Please read this Policy carefully and contact us on our "Contact Us" page or menu on the Website, or through [email protected] if you have any questions about our privacy practices. We may make changes to this Policy from time to time and it is important that you check this Policy for any updates. If we make changes we consider to be important, we will let you know by placing a notice.
This Policy was last updated on March 5th 2019.
We collect, use, disclose, transfer and store personal data when needed to provide our services to our users and to meet our operational and business purposes as described in this Policy. We want to be clear about our privacy practices to ensure you can make informed decisions about the use of your personal data. You can contact us at any time with questions or concerns by sending an email to [email protected].
We use your personal data to provide you with the services you request through the Website and Exchange in order to meet our contractual obligations in relation to those services (including processing your trades), to keep in touch with you, to provide you with information about the products you trade and and the information you need to manage your account. We may also use your personal information to market our products and services to people like you. We will notify you separately if we process your personal data for any other purpose and, if required, ask for your consent.
When you create an account on Tradebits Exchange, we require you to provide your first and last name, email address, details about your financial status, your residential address, phone number, date of birth, a copy of your photo-ID, such as passport, driving licence, or national ID, a copy of a recent utility bill/bank statement (or similar) as evidence of your residential address and credit card or bank card details.
We also collect information about the form of identification used in relation to an individual in order to send or receive a transaction (required by law in some instances), and information about a transaction, including an individual’s account and delivery instructions. We may also collect information about employment details, employment history, the individual’s current financial circumstances; the individual’s foreign exchange preferences and tolerance to risk; and other matters that are relevant to the services we provide.
We use this data to verify your identity and to set up and administer your Tradebits account, provide technical and customer support and training and send you important account, subscription and service data (which may be sent by notifications through the Exchange). If it is necessary to use your personal data for any other service you may request whilst using the Tradebits Exchange, we'll tell you how we will use your personal data at the time (probably, with a pop up notice) and if there are any additional terms and conditions which will apply. You will be asked to confirm you agree to these additional terms and conditions before your application can proceed.
We may send you information by SMS, push notification, email or in-app notification about our products, services and offers we think would be of interest to you. The information we send you will always be in relation to the services or products you have requested from us and our communication to you is because we want you to hear more about what we can offer you as our customer and to give you opportunities to use our products and services in a better and more frequent way. The way we communicate with you in this way is based on what is known as our legitimate interest, and we will only ever send you communications that you would reasonably expect and have a minimal impact on your privacy.
If you receive email communications from us about the market or your activity on the Tradebits Exchange, and don't want to receive these communications in the future, please use the unsubscribe link within the email and we will stop sending you this information via email. Alternatively, when you are logged into your account you can manage your preferences any time.
Please note that push notifications are sent to every device you have logged into your account from. If you use another person’s device to log into your trading account or allow another person to log into their trading account using your device, this will result in push notifications being sent to the device(s) used to access the trading account. Therefore, if you have used another person’s device to log into your trading account or have allowed another person to log into their trading account using your device please contact Customer Service to request the removal of a particular device from a trading account.
To review and amend your other marketing preferences, go to the Settings section on the Tradebits Exchange.
We use personal data such as your location, trading history and alike to deliver tailored content such as news, research, reports, and business information and to personalise your experience with our services.
When you email us (through the Contact Us page) or use the Live Chat feature, you may be requested to provide some additional personal data, like your name, email address and residential address. We will use this data to respond to your query and verify your identify.
Emails are stored on our standard internal contact systems which are secure and cannot be accessed by external parties.
We may be required to retain and use personal data to meet our internal and external audit requirements, for data security purposes and as we believe to be necessary or appropriate: (a) to comply with our obligations under applicable law and regulations, which may include laws and regulations outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to monitor compliance with and enforce our Platform terms and conditions; (d) to carry out anti-money laundering, sanctions or Know Your Customer checks as required by applicable laws and regulations; or (e) to protect our rights, privacy, safety, property, or those of other persons. We may also be required to use and retain personal data after you have closed your Tradebits Exchange account for legal, regulatory and compliance reasons, such as the prevention, detection or investigation of a crime; loss prevention; or fraud prevention.
We also collect and process non-personal, anonymised data for statistical purposes and analysis and to help us provide a better service.
We share or disclose your personal data when necessary to provide services or conduct our business operations as described below. When we share personal data, we do so in accordance with applicable data privacy laws and our internal security standards.
Below are the parties with whom we may share personal data and why.
Within Tradebits Exchange:
Tradebits Exchange businesses are supported by a variety of the Group's teams and functions. We may make personal data available to them if necessary for the provision of services, account administration, sales and marketing, customer and technical support. All of our employees and contractors are required to follow our data privacy and security policies when handling personal data. We may process personal data in respect of the Tradebits Exchange in the following locations: Netherlands.
Our third party service providers:
We partner with and are supported by service providers. We will make personal data available to our service providers only when necessary to fulfil the services they provide to us, such as software, system and platform support; direct marketing services; cloud hosting services; advertising including affiliate advertising; data analytics; and order fulfilment and delivery. Our third-party service providers are not permitted to share or use personal data we make available to them for any other purpose than to provide services to us.
We will share personal data when we believe it is required, such as:
In order to meet with our internal compliance and regulatory obligations we monitor your trading activity such as the frequency of your trading and number of trades, and monetary activity such as number of deposits/withdrawals, payment methods used, your device information and IP.
Your personal data may be sent, stored and/or used in a country outside European Economic Area (EEA) which does not offer the same level of protection as the EEA. When you give us your personal data, you agree to us doing this.
We will take all steps reasonably necessary to ensure that your personal data is kept secure and protected in accordance with our legal obligations and standards. If this is not possible, for example because we are required by law to disclose data, we will ensure that the sharing of the data is lawful. To receive copies of our standards and safeguards for international transfers please contact us.
Obtaining a copy of your personal data and correcting mistakes we respect your right to access and control your personal data. We will respond to requests for personal data and, where applicable, will correct, amend or delete your personal data.
Access to personal data:
We will give you access to your personal data (including a copy or the ability for us to send your personal data to another provider) on request, unless any relevant legal requirements prevent us from doing so or if other exemptions apply. Before providing access to you, we will ask you to prove your identity and give us sufficient information about your interaction with us so that we can locate any relevant data.
Correction and deletion:
You have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request us to delete your personal data. In case you request us to delete your personal data this will result in the automatic closure of your account and we will remove your personal data from active processing. However, we will be required to maintain your personal data to comply with our legal and regulatory requirements as well as in accordance with our internal compliance requirements in relation to maintaining records.
If you would like to control the use of your information for marketing you may do it by sending us a request on [email protected].
In other certain circumstances you can ask us to stop processing your personal data. However, this may result in us being unable to continue to provide you with access to the Tradebits Exchange.
We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your personal data, and for any additional copies of the personal data you request from us.
We are committed to safeguarding and protecting personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any personal data provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
We will only retain your personal data for as long as we reasonably require it for legal or business purposes subject to a maximum of seven years. In determining data retention periods, we take into account local laws, contractual obligations, and the expectations and requirements of our customers. When we no longer need personal data, we securely delete or destroy it.
If you have any queries about the contents of this Policy, or wish to inform us of a change or correction to your personal data, would like a copy of the data we collect on you, or would like to raise a complaint or comment, please contact us via www.tradebits.nl.
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can escalate your complaint to the data protection regulator in your jurisdiction.
The Data Protection officer, can be contacted at [email protected] .