As part of our effort to improve Traders performance through our new innovative idea, ZISHI Elite collects and processes personal data relating to Traders. The organisation is committed to being transparent about how it collects and uses that data and to meet its data protection obligations.


What information do we collect?

ZISHI Elite collects a range of information about you. This includes: Your name, address and contact details, including email address, telephone number and phone IMEI number. Heart rate, heart rate variability, sleep quantity and quality, mood, mentality, trader’s daily volume and PNL, Traders order activity and Trading performance. ZISHI Elite may collect this information in a variety of ways. For example, data might be contained in application forms, through interviews, questionnaire or other forms of assessment. Also by using Polar H10 device (or a similar device) to capture HR & HRV. Data will be stored in a range of different places, including on your Polar H10 device (or similar device), ZISHI Elite App, management systems and on other IT systems (including email).


Why does ZISHI Elite process personal data?

The objective is to assess the impact of trading on stress and energy, health and well-being and the subsequent impact of that stress and low energy on trading decisions and performance. The process involved measuring the trader’s physiological states using Heart Rate Variability (HRV) data and traders basic lifestyle factors, such as sleep, physical activity, mood etc. As part of this process, we will collect your personal data, which will be analysed and used to help determine correlation between the above variables and Trader’s performance, thereby highlighting Trader’s optimal performance zones. It also aims to help support traders in the area of wellness. Under no circumstance will data from ZISHI Elite be used in any form of performance review by managers.


Lawful Basis for processing your data

ZISHI Elite relies on your consent and explicitly, in some instance to process your personal data for the purpose stated above. You do not have to provide your consent and you can withdraw your consent at any time. ZISHI Elite also has a legitimate interest in processing some personal data and for keeping records of the process. We may also need to process data from participants to respond to and defend against legal claims.


If consent is not provided

If you do not provide your consent for ZISHI Elite to process your personal data for a specific service that is offered under the lawful basis of your consent then we might not be able to provide that service to you in full.


The right to withdraw consent

Where the ZISHI Elite is relying on your consent to process your personal data, you have the right to withdraw your consent at any time. If you are unsure how to withdraw your consent, please contact: Data Protection Officer at


Who has access to data?

Your information may be shared internally for administration purposes. This includes members of the ZISHI Elite team, Application developers, Office managers and IT staff if access to the data is necessary for the performance of their roles. Your anonymised information will also be shared with third parties like Bangor University Professors to conduct analysis to determine correlation between variables and Trader’s performance. Under no circumstance will your data be sold or shared with any parties who are external to the company or project other than those listed above.


How does ZISHI Elite protect data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Where we have need to share your data with third party organisations, we ensure it is fully anonymised and transferred via secure transmission methods.


For how long does ZISHI Elite keep data?

The periods for which your data will be held is stated in our retention schedule, which is available on request.


Your rights:

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require the organisation to change incorrect or incomplete data;
  • require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing and;
  • object to the processing of your data where ZISHI Elite is relying on its legitimate interests as the legal ground for processing

If you would like to exercise any of these rights, please contact Data Protection Officer at If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.


What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to ZISHI Elite during the process. However, if you do not provide the information required, we may not be able to process your information for the purpose properly or at all.