With this privacy policy, we are explaining what data and information we may collect from you and how we may use that information.

Please read this privacy policy and associated notices so that you are fully aware of how and why we are using your data. This privacy policy is in addition to the other privacy notices and is not intended to override them. If you provide personal information to us about other individuals, we will process such information in accordance with this privacy policy.

How to contact us?

Our Data Protection Officer (“DPO”) is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Email: support@mytradewin.com

If you wish to contact us to make a complaint about how we handle your personal data, you can do so through our Data Protection email (whose contact details are above).

What if this Policy changes?

This policy was last updated on the date shown at the bottom of the document. We will only use your personal data for the purposes for which we collected it or for reasons which we believe are compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO using the contact details provided.

We reserve the right to make changes to this policy from time to time, and we will do that without notifying you. If you enter our website, it means you have read all updated policies. However, if we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis, which allows us to do so.

Please note that we will not process your personal data without your knowledge or consent unless this is required or permitted by law. In such cases, we will do so only in compliance with the law. Please notify us if the personal data we hold about you is not accurate and current.

What data has been collected?

Personal data, or personal information, means any information which can be used to identify an individual. It includes pseudonyms such as unique identifiers (e.g. client, name, address, or any other identification) but excludes data from which a person cannot be identified (anonymised data). The data that are being collected are your username, the date of entering into business cooperation with you, as well as your email address.

The information that we collect will depend on your relationship with us.

Our website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

We will always ensure a high degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by our regulator.

Please contact the DPO if you want further information on the specifics regarding your personal data.

How long will we collect and keep the data?

We will only retain your personal data for as long as reasonably necessary to fulfil the relevant purposes set out in this privacy notice and to satisfy our legal, statutory, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements, but not longer than 5 years.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

How will we protect your data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. Also, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

What are the Client’s rights?

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify the accuracy of the new data you provide to us.

What is the Request erasure of a client’s personal data?

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

What is the time limit to respond?

We shall respond to all legitimate requests within one month unless your request is particularly complex or you have made several requests. In this case, we will notify you, keep you updated, and may take longer to respond.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your personal data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You may receive marketing communications from us if you have given us your contact details when signing up for a service from us, and by using our services and entering into business cooperation with us, you agree with everything abovementioned.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Besides, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

Effective date 01st February 2024