§ 1 DATA ADMINISTRATOR
Administrator of your data is Trade The Future Holding Limited – a company incorporated under the International Business Companies Act of 1994 of the Republic of Seychelles with a company certificate number of 204945, with registered seat in Global Gateway 8, Rue de la Perle, Providence Mahé, Seychelles („TFH”).
§ 2 WEBSITE
To ensure that all necessary steps are taken to protect the privacy of our users, TFH had created this policy in such way that it fully complies with:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (“GDPR”),
- the Data Protection Act of 2003 (“DPA”).
The data collected by us is processed, stored and may be transferred to any country within European Union and not beyond.
§ 3 VERIFICATION OF IDENTITY
- As a customer due diligence process, we may verify the ID/information and/or other documentation provided by you against third party databases.
- In order to properly provide services, it is necessary to register and verify your account. For this purpose, TFH only processes the necessary data, without which these processes cannot be legally or technically performed properly. In case you do not provide TFH with the required data, TFH will not be able to perform the service ordered by you – create accounts or perform transactions.
- Your consent to the processing of personal data is voluntary. If you do not give your consent to the processing of your personal data, or if you withdraw your consent, TFH will not take any action to which such consent applies.
§ 4 TYPES OF INFORMATION WE COLLECT
- Visiting and using TFH Website is related with the necessity of personal data collection and process.
- We collect various kinds of information that you provide to us as well as information we obtain from your use of the Services. Some of the types of information that we may collect include:
- “Personal Information” – information that could identify an individual person, such as your email address.
- “Trading Data” – data regarding an individual’s trading and holdings within the Services.
- “Usage Data” – data regarding an individual’s online activity (other than Trading Data) that, by itself, does not identify the individual, such as:
- technical information, including a user’s browser type, service provider, IP address, operating system and webpages visited;
- information about what a user has searched for and looked at while using the Services.
- TFH may process your personal data which comes directly from you and may be provided to TFH during the process of setting the account. This data means the data entered by you on the form provided on the website or contained in the documents provided to the TFH. Such data is also generated by you during the usage of the services available on our website.
- In view of the obligations imposed by binding law, TFH will have to verify the accuracy of the data provided to TFH, TFH will monitor your transaction history. It will be done by analysing the course, volume, currency and type of transactions.
- Cookies are small files invented to track, save and store information about usage of the website and user’s interaction on it that are saved to the user’s computer. Collecting this data provide the users quality experience within the Website.
- It is possible, the TFH will process collected data through cookie files when the website is used by you. TFH will process such data in order to:
- Identify user as logged in to the TFH website and show that they are logged in;
- Remember data from completed forms, surveys or login data to the website;
- Adjust the website’s content to users’ individual preferences (such as website colours, font size, page layout)
- Keep anonymised data, which will present the way the website is used
- Display individualized advertisements for users of the website in connection to their preferences
- Optimise the functioning of the website.
- By saving cookies, it is possible to display on the device that record the activity of the website your individualized preferences.
§ 6 AUTOMATIC DATA COLLECTION TECHNOLOGIES
- TFH may use automatic data collection technologies to collect certain information about our Users equipment, browsing actions, and patterns, including:
- Details of visits to our Website, including traffic data, geolocation data, logs, and other communication data and the resources that our Users access and use on TFH Website.
- Information about computer and internet connection, including our Users IP address, operating system, and browser type.
- We may collect information about you in the following ways:
- Email address
- Country of residence
- Encrypted Password
- The Bitcoin or other crypto asset public blockchain address(es) you use to fund your account (your “Wallet Address(es)”)
- The information TFH collects automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information TFH collects in other ways.
- The technologies TFH uses for this automatic data collection may include Cookies and Google Analytics – a web analytics service from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).
§ 7 PROFILING
- TFH can also introduce profiling. The purpose of profiling is to better analyse your personal factors. In this way we can anticipate your personal preferences, interests etc.
- The analysis and processing of such data will aim to offer you products as close as possible to your activity.
- The data collected, as well as the results obtained on the basis of this data, will allow us to make a decision on whether we can perform the services you have ordered
§ 8 HOW WE USE YOUR INFORMATION
- We may use the Personal Information we collect for any of the following purposes:
- to provide the Services to you;
- to operate, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
- for customer service, security, to detect fraud or illegal activities, or for archival and backup purposes in connection with the provision of the Services;
- to communicate with you;
- to help us develop our new products and services and improve our existing products and services;
- to enforce or aid in the enforcement of applicable law, our Terms of Service, and other applicable policies;
- to create aggregated or otherwise anonymized data, which we may use in any manner we deem fit.
- We may share and disclose Personal Information as described at the time information is collected or as follows:
- When you consent. We may share Personal Information with third parties if you have given us your consent to do so.
- To perform services. We may disclose Personal Information to third parties in order to perform services requested or functions initiated by users. In addition, we may disclose Personal Information in order to identify a user in connection with communications sent through the Services.
- With third party service providers performing services on our behalf. We share information, including Personal Information, with our service providers to perform the functions for which we engage them (such as hosting and data analyses). We may share information as needed to operate other related services.
- For legal purposes. We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.
- We may use or disclose Usage Data and Trading Data in any manner we deem fit, provided it does not include Personal Information.
- Our legal bases to process Personal Information include processing that is necessary.
- You must bear in mind that some of your personal data may be stored and processed for a longer period of time than indicated above, if such an obligation arises under applicable law.
- Please note that if the necessity of processing your data results from an obligation imposed by law, it may be processed even if your consent is expired or withdrawn.
- Because TFH is processing your data, you have a right to:
- to be informed about the processing of your personal data,
- to access your personal information,
- to request that your personal data be corrected or updated,
- to supplement personal data,
- to demand the immediate deletion of your personal data,
- to demand a restriction on the processing of your personal data,
- to receive data provided to the TFH,
- the transfer of personal data,
- to object to the processing of your personal data,
- object due to causes related to your particular situation,
- withdraw consent to the processing of personal data,
- fil a complaint to the supervisory body.
- If you want to exercise one or more of the rights indicated above, please contact firstname.lastname@example.org
- If you feel that the processing of your personal data by us violates the law, you can file a complaint to the supervisory body that deals with the protection of personal data. As we established dedicated representative for GDPR issues in Cyprus you may contact:
- Office of the Commissioner for Personal Data Protection
Office address: Iasonos 1, 1082 Nicosia, Cyprus
Postal address: P.O.Box 23378, 1682 Nicosia, Cyprus
Tel: +357 22818456; Fax: +357 22304565
- Office of the Commissioner for Personal Data Protection
§ 9 THIRD PARTIES
- You must bear in mind that your personal data may be entrusted to third parties in order to process them properly. TFH does not have the possibility to process all data provided by Users, therefore some of the processes are transferred to third parties with whom it has concluded appropriate agreements and which have a level of data protection not lower than TFH.
- We may entrust your personal data for processing to entities inter alia responsible for:
- providing the messages sending services, hosting services for the website, entities providing IT services, providing banking services, postal or courier providers, providing accounting services, providing verification of the documents authenticity, assessing the risk of fraud, providing other services that may be necessary to ongoing operation of the TFH and supports services provided by us.
- The entities with which TFH cooperates meet all the requirements imposed on them by law, and have adequate technological, human and financial resources to process your personal data in a manner consistent with all their standards and to properly secure them.
- The fact that your data is transferred for the purpose of proper processing to other entities does not result in the loss of these data by the TFH.
- It is also possible that your personal data will be processed by entities established outside the European Union or the Republic of Seychelles.
§ 10 CONTACT
- Users contacting TFH and/or providing any personal details do that at their own risk and at their own discretion. Personal information of any user is stored securely until it has no use or it is no longer required, in compliance with Data Protection Act of 2003, GDPR. Any submitted information may be used by us to further provide you with information about our products and services or to assist you in answering any questions or queries submitted by you. This includes using your details to inform you of important announcements within website. Regarding receiving any email marketing material, we assure you that your details are not passed on to any third parties.
- If you have any questions/ requests/ complaints regarding the processing of your personal data by TFH, you are able to contact our dedicated representative in the European Union via e-mail at adres e-mail support dedykowany pod derywatywy or contact TFH by writing at the address Global Gateway 8, Rue de la Perle, Providence Mahé, Seychelles
- Your question, application or complain sent to TFH should in particular include:
- All necessary data relating to the person or persons concerned by the question or complaint,
- The reason for sending a question or complaint – event which is the base of such request,
- Requests and legal ground for demanding request,
- The expected manner of handling the matter.
§ 11 TRANSFERRING FUNDS
Users who send cryptocurrencies to TFH through keys and cryptographic hashes consent to the fullest extent to accepting any responsibilities for the risks involved. Services offered by Website require users to automatically accept liability of any loss, damages or implications incurred through the use of this website. TFH and its owners are not liable for any loss of cryptocurrencies. If you do not agree with our policy, you can request a withdrawal of your assets once logged in.
§ 12 SECURITY
- This website does not store any users’ financial data on TFH servers. All keys and hashes accessed by the website are immediately forwarded to offline storage centres.
- The protection of personal data provided by the TFH consists in particular of:
- securing the possibility of downloading, copying or making available data by unauthorized persons,
- personal data, databases and devices on which personal data are processed are duly protected against loss, damage or destruction.
- We employ security measures designed to protect the security of all information submitted through the Services. However, the security of information can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, email address, or other form of authentication involved in obtaining access to password protected or secure areas of any of our Services. We may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the Services are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.
§ 13 EXTERNAL LINKS
The Website will never deliberately include any potentially malicious external links on its servers. While we, as TFH, seek to improve your overall experience by providing safe and relevant sources, a policy of caution should be adopted before clicking on any external links referenced by this website. It is for your own safety that you note that any external material is entered by you at your own risk and TFH cannot be held liable for any damages caused by visiting/interacting with any content on external websites.
§ 15 REVOCATION OF CONSENT TO THE PROCESSING OF PERSONAL DATA
Many data processing operations are only possible with our Users express consent. Our User may revoke consent at any time with future effect. An informal making this request is sufficient