TradrAPI Privacy Notice

Last update: August 27th, 2024 | Version: 1.1

1. Scope

2. Data Collection

3. Data Usage

4. Legal Basis for Processing Personal Data

5. Disclosure of Personal Data

6. Third-Party Sites

7. Social Login

8. Mobile Device Information

9. User Forum

10. Retention

11. Data Security

12. Your Rights under the General Data Protection Regulation (“GDPR”)

13. Your Rights under the California Consumer Privacy Act (“CCPA”)

14. Cookies

15. Amendments to TradrAPI's Privacy Notice

16. Contact Details

Scope
1. This Privacy Notice (“Notice”) aims to give you information on how we collect and process your Personal Data through or in conjunction with your use of this website and our services.
2. This Notice stipulates details and conditions of collecting and processing your personal details and provides you with information in accordance with the transparency principle and requirements under the applicable data protection laws.
3. This Notice delineates the methods by which we acquire and handle your Personal Data via the digital interfaces and software programs associated with this Privacy Notification.
4. TradrAPI is the controller¹ responsible for your Personal Data (referred to as “we”, “us”, “our”, and “Company” in this Privacy Notice).
5. The https://tradrapi.com (the “Site”) is not intended for children and we do not knowingly collect data relating to children (below 18 years of age).
6. By using our website, you consent to the data practices described in this Notice and all extensions and addendums to this Notice.
Data Collection
1. In accordance with the information we gather pertaining to our users: Personal Data means any information that identifies you as an individual or that relates to an identifiable individual. Whenever it is not possible or feasible for us to make use of anonymous and/or anonymized data (in a manner that does not identify any users of the Site or customers of our services), we are nevertheless committed to protecting your privacy and the security of your Personal Data at all times.
2. Data obtained from you: We collect from you, through interaction with you or through your interaction with us or our services different kinds of Personal Data about you which we have grouped together as follows:
  1. Account Opening and Client Services: TradrAPI collects Personal Data when individuals open brokerage or digital asset accounts and when providing client services.
  2. User Registrations and Engagements: Personal Data is collected when users register for job opportunities, create user profiles, subscribe to newsletters, or participate in public forums on TradrAPI's websites.
  3. Types of Collected Personal Data: The Personal Data collected may include but is not limited to:
    1. Full Name;
    2. Contact details;
    3. Address;
    4. Investment profile;
    5. Background information for job applications.
  4. Automatic Collection Through Tracking Technologies: Information about the devices used to access TradrAPI's websites is automatically collected. This includes:
    1. IP address;
    2. Device identifier;
    3. Web browser details;
    4. Browsing details through cookies and other tracking technologies.
  5. Third-party Data Sources: TradrAPI may obtain Personal Data from third-party sources, which may include:
    1. Demographic information;
    2. Professional information – This data may be obtained from data brokers or publicly available online sources.
  6. Data Merging and Analytics: When necessary and in compliance with applicable laws, TradrAPI may merge this data with existing information for purposes such as benchmarking and market data analytics.
Data Usage
1. At TradrAPI, we prioritize the protection and respectful handling of your Personal Data. This section outlines how we utilize the information we collect from you through our website and services. By accessing or using our platform, you consent to the data practices described herein.
2. Purposes of Personal Data Usage. We may collect and use Personal Data² for the following purposes:
  1. Opening and managing accounts: Your personal information is necessary to establish and maintain your account on our platform.
  2. Processing fund transfers and withdrawals: We may utilize your data to facilitate financial transactions and withdrawals as per your instructions.
  3. Improving services and website functionality: Your feedback and usage patterns help us enhance our services and optimize website performance.
  4. Distributing newsletters and alerts: With your consent, we send newsletters and alerts to keep you informed about updates and relevant information.
  5. Recruitment and evaluation of job applicants: For recruitment purposes, we may collect and assess personal data submitted by job applicants.
  6. Analyzing website performance: We may analyze user behavior and website interactions to improve user experience and functionality.
  7. Preventing fraud and enforcing terms and conditions: Personal Data is utilized to detect and prevent fraudulent activities and ensure compliance with our terms and conditions.
  8. Complying with legal obligations: We may process Personal Data to fulfill legal requirements and obligations.
  9. Executing TradrAPI agreements: Personal Data may be used to execute agreements between TradrAPI and its users or partners.
3. Necessity of Personal Data. The collection and processing of Personal Data are justified by the following reasons:
  1. Essential for website operation and client services: Certain Personal Data is essential for providing you with access to our platform and delivering our services effectively.
  2. Used for providing market data products: We may use your data to provide you with market data services or similar offerings.
  3. Analyzed for personalized content and services: In instances where analysis of your Personal Data is conducted, such action assists us in tailoring our content and services to better align with your preferences and needs.
  4. Retained for future communication purposes: We may retain your data to communicate with you regarding your account, updates and relevant information.³
4. Use of Cookies and Tracking Technologies. We utilize cookies and tracking technologies for the following purposes:
  1. Website management and analytics: Cookies help us manage website operations and analyze user behavior to improve our services.
  2. Monitoring user interactions: We may use cookies to monitor how users interact with our website and services to enhance user experience.
  3. Tracking links opened or interacted with in communications: Cookies may be used to track links opened or interacted with in communications sent to you.⁴
5. User Privacy Measures. We are committed to safeguarding your privacy and uphold the following measures:
  1. Does not track users across third-party websites: We do not track your activities across third-party websites.
  2. Does not alter data collection practices based on “do not track” signals: We maintain consistent data collection practices regardless of ”do not track” signals.
  3. Prioritizes user privacy and adheres to stated data usage practices: Your privacy is paramount, and we adhere to the data usage practices outlined in this Privacy Notice.

Legal Basis for Processing Personal Data

This Section outlines the legal framework that governs the processing of Personal Data by TradrAPI:
1. Legitimate Interest: We may process your Personal Data based on our legitimate interest in promoting and safeguarding TradrAPI. This includes fostering and managing relationships, recruitment activities and delivering our services effectively.
2. Consent: With your explicit consent, we may utilize your data for various purposes, such as creating user profiles, sending newsletters or alerts, and for business-related enhancements to your website experience.
3. Performance of Contract: Processing of your data may occur to fulfill our contractual obligations to provide you with our services. This ensures the performance and delivery of agreed-upon terms between you and TradrAPI.
4. Legal Compliance: In certain instances, we may process your data to comply with legal requirements, including fulfilling our legal obligations.

We have set out below a description of the possible ways we plan to use your Personal Data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.⁵

Purpose	Data Category	Legal Basis
To register you as a new user; to identify you and verify you when you access your account to allow you to participate in services accordingly with the T&Cs	- Registration Data - Contact Data - Log-in Data	- Performance of the contract
To allow your participation in the services	- Usage Data	- Performance of the contract
To manage our relationship with you, to provide you with access to services and any ancillary products	- Registration Data - Contact Data - Profile Data - Other Communication Data - Usage Data	- Performance of the contract - Compliance with legal obligations
To establish and investigate any suspicious behaviour in order to protect our business from any risk and fraud	- Registration Data - Contact Data - Log in Data - Other Communication Data	- Legitimate interest (detection and prevention of fraud)
Direct Marketing of our own goods and services – including bonuses and offers	- Marketing Communication Data	- Legitimate interest (to promote our own service, to develop our business and enhance relationship) - Consent
Social Media Marketing	- Contact Data	- Legitimate interest (to promote our own service, to develop our business and enhance relationship) - Consent
Commercial business analyses for the creation of standards, periodical as well as ad hoc reports	- Usage Data - Analytics Data	- Legitimate interest (to develop our products/services and grow our business)
Web Analytics	- Usage Data - Analytics Data	- Legitimate interest (to develop our products/services and grow our business)

Direct Marketing – In compliance with relevant laws and regulations and through a legitimate interest or with your consent, TradrAPI may periodically notify you about similar products or services. This includes but is not limited to, new services and promotions, bonuses and offers. This notification may be conveyed through (i) electronic email (or SMS), or (ii) social media, or (iii) live phone calls, or (iv) push notification (desktop and/or app).
When relying on legitimate interest, TradrAPI will give you the opportunity to oppose such direct marketing when registering on our Site.
When relying on consent, the consent may be granted by you when registering on our Site.⁶

Disclosure of Personal Data
1. At TradrAPI, we prioritize the protection and confidentiality of your Personal Data. It is imperative for us to transparently communicate how your information may be disclosed and transferred, especially on an international scale. Below, we delineate the protocols and safeguards in place:
  1. Recipient Identification: TradrAPI reserves the right to transfer Personal Data globally to subsidiaries, affiliates and third-party service providers. Such transfers are conducted with the utmost care and adherence to data protection standards.
  2. International Data Transfer Protocols: Safeguards are implemented to ensure the security and integrity of your data, particularly during international transfers. These measures encompass encryption, pseudonymization and contractual agreements with recipients to uphold data protection standards.
  3. Consent and Legal Obligations: Your Personal Data will not be shared with third parties without explicit consent, except where mandated by law. TradrAPI complies with legal requirements and only discloses information when necessary for legal proceedings, law enforcement purposes, or governmental requests.
  4. Privacy Notice Adherence: Third-party service providers engaged by TradrAPI are contractually bound to uphold our Privacy Notice and adhere to data protection standards in their handling of Personal Data.
  5. Legal Compliance: TradrAPI may disclose Personal Data if required by law, law enforcement agencies, or government officials. Additionally, information may be shared to prevent harm, illegal activities, enforce Terms and Conditions, or support corporate functions in accordance with applicable laws and regulations.
  6. Recipient Notification: In cases where data rectification, deletion, or processing limitation is requested by individuals, TradrAPI will notify relevant third-party recipients to ensure compliance with such requests.
  7. Business Transition: In the event of re-organization, merger, or sale, Personal Data may be disclosed or transferred as part of the business transition process. TradrAPI will take appropriate measures to safeguard the confidentiality and integrity of your information throughout such transitions.
2. By availing our services or accessing our platform, you acknowledge and consent to the disclosure and transfer of your Personal Data as outlined in this Section.
Third-Party Sites
1. TradrAPI provides links to external websites or information as a service. Clicking these links redirects users away from TradrAPI's site.
2. It is important to note that TradrAPI neither endorses nor sponsors these third parties or their sites.
3. Users are solely responsible for their use of these external links, which is subject to the terms and privacy notices of the respective third-party websites.
Social Login
1. When users opt to access our platform via Google, Facebook, Apple etc. Identity Provider they initiate an authentication sequence overseen by this external entity. Throughout this sequence, Google, Facebook, Apple etc. Identity Provider undertakes requisite verification protocols to establish and validate the user's identity. Upon successful validation, a security token is generated, encapsulating vital user particulars like name and email address. Critically, this security token undergoes digital signing by the respective Identity Provider, ensuring the veracity and integrity of the enclosed data.
2. In the role of service provider, we play a role in the federated single sign-on process. Our validation of the signature affixed to the security token affirms its legitimacy. Subsequent to validation, the user's identity information within the token is harnessed to create a secure and authenticated session within our platform. Consequently, ongoing access to our services subsequent to the initial authentication obviates the need for recurrent submission of login credentials.
3. The crafting of this federated single sign-on proficiency aims to enhance user convenience while maintaining the necessary security protocols. Seamless utilization of existing credentials from Google, Facebook, Apple etc. Identity Provider grants effortless access to our platform, thereby enhancing the overall user experience.
4. Users should be aware that by utilizing our services, certain information may be accessed through this process. Such information may include but is not limited to email addresses, names, profile pictures, genders and locations. TradrAPI adheres to the terms of the respective social network platforms and their privacy policies when handling this data.
5. Users retain control over their data sharing preferences through the privacy settings provided by the social network platforms they engage with. To disconnect a social media account, users are advised to consult the settings available within the respective social network account and its provider.⁷
Mobile Device Information
1. TradrAPI relies on trusted third-party service providers for in-depth analysis of mobile applications. This analysis aims to optimize performance, track usage patterns, and promptly rectify any errors detected within mobile applications.
2. Reports generated encompass aggregate usage data, browsing patterns, device information and details on application errors.
User Forums
1. When engaging in user forums on this Site, please be aware that any information you share may be accessed and used by other individuals.
2. TradrAPI cannot be held responsible for the actions or policies of third parties who collect and utilize data that users publicly disclose on the website forums.
3. We encourage users to exercise caution and discretion when sharing personal or sensitive information in these forums.
Retention
1. We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
2. The criteria we use to determine what is ‘necessary’ depends on the nature of the particular Personal Data in question. Our normal practice is to determine whether there is/are any law(s) (for example license requirement, tax or corporate laws, etc.) permitting or even obliging us to keep certain Personal Data for a period of time (in which case we will keep the Personal Data for the maximum period indicated by any such law) and if not, whether there are any laws and/or contractual provisions that may be invoked against us by you and/or third parties and if so, what the prescriptive periods for such actions are. In the latter case, we will keep any relevant Personal Data that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you and/or third parties.
3. Where your Personal Data is no longer required by us, we will either securely delete or anonymize the Personal Data in question.
Data Security
1. We have implemented security measures to safeguard your Personal Data from accidental loss, unauthorized access, alteration or disclosure. To comply with the law, we employ industry-standard encryption techniques to encrypt data during transit and at rest, ensuring confidentiality and integrity at all times.
2. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a need to know business requirement. They will only process your Personal Data on our instructions or subject to a lawful ground, as well as their duty of confidentiality.
3. TradrAPI cannot provide absolute assurance of safeguarding against unauthorized access or breaches. In the event of a data breach, TradrAPI will conduct a thorough risk assessment and notify impacted individuals in accordance with applicable local laws.
Your Rights under the General Data Protection Regulation (“GDPR”)
1. In accordance with the EU and UK GDPR, you have the right to request confirmation from us regarding the processing of your Personal Data and we will provide you with access to the following information with reasonable intervals:
  - what Personal Data we have about you;
  - the reasons why we are processing your data;
  - the recipients to whom your data may have been disclosed;
  - the duration for which we intend to keep your data (if possible);
  - whether we transfer your data and the safeguards we have to protect your data;
  - your rights with respect to your Personal Data;
  - the process for making a complaint;
  - the source of your Personal Data;
  - whether we have used any automated decision-making or profiling and any related information.
2. Right to Rectification – Although all reasonable efforts will be made to keep your Personal Data updated, you are kindly requested to inform us of any changes. With respect to your residential address and phone number, you can notify us of the change by amending your profile of any changes to your personal data. If the change pertains to data that cannot be amended by changing your profile, please contact us. To this end you have the right to ask us to rectify inaccurate Personal Data and to complete incomplete Personal Data concerning you. We may seek to verify the accuracy of the data before rectifying it.
3. Right to Erasure – You have the right to ask us to delete your Personal Data and we shall comply without undue delay but only where:
  - the Personal Data are no longer necessary for the purposes for which they were collected; or
  - you have withdrawn your consent (in those instances where we process on the basis of consent) and we have no other legal ground to process your personal data; or
  - you have successfully exercised your right to object (as explained below); or
  - your Personal Data have been processed unlawfully; or
  - there exists a legal obligation to erase the data to which we are subject.
4. Right to Data Restriction – You have the right to ask us to restrict (that is, store but not further process) your Personal Data but only where:
  - the accuracy of your personal data is contested (see the right to data rectification above), for a period enabling us to verify the accuracy of the Personal Data; or
  - the processing is unlawful and you oppose the erasure of your Personal Data; or
  - we no longer need the Personal Data for the purposes for which they were collected but you need the Personal Data for the establishment, exercise or defense of legal claims; or
  - you exercised your right to object and verification of our legitimate grounds to override your objection is pending.
5. Following our request for restriction, except for storing your Personal Data, we may only process your Personal Data:
  - where we have your consent; or
  - for the establishment, exercise or defense of legal claims; or
  - for the protection of the rights of another natural or legal person; or
  - for reasons of important public interest.
6. Right to Data Portability – You can request us to give you your Personal Data in a format that is easy to read by machines, or directly transfer it to another data controller if possible without harming others' rights and freedoms. This right only applies if:
7. the processing is based on your consent or on the performance of a contract with you; and
8. the processing is carried out by automated means.
9. Right to Object to Certain Processing – In those cases where we process your Personal Data for the performance of a task carried out in the public interest or when processing is necessary for the purposes of the legitimate interest pursued by us or by a third party (as indicated in the Table in the clause 4.2 above), you shall have the right to object to processing of your personal data by us.
10. When your data is processed for direct marketing purposes, you have the right to object at any time to the processing of your Personal Data, which includes profiling to the extent that it is related to such direct marketing.
11. Right to Withdraw Consent – In situations where we handle your Personal Data based on your consent, we will never assume your consent but rather obtain it from you in a clear and explicit way. You have the right to withdraw your consent at any time and the process of doing so should be the same as providing it. If you decide to withdraw your consent, we will check if we have an alternative legal basis for processing your personal data, such as a legal obligation. If we do, we may still process your data without your consent and will inform you accordingly.⁸
12. Right to lodge a Complaint – You are entitled to file complaints with the relevant Data Protection Supervisory Authority. If you reside in an EU member state, you can file a complaint with the Data Protection Authority of that particular state. However, we request that you first attempt to resolve any issues with us before contacting the competent authority, even though you have the right to do so at any time, as mentioned above.
Your Rights under the California Consumer Privacy Act (“CCPA”)
1. For California residents under 18 years old who are registered users of any Sites featuring this Privacy Notice, California Business and Professions Code Section 22581 allows the request and removal of publicly posted content or information.⁹
2. In compliance with the CCPA, this Privacy Notice outlines the Personal Data categories collected, processed and disclosed by TradrAPI, along with the data sources and business purposes for such actions.
3. Under California law, you may also request, up to twice within a 12-month period, information regarding TradrAPI's collection, usage and disclosure of your Personal Data. This includes:
  - Categories of Personal Data collected and their sources in the preceding 12 months.
  - Commercial or business reasons for collecting, using, or disclosing that data.
  - Categories of third parties to whom the data was disclosed in the preceding 12 months.
4. Furthermore, upon receiving a verifiable request confirming your identity, you may inquire about the specific pieces of Personal Data collected about you and/or shared with third parties in the previous 12 months.
5. You also retain the right to request deletion of Personal Data collected or maintained by us, subject to certain limitations specified in California law.
6. To process your request, you must provide specific Personal Data to verify your identity as required by the CCPA. This may include your full name, email address, physical address, telephone number and details about your relationship with us.
7. TradrAPI does not engage in discriminatory practices based on the exercise of these rights.
Cookies
1. TradrAPI Site uses cookies, for further information on what cookies are, which cookies we use, how and why we use cookies and how you can control which cookies are dropped, please read our Cookies Notice.
Amendments to TradrAPI's Privacy Notice
1. Through utilization of the Site, you acknowledge and consent to the acquisition, utilization, and retention of your Personal Data by the Company, as delineated within this Privacy Notice and other pertinent sections of the platform.
2. We retain the prerogative to modify this Privacy Notice periodically. Notification of such alterations shall be disseminated by means of updating this Privacy Notice.
3. In instances where substantial modifications are made, granting us additional privileges concerning the utilization of Personal Data previously obtained from you, we shall seek your consent either through electronic communication to your designated email address or by publishing details regarding said alterations on our platform.
Contact Details
1. For inquiries pertaining to the retention period of the data you provide to us or for any other questions related to data privacy, please direct your correspondence to our customer support at [email protected].

The term “Controller” refers to the definition provided in the General Data Protection Regulation (“GDPR”), as delineated in Article 4(7). ↩
We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, from our experience, we may not exclude that you, at your own discretion, send us such data in communication with us. ↩
In situations where we are required by law or a contractual agreement to collect Personal Data from you, and you refuse to provide this information, we may be unable to fulfill our obligations under the contract or initiate a contract with you. For instance, we may be unable to provide you with the services we offer. ↩
Please refer to the Cookies Notice for comprehensive details regarding the cookies utilized by us, including their attributes and functionalities. ↩
Please note that the table sets out the general information about the Personal Data we process. Certain data categories and/or purposes may differ in different jurisdictions and/or brands under which TradrAPI provides its services. ↩
Note that even if you object to receiving direct marketing materials, from time to time, we may still need to send you certain important communications from which you cannot opt-out. ↩
It is important to note that TradrAPI does not assume responsibility for any issues or complications arising from the settings or actions of social network providers. Users are encouraged to familiarize themselves with the terms and conditions as well as the privacy policies of the social network platforms they use. ↩
Note that while you can decline to provide us with your Personal Data, we may not be able to provide you with the services you requested if we need that information, especially if consent is the only legal ground we have available to us. ↩
It is important to note that such a request does not guarantee complete removal and legal circumstances may prevent or limit removal despite the request. ↩

TradrAPI Privacy Notice

Scope

Data Collection

Data Usage

Legal Basis for Processing Personal Data

Disclosure of Personal Data

Third-Party Sites

Social Login

Mobile Device Information

User Forums

Retention

Data Security

Your Rights under the General Data Protection Regulation (“GDPR”)

Your Rights under the California Consumer Privacy Act (“CCPA”)

Cookies

Amendments to TradrAPI's Privacy Notice

Contact Details

Footnotes