. The Personal Data We Collect
We only collect personal data that you choose to provide, or that is necessary to operate this website.
- Job and internship applications. When you apply through any of our application forms, we collect your name, email address, phone number, preferred location, your education and work background, your motivation for applying, and any CV or supporting documents you upload.
- Experienced trader applications. In addition to the above, we collect track-record information, including monthly profit-and-loss figures. This is financial information about you and is treated with particular care.
- Contact enquiries. When you use our contact form, we collect your name, email address, and the content of your message.
- Website usage data. If, and only if, you accept analytics cookies, we collect limited, aggregated information about how visitors use the site. We do not use this data for advertising.
3. How and Why We Use Your Data
We use personal data only for the purposes for which it was provided:
- To assess and respond to your application, communicate with you about it, and manage our recruitment process.
- To respond to enquiries submitted through the contact form.
- To understand and improve how the website is used (analytics, only with your consent).
Our lawful bases for processing are: taking steps at your request prior to entering into a contract and our legitimate interest in recruiting traders (for applications and enquiries); and your consent (for analytics cookies, which you may withdraw at any time).
4. Automated Tools in Application Review
To help our team review applications efficiently, we use an AI tool to produce a short summary and an indicative score for each application. This is a decision-support aid only. Applications are reviewed by people, and no decision producing legal or similarly significant effects is made solely by automated means. If you would like a human to review any aspect of how your application was handled, you can contact us. [confirm] wording with your adviser in light of GDPR Article 22.
5. Who We Share It With
We do not sell your personal data. We share it only with service providers who process data on our behalf, under contract, to operate this website and our recruitment process. These currently include providers for website hosting, application and database storage, content management, email, website analytics, and the AI review aid described above. [confirm] the final list of processors and ensure a data-processing agreement is in place with each.
Some of these providers may process data outside the European Economic Area. Where that happens, we rely on appropriate safeguards such as Standard Contractual Clauses. [confirm] the transfer mechanism for each provider.
6. How Long We Keep It
We keep application data for as long as necessary to manage the recruitment process and for a reasonable period afterwards in case a future opportunity arises, after which it is securely deleted. [confirm] the exact retention periods (for example, unsuccessful applications retained for 12 months, with consent to retain longer in a talent pool).
7. Your Rights
Under the GDPR you have the right to: access the personal data we hold about you; have inaccurate data corrected; have your data erased; restrict or object to processing; data portability; and, where processing is based on consent, to withdraw that consent at any time. To exercise any of these rights, contact us via our Contact page.
You also have the right to lodge a complaint with the Irish Data Protection Commission (dataprotection.ie) if you are unhappy with how we have handled your data.
8. Cookies
Cookies are small files placed on your device when you visit a website. Some are essential for the site to work; others are optional and only used with your consent. We use cookies to operate the site and to remember your consent choice, and, only if you accept, for anonymous usage analytics. We do not use cookies for advertising.
Strictly-necessary cookies cannot be switched off as the site cannot function without them. Non-essential (analytics) cookies are not set unless you accept in our cookie banner, and you can change your mind at any time by clearing your browser storage for this site.
Cookies we use:
- pe_session - Positive Equity (first-party). Maintains a logged-in staff/admin session. Strictly necessary. Session (up to 24 hours).
- pe_cookie_consent - Positive Equity (first-party). Remembers whether you accepted or declined non-essential cookies. Strictly necessary. Persistent (browser local storage).
- PostHog analytics - PostHog (EU region). Anonymous, aggregated usage analytics, only active after you accept. Analytics (non-essential). Up to 12 months.
[confirm] this list against a live audit of what the site actually sets, and update it whenever a new third-party tool is added.
9. Changes to This Policy
We may update this policy from time to time. Any changes take effect when published on this page, and we will update the last updated date above.
10. Contact
For any privacy-related request or question, please reach us through our Contact page.