This Privacy Policy, together with the Terms of
Service, governs the collection, processing, use and storage of your personal
data by TradeDigital.
TradeDigital is an online platform that
facilitates the trading of cryptocurrency-related products. In order to be able
to provide our services to you, we need to process certain data about you. We
take your privacy very seriously and will always process your personal data in
accordance with the guidelines of this Privacy Policy. You can also find
information about us, the platform and our legal basis to process your personal
data in this Privacy Policy. Any capitalized terms you may encounter are
defined in our Terms of Service.
1. Who does this Privacy Policy apply to?
This Privacy Policy applies to all visitors of the
Website www.TradeDigital.com, or users of the related APIs, that share personal
information with us. Whether you are a mere visitor of our Website, contact us
directly or submit personal information in another way, we will always process
your personal data in accordance with this Privacy Policy.
2. Who are we?
The Platform is made available by T3 Group SA, a corporation incorporated under the laws of Panama, registered at
the Panama Mercantile . T3 Group SA is the
controller for the processing of your personal data.
3. Which types of personal data do we process?
During your use of our Website and the Platform,
we may process the following personal data of you:
a. Personal data you provide when creating an
Account, which includes:
• Email address;
• Login details (username and password);
• Country of residence;
• Security details (two-factor authentication
token, app passcode).
b. Personal information we require to verify your
identity and comply with “Know Your Customer” and anti-money laundering
regulations, which information depends on the degree of the identity check to
be performed. If you register a personal Account, we may require you to provide
the following information in this respect:
• Name;
• Address;
• Bank account information, such as a bank account
statement;
• A copy/image of your passport, driver’s license
or ID card;
• Residency verification information (e.g. utility
bill, bank statement).
If you register an Account on behalf of a
registered entity (corporate Account), we require the following personal data
to verify your Account:
• Your full name;
• The statutory name and any deviating trade names
of the entity;
• The company address registered with Chamber of
Commerce;
• A valid business incorporation document (from
the Chamber of Commerce and/or Financial Services Commission);
• URL of government website containing your
company details that verifies the authenticity of the registration;
• A Certificate of incorporation;
• Memorandum and Articles of Association
(containing the structure and rules of the company);
• Sources of funding;
• Register of shareholders/partners/members
(complete list of names, addresses and number of shares of every current
shareholder);
• Ownership structure chart showing the
percentages of each shareholder, the ultimate beneficial owner(s) and the
countries of residence/incorporation;
• List of full names and ownership percentages of
shareholders who own 25% or more of the shares in the company;
• ID and a recent proof of residential address of
all shareholders who own 25% or more of the shares in the company;
• List of full names, date of birth, address
details of all directors;
• ID and a recent proof of residential address of
all directors;
• List of individuals who are allowed to trade on
the Platform;
• ID and a recent proof of residential address of
all individuals who will trade on the platform of TradeDigital.
c. In order to facilitate your trading of Products
on our Platform, we require the following information:
• The address of your wallet from which you
deposit/withdraw Cryptocurrency into/from your Account;
• Your orders, trades, positions and balances.
d. Information related to communication between
you and us:
• Name;
• Email address; and
• Details of your request and/or complaint and
other information you provide us with in the course of the communication
session.
e. Information you provide us with when you visit
our Website and use our Platform:
• Login records;
• A unique token of your browser session;
• IP address;
• Information about your device, browser,
operating system, and network system;
• Viewing time and online behaviour on the
Platform.
4. For which purposes do we process your personal
data?
We may use your personal data to:
• Create and administer your Account;
• Give you access to our Platform and to provide
our services;
• Verify your identity and to comply with
applicable laws and regulations in that respect;
• Cooperate with requests of law enforcement
agencies;
• Process your trades;
• Analyse your use of our Website and Platform;
• Provide you customer support;
• Send you updates, newsletters, surveys or
promotions;
• Contact you about other aspects of our services.
We will not process your personal data for other
purposes.
5. Which legal grounds apply to our processing of
personal data?
We are entitled to process your personal data
pursuant to different legal grounds. The following table contains an overview
of the legal grounds we invoke to process specific personal data:
Processing activity Legal ground
Creating your account Performance of a contract
Verifying your (company’s) identity (KYC/CDD)
Compliance with a legal obligation
Marketing activities (promotional communication)
Consent (which you can revoke at any time)
Trading facilitation Performance of a contract
Communication details to handle enquiries
Performance of a contract
Browsing information or sharing with law
enforcement Our legitimate interests
6. How long do we retain your personal data?
We will not retain your personal data longer than
necessary for the purposes for which we have obtained such data. In principle,
we may retain your personal data up to a maximum of three (3) years upon the
ending of our business relationship.
We will not delete your personal data if we are
required to retain such data to comply with any statutory obligation. In
particular, we reserve our rights to retain the information to verify your
identity for a period of at least five (5) years. In addition, we may retain
personal data that are necessary for the purposes of legal proceedings, complaints
and disputes for as long as this is necessary to protect our legitimate
interests.
7. Who has access to your personal data?
Our authorised personnel shall have access to your
personal data on a need-to-know basis. These persons have undergone background
screening before they were employed and are required to treat the information
as highly confidential.
In addition, we may engage third-party service
providers to provide ancillary services. If and to the extent such parties will
come into the possession of your personal data, such parties will act as our
data processor. These are, for example, cloud service providers and suppliers
of certain software solutions. We will enter into a data processing agreement
with these parties, which shall include arrangements on data security to
protect your personal data against data breaches. Such data processors will
only process your personal data to the extent required for the provision of
services for which they are engaged.
We may also share personal data with affiliates
who referred you to our Website, and partners for promotions or co-branded
service integrations.
We may provide your personal data to competent
authorities upon their request to the extent legally required or to the extent
necessary to defend our rights in legal proceedings or investigations.
8. Will your personal data be transferred to
countries outside the European Economic Area?
Our third-party service providers may be located
in countries outside the European Economic Area (EEA), which may not offer an
adequate level of protection of personal data. In order to protect your
personal data and to live up with our obligations, we shall enter into a data
transfer agreement on the basis of the Standard Contractual Clauses as approved
by the European Commission prior to engaging service providers outside the EEA.
9. Is your personal data secure?
We process your personal data with the greatest
possible care and scrutiny. This means we will adopt appropriate technical and
organisational measures to ensure that all the information is correct, current
and complete and to prevent it from being accessed by unauthorised persons
inside and outside our organisation. We use ‘best practices’ to secure your
personal data. For instance, your personal data is encrypted with Secure
Sockets Layered (SSL) technology and our directories and databases are password
protected.
10. What are your rights in respect of my personal
data?
You are entitled to ask us if we are processing
your personal data. You may at any time, with reasonable intervals, exercise
your right of access to your personal data. Upon your inspection, you may
request us to rectify or erase any (inaccurate) information or have us restrict
or terminate the processing of your personal data. However, we reserve our
right to deny such a request to restrict or terminate the processing of your
personal data if we have a legitimate interest to continue the processing of
your personal data, in particular, if we require the information in (possible)
legal proceedings.
You are entitled to request us to transfer
(certain of) your personal data to you or to another party.
If your personal data is being processed based on
your consent, you may withdraw your consent at any time. In order to exercise
this right and the rights as mentioned above please contact us using the
contact information set out in this Privacy Policy.
11. Use of Cookies
We use cookies when you visit our Website and use
our Platform. A cookie is a small file that is saved on your computer, tablet
or mobile phone when viewing a website. With the help of cookies user
preferences may be saved for later use, or browsing habits can be tracked for
statistical purposes. A lot of improvements in a website’s user experience and
performance are possible thanks to the implementation of cookies.
We use the following cookies:
• Functional cookies to enable your use of our
Website and Platform, and clear gifs in our emails so that we can check the
receipt of our emails;
• Analytical cookies to show us which pages you
visited and clicked on within our Website. We use the web statistics of this
behaviour to improve our services, and more specifically our search results.
The collected data through cookies - including IP addresses – remain anonymous
but can be stored by Google on servers in the United States. Read more about
Google’s Privacy Policy here: https://www.google.com/policies/privacy/;
These cookies are saved until you delete them in
your Internet browser. You can block the use of cookies by changing the
settings in your browser. This may, however, limit your user experience. More
information on enabling, disabling and deleting cookies can be found in the
Help-function of your browser.
12. How can I file a complaint?
If you have complaints about how we handle your
personal data, you can contact us using the contact details in this Privacy
Policy. We are happy to help you find a solution. In addition, you may file a
complaint about the way we process your personal data with the supervisory
authority in the country where you are resident (where applicable).
13. Questions?
If you have any questions concerning the manner in
which we process your personal data, or you wish to invoke any of your
statutory rights, you may contact us via the email address provided on the
“Contact Us” page on our Website.
We may update this Privacy Policy from time to
time. We will inform you when we make changes to our Privacy Policy and you can
always find the most recent version of the Privacy Policy on www.TradeDigital.com.
Effective Date: 12-Apr-2023
Last Updated: 12-Apr-2023
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