Privacy Policy
This Privacy Policy is effective as of December 21, 2021.
1. INTRODUCTION
TradeQ Technology Capital Partners offers software as a service that allows users to manage their cryptocurrency holdings across multiple accounts, including SmartTrade Terminal and automated Trading Bots. This Privacy Statement explains how TradeQ Technology Capital Partners, e-mail [email protected] ("Tradeqs," "our," "we," or "us"), as the personal data controller, collects and processes your ("you") personal data when you visit the website. https://tradeqs.com/ (“Website”) as well as the provision of the Software If you are the Signals Provider, please read our Signals Provider Privacy Notice.
Unless otherwise specified, capitalised terms in this Privacy Policy have the meanings given to them in the Terms of Use..
2. DATA WE COLLECT
We have set out in the table below the categories of personal data we collect and use about you:
Category of personal data |
Data collected |
|
|---|---|---|
When you visit our Website or contact with us |
Technical Data |
When you visit our Website, we process technical data about your visit, such as your IP address, location data (down to the city level), access-provider, referring URL, date, time, access tokens, session key, browser type and version, browser language, operating system, and the amount and state of transferred data. Because this information can be linked to you, Personal Identification Information may be processed as well. These data can also be used to generate anonymized statistical reports. |
Cookie Data |
We use cookies on the Website to improve its performance and functionality. Cookies may collect personal information about you. Please read our Cookie Policy to learn more about the cookies we use. |
|
Communication Data |
We process, in addition to Personal Identification Information (limited in case of contacting via social media), the contents of your message if you interact with us via our Website live chat, e-mails, and sign-up forms, Tradeqs Facebook page, Youtube channel, Twitter page, Telegram, or any other official social media account. |
|
When you use the Software |
Personal Identification Information |
Name, e-mail address, 2FA key, IP address, token, language,if you choose to sign up via Facebook, we collect your Facebook UID, Facebook profile name, Facebook e-mail |
The personal data we process is collected from one of the following sources:
- the data is disclosed by you directly to us;
- we receive the data from your Exchange Account provider due to you connecting your Exchange Accounts to the Client Account;
- we receive the data from social media service provider due to you registering or contacting with us via your existing social media account;
- we receive the data from the payment service provider due to you concluding the Purchase Agreement and paying for the Subscription;
- we receive Technical Data automatically from your browser, our servers and systems;
3. What we use your personal data for
We have set out in the table below the reasons why we process your personal data:
Purpose for processing |
Category of personal data processed |
Legal basis |
|
|---|---|---|---|
Client authentication |
Personal Identification Information |
Performance of the Terms of Use |
|
Enabling the Software and its functionalities |
Personal Identification Information, Financial and Transaction Data |
Performance of the Terms of Use and if relevant performance of the Purchase Agreement |
|
Sending newsletters to your e-mail |
Personal Identification Information |
Consent |
|
Providing you with notifications via your chosen channel (for example, mobile app, e-mail, Website, Telegram Bot) |
Personal Identification Information |
Consent given for the specific notification channel |
|
Direct marketing campaigns - Client marketing campaigns in relation to the Software, its functionalities and products already provided to you |
Personal Identification Information, Financial and Transaction Data (mainly the transaction activity) |
Our legitimate interest in providing you with information relating to the services and products you have previously sourced from us |
|
Processing data for predictive analytics and insights, improvement and development of the Software |
All of the data categories indicated in Section 2 above |
Our legitimate interest in improving and developing the Website and the Software within the course of our business activities or performance of the Terms of Use |
|
Diagnosing and repairing technical issues related to the Software and the Website |
Technical Data |
Our legitimate interest in providing data security and preventing fraudulent actions related to the Software and the Website; ensuring the functioning of the Software and the Website |
|
Storing information containing personal data in backup systems |
All of the data categories indicated in Section 2 above |
Our legitimate interest in ensuring the security of data processing operations |
|
Data disclosures to potential acquirers of Tradeqs business, including legal advisors, auditing service providers in case of a merger, acquisition or selling the whole or part of our business |
All of the data categories indicated in Section 2 above |
Our legitimate interest in ensuring proper due diligence process and business continuity |
|
Data disclosures to our service providers |
All of the data categories indicated in Section 2 above |
Our legitimate interest in utilising the information technology infrastructure and services provided by our co-operation partners |
|
Mandatory disclosures to law enforcement and data protection authorities |
All of the data categories indicated in Section 2 above |
Performance of our legal obligation |
|
Client identity verification (KYC) for recovery |
Personal Identification Information |
Performance of the Terms of Use |
|
Client’s transaction history |
Financial and Transaction data |
Performance of the Terms of Use |
|
Responding to your enquiries and requests submitted via the website, sign-up forms, live chat or e-mail or any social media platforms |
Communication Data, however, depending on the nature of your enquiry we can process all the data indicated in Section 2 above |
In case your question clearly relates to matters connected to the Terms of Use, Client Agreement or Purchase Agreement we process the data for the performance of the Contract. In other cases, we rely on our legitimate interests in ensuring effective relations management with all the interested parties in our Software and services |
|
Client invoicing for the Purchase Agreement or for mediating your payments to Signals Providers (no personal data are shared with Signals Providers) |
Personal Identification Information, Financial and Transaction Data |
Performance of the Purchase Agreement or our legitimate interest in performing the Signaller Agreement concluded with the Signals Provider |
|
Transfer of funds from a payment service provider to your Client Account and making out payments upon your withdrawal request via payment service provider |
Financial and Transaction Data, Personal Identification Information |
Performance of the Terms of Use |
|
Determining your location for designating applicable VAT rate |
Personal Identification Information |
Performance of the Purchase Agreement |
|
Handling the refunds related to Purchase Agreement |
Personal Identification Information, Financial and Transaction Data, Communication Data |
Performance of the Purchase Agreement or in certain situations performance of our legal obligation |
|
Enabling your use of the Trial |
Personal Identification Information |
Performance of the Trial Terms |
We may process your personal data for other purposes, provided that we disclose the purposes and use to you at the relevant time, and that you either consent to the proposed use of the personal data, other legal grounds exist for the new processing purposes or the new purpose is compatible with the original purpose brought out above.
4. SHARING YOUR PERSONAL DATA
Your information will not be made public or shared with other Website visitors or clients. Tradeqs workers have access to personal data to the extent that it is required for the fulfilment of their job tasks.
To help us provide our service, we use third-party processors and distinct data controllers. They will only have access to your personal data as long as it is reasonably necessary for them to execute these duties on our behalf, and they will be obligated not to disclose or use it for any other purpose.
5. ENSURING THE SECURITY OF PERSONAL DATA
We have implemented the appropriate technical and organisational security measures to safeguard your personal information against unintentional or unlawful destruction, loss, or alteration, as well as unauthorised disclosure, abuse, or other processing in violation of applicable legislation. We also advise you to take steps to protect your personal information. We strongly advise you not to share your personal data with us or any of our partners via public forums or other public channels unless you understand and agree that the data will be publicly accessible.
6. RETENTION AND DELETION OF PERSONAL DATA
Your personal data (all data types listed in Section 2) will be maintained for as long as it is reasonably necessary to achieve the goals outlined in Section 3 above, or until we are required by law to do so. 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 processing purposes and whether we can achieve these purposes through other means, and applicable statutory obligations when determining the appropriate retention period for personal data. We consider the viable need to resolve disputes and enforce the contract between us while retaining personal data, or we anonymize your personal data and retain this anonymized information indefinitely.
After the expiry of the retention period determined above or the termination of the legal basis for processing purpose, we may retain the materials containing the personal data in the backup systems, from which the respective materials will be deleted after the end of the backup cycle. We ensure that during the backup period appropriate safeguards are applied and the backed-up materials are put beyond use.
7. YOUR RIGHTS AND PREFERENCES
Under data protection law, you have rights including:
- Right to be informed and to access. You may get information regarding your personal data processed by us.
- Right to data portability. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. Moreover, you may request that the personal data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible.
- Right to erasure. You the right to have personal data we process about you erased from our systems if the personal data are no longer necessary for the related purposes.
- Right to object and restrict. You have the right to object to the processing of your personal data and restrict it in certain cases.
- Right to rectification. You have the right to make corrections to your personal data.
- Right to withdraw consent. When you have given us consent to process your personal data, you may withdraw said consent at any time.
To exercise any of the abovementioned rights, please contact our customer support team via e-mail indicated in Section 8 below.
Please note that in case you are requesting to use the above described rights or any other rights related to our services, on someone elses name (legal representative, close relative of deceased customer etc), we have the right to ask additional information from you to prove the authorization for such request (signed authorization from customer, requestor ID, death certificate etc.).
Such additional information is required to protect our customers’ personal data and financial interests.
8. OTHER IMPORTANT INFORMATION
Newsletter, notifications and direct marketing campaigns
You may be subjected to direct marketing campaigns, get our newsletter, or receive notifications if you give us your explicit approval. You can change your account settings to opt out of direct marketing campaigns, newsletters, and notifications. Unless you have requested not to receive such information, we may send you news, special offers, and general information about other items, services, and events that we offer that are comparable to those that you have already purchased or inquired about.
Please keep in mind that email marketing messages contain an opt-out feature within the message (e.g. an unsubscribe link in the emails we send to you). If you click the link in an email, you will be removed from further notifications in that category. The Account Settings page allows you to make decisions regarding all types of email and push marketing communication.
Dispute resolution
Please email us at [email protected] if you have any questions. Disputes about the processing of personal data are resolved by our customer service team. This Privacy Policy may be amended or modified from time to time to reflect changes in the way we process personal data. We will tell you if there are any substantial changes, as required by applicable laws.
Age limitations
We do not knowingly collect any information from individuals under 18 years of age. If we discover a user of being younger than 18 years old we will require the user to close their account and we will take steps to delete any collected information as soon as possible.
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