Privacy Policy - XENO Automated Investment Management

Privacy Policy

Effective Date: May 29, 2017

Ensuring Your Privacy

Earning you trust is XENO’s to priority. The privacy of your information is essential to earning and keeping that trust. All the decision we make about how we gather, store, and use any information we obtain from you is driven by this principle. Your personal information will never be traded, rented, or sold to anyone.


XENO Investment Management (“XENO”, “we”, “us” and/or “our”) operates an Automated Investment Management Platform (“Platform”). The Platform is available on our website. This Privacy Policy details how XENO handles your personal information whenever you use our Platform.

Throughout this agreement, a Visitor refers to a person who uses our website to assess our Platform, or for purpose of gaining information. On the other hand, a Client is a person who signs our Client Agreement and sets up an investment account by XENO on our website. This Privacy Policy, the Terms of Use and where applicable Client Agreement collectively govern your use or assessment of our Platform.

Collection of Information

The types of information we collect depend on whether you are a Visitor or Client. We collect Personal Information from you when you voluntarily provide information to us. Examples of instances when we collect Personal Information include when you answer questions on our website to select your goal, determine your risk tolerance and the recommended investment portfolio if you were to become a Client. This information is collected whenever you are in the process of registering to open an investment account, when you contact us through the landing page or inside your account when you become a Client. At whatever point XENO collects Personal Information, we make sure to link to this Privacy Policy and other relevant documents, like the Terms of Use.

In General

XENO’s servers automatically record certain information about your activity on our Site. XENO records information the following information:

  • browsing activity,
  • data displayed or clicked on (such as UI elements, ads, and links),
  • such as browser type,
  • IP address,
  • date and time of access,
  • cookie ID, and
  • referral URL.

Together with cookies, XENO may use third-party tracking technology, for example Google Analytics, to record similar information regarding your use or assessment of our Platform.

Visitor Information Collected

In order to use our platform, we may collect certain personal information such as:

  • name,
  • address,
  • telephone number, and
  • email address

We also collect some information that you voluntarily provide such as:

  • age bracket,
  • investable assets,
  • financial goals and objectives,
  • income information, and
  • other critical financial planning information.

We may collect your name, e-mail address and/or telephone number should whenever choose to engage with us through our website, email or telephone.

Client Information Collected

Because investment management is a highly regulated industry, if you choose to become a Client, besides the information we collect from you as a Visitor, we will also collect information that includes, but is not limited to:

  • full legal name,
  • biographical information such as date of birth
  • contact information,
  • identification documents
  • citizenship and/or country of residence,
  • investment objectives,
  • net worth, and
  • other regulatory disclosures that are required under by the regulators and other government agencies.

Use of Information

The information that is taken from both Visitors and Clients by XENO is stored, processed, and maintained securely. It helps us to provide Client support, roll out innovative products or services and operate within the rules and regulations set by the Capital Markets Authority, Uganda Retirement Benefits Regulatory Authority, and other government agencies

Provision of the information is voluntary, however, if you decide not to provide the requisite information, you will most certainly not be able to use the full functionality of the Platform or even become a Client. Occasionally, we may share the information required to become a Client with third parties such as our custodian, trustee, and brokerage partners specifically to allow them provide services to you.

We may periodically use your Personal Information to relay certain critical information to you about our Platform. If you decide at any time that you do not wish to receive certain marketing information, use the “unsubscribe” steps included in every communication to cause this to stop. However, even when you unsubscribe from receiving marketing information, we will still send periodic administrative information such as billing and Platform notifications as well as obligatory regulatory notifications.

Sharing of Information and Exceptions

XENO does not sell, rent, or trade your personal information with any third parties other than with your consent or as required by law.

However, in order to efficiently provide our services and for our business operations, we may share your personal information with third parties, including but not limited to:

  • consumer identification verification services,
  • public accounting firms, and
  • certain other service providers (including companies that perform marketing and analytics services).

For any third parties we may share your information with, we have entered into agreements that require them to keep this information confidential. In addition, we may disclose your information to other third-party financial institutions, e.g., if you ask us to transfer your assets from XENO to such financial institutions.

We may also disclose personal information in response to service of legal process, such as court orders, summons, or subpoenas, or as permitted or required by law when we reasonably deem it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud (including identity theft), front-running or scalping, situations involving potential threats to the physical safety of any person, or suspected violations of our Privacy Policy, Terms of Use or other customer agreements.

Furthermore, we may disclose personal information in specific other cases with your express consent.

In order to provide workplace services to employers or plan sponsors, such as retirement savings plan services and recordkeeping services, we may exchange any information received in connection with such services with the employer or plan sponsor or others they may authorize. We may also share information, including but not limited to account positions, contributions, distributions, and Money Markets flows, with a third-party financial institution that serves as a directed trustee, or custodian bank.

You may request deletion of personal information by emailing and providing us enough information to identify your account and prove that you are the owner of the identified account. We will endeavor to make any deletion request effective as soon as reasonably practicable. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws. Under no circumstances will we share any personal information data unless lawfully required by courts of law, the regulators or other government agencies.

You may decline to provide personal information to XENO. Declining to provide personal information may disqualify you from accessing XENO services and Site features that require certain personal information.

How Your Personal Information is Protected

XENO works diligently to protect your personal information. We deploy several physical and electronic safeguards to keep your information safe and private. We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. For example, we limit access to your personal and financial information to only those employees with authorized access who need to know the information in order to perform their jobs, and we require third parties who perform services for XENO to agree to keep your information confidential.

Moreover, if you decide to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. Please note that, if you maintain a XENO account that you access through our website, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.

Accessing or Changing Personal Information Collected

Once you have registered with XENO, you can access your profile, review the information that is stored, and revise that information. If you have any problems, you may also contact us at Because of regulatory requirements, we do not delete residual copies of outdated information and must therefore preserve all customer data for a minimum of three years.

Other Important Information


XENO takes reasonable steps to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. No Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free so, please take special care in deciding what information you send to us in this manner.


We do not allow third-party advertising on our Website.

Social Media and Links to Other Web Sites and Apps: “Third Parties”

This Privacy Policy and these terms apply only to XENO operated services and applications. This Site may contain links that access other web sites and apps that are not operated or controlled by XENO. The policies described herein do not apply to Third Party websites or applications.


XENO is not to be used by anyone under the age of 18 and, as such does not knowingly collect Personal Information from anyone under the age of 18. If you are under the age of 18, please do not submit any Personal Information to XENO. If a parent or guardian becomes aware that his or her child under the age of 18 has provided us with personally identifiable information without his or her consent, he or she should contact us at and we will delete such information from our files.


By using and continuing to use the XENO website and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto.

This Privacy Policy may change from time to time. We will post any Privacy Policy changes and, if the changes are substantial, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). Each version of this Privacy Policy will be identified at the top of the page by its effective date.

This document constitutes XENO’s complete Privacy Policy for XENO and the Services

If you have questions or comments about this Privacy Policy, please email us at