Privacy Notice

Last update 7th August 2024

Scope
Data Collection
Data Usage
Legal Basis for Processing Personal Data
Disclosure of Personal Data
Third-Party Sites
User Forums
Mobile Device Information
Social Sharing Feature
Retention
Usage of Automated Chatbots
Data Security
Your Rights under the General Data Protection Regulation (“GDPR”)
Your Rights under the California Consumer Privacy Act (“CCPA”)
Cookies
Amendments to TradeLocker’s Privacy Notice
Contact Details
Acceptance

1. Scope

1.1. 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. 1.2. 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. 1.3. 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. 1.4. The https://tradelocker.com (the “Site”) is not intended for children and we do not knowingly collect data relating to children (below 18 years of age). 1.5. By using our website you consent to the data practices described in this Notice and all extensions and addendums to this Notice including Terms and Conditions (‘T&C’).

2. Data Collection

2.1. 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. 2.2. Data obtained from you: We may 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:

Account Opening and Client Services: TradeLocker collects Personal Data when individuals register for a trader account.
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 TradeLocker’s websites.
Types of Collected Personal Data: The personal data collected may include but is not limited to foll name contact details address investment profile etc.
Automatic Collection Through Tracking Technologies: Information about the devices used to access TradeLocker’s websites is automatically collected. This includes: IP address; device identifier; web browser details; browsing details through cookies and other tracking technologies.
Third-party Data Sources: TradeLocker may obtain Personal Data from third-party sources which may include demographic information professional information etc. This data may be acquired from publicly available online sources.
Data Merging and Analytics: When necessary and in compliance with applicable laws TradeLocker may merge this data with existing information for purposes such as benchmarking and market data analytics.

3. Data Usage

3.1. At TradeLocker 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. 3.2. Purposes of Personal Data Usage. We may collect and use Personal Data for the following purposes:

Opening and managing accounts: Your personal information is necessary to establish and maintain your account on our platform.
Improving services and website functionality: Your feedback and usage patterns help us enhance our services and optimize website performance.
Distributing newsletters and alerts: With your consent we send newsletters and alerts to keep you informed about updates and relevant information.
Analyzing website performance: We may analyze user behavior and website interactions to improve user experience and functionality.
Complying with legal obligations: We may process Personal Data to fulfill legal requirements and obligations.
Executing TradeLocker agreements: Personal Data may be used to execute agreements between TradeLocker and its users or partners.

3.3. TradeLocker’s services may involve the use of technology provided by TradingView. Please note that TradingView’s privacy policy, available here, is not applicable to TradeLocker’s implementation of TradingView’s technology. TradeLocker is solely responsible for the collection, use, and protection of your personal data in accordance with this Privacy Notice. 3.4. We may share your personal data with third-party service providers who assist us in delivering our services. These providers are contractually bound to process your data only as instructed by TradeLocker and in compliance with this Privacy Notice and applicable data protection laws. Such third-party service providers may include, but are not limited to, companies that offer charting and analysis tools, data providers, and other entities that support our platform’s functionality. 3.5. Necessity of Personal Data. The collection and processing of Personal Data are justified by the following reasons:

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.
Used for providing market data products: We may use your data to provide you with market data services or similar offerings.
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.
Retained for future communication purposes: We may retain your data to communicate with you regarding your account updates and relevant information.

3.6. Use of Cookies and Tracking Technologies. We utilize cookies and tracking technologies for the following purposes:

Website management and analytics: Cookies help us manage website operations and analyze user behavior to improve our services.
Monitoring user interactions: We may use cookies to monitor how users interact with our website and services to enhance user experience.
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. Legal Basis for Processing Personal Data

4.1. This Section outlines the legal framework that governs the processing of Personal Data by TradeLocker:

Legitimate Interest: We may process your Personal Data based on our legitimate interest in promoting and safeguarding TradeLocker. This includes fostering and managing relationships recruitment activities and delivering our services effectively.
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.
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 TradeLocker.
Legal Compliance: In certain instances we may process your data to comply with legal requirements including fulfilling our legal obligations.

4.2. 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.

Purpose	Data Category	Legal Basis
To register you as a new user i.e. issuing or assigning the login credentials to identify whether the credentials are valid upon login and to allow you access to services accordingly with the T&Cs.	Registration Data, Contact Data, Log-in Data	Performance of the contract
To allow your access 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
Direct Marketing of our third parties 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)

4.3. Direct Marketing – In compliance with relevant laws and regulations and through a legitimate interest or with your consent TradeLocker 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). 4.4. When relying on legitimate interest TradeLocker will give you the opportunity to oppose such direct marketing when registering on our Site. 4.5. When relying on consent the consent may be granted by you when registering on our Site.

5. Disclosure of Personal Data

5.1. At TradeLocker 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:

Recipient Identification: TradeLocker 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.
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.
Consent and Legal Obligations: Your Personal Data will not be shared with third parties without explicit consent except where mandated by law. TradeLocker complies with legal requirements and only discloses information when necessary for legal proceedings law enforcement purposes or governmental requests.
Legal Compliance: TradeLocker 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.
Recipient Notification: In cases where data rectification deletion or processing limitation is requested by individuals TradeLocker will notify relevant third-party recipients to ensure compliance with such requests.
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. TradeLocker will take appropriate measures to safeguard the confidentiality and integrity of your information throughout such transitions.

5.2. 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.

6. Third-Party Sites

6.1. TradeLocker provides links to external websites or information as a service. Clicking these links redirects users away from TradeLocker’s site. 6.2. It is important to note that TradeLocker neither endorses nor sponsors these third parties or their sites. 6.3. 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.

7. User Forums

7.1. Participation in user forums on this Site or through links redirecting to third-party platforms like Discord or Telegram implies acknowledgment that shared information may be accessible and utilized by other individuals. 7.2. TradeLocker disclaims responsibility for the practices or actions of third parties who gather and employ data publicly disclosed by users on the website forums. 7.3. Users are advised to exercise prudence and discretion when divulging personal or sensitive information in such forums.

8. Mobile Device Information

8.1. TradeLocker 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. 8.2. Reports generated encompass aggregate usage data browsing patterns device information and details on application errors. 9.1. TradeLocker offers a social sharing feature enabling users to share trading activity on external social media platforms (e.g., Instagram, X, etc.) to enhance user experience and foster community engagement, including the sharing of financial information such as current positions (active trades) and completed activities (closed trades). 9.2. Participation in the social sharing feature is entirely optional and operates on an opt-in basis. Users must provide explicit consent prior to use of this function for the first time, which will serve as the legal basis for TradeLocker to share trading information. 9.3. Data shared via the social sharing feature remains under the user’s control and may be deleted from the TradeLocker platform at any time. However, TradeLocker does not control or influence the retention or deletion policies of third-party platforms. Users are strongly encouraged to review the privacy notices of these external platforms, as shared content may persist there even after it has been deleted from TradeLocker. 9.4. Users are advised to exercise caution when sharing financial or personal information publicly. TradeLocker makes no representations regarding the security or privacy practices of third-party platforms. 9.5. Users are responsible for ensuring that any content shared via the social sharing feature complies with all applicable laws, regulations, and rules in their jurisdiction. TradeLocker disclaims any liability for users’ non-compliance with such laws. 9.6. TradeLocker may utilize aggregated and anonymized data from the social sharing feature for the purpose of improving our services. However, no personally identifiable information from shared posts will be used for marketing or any other commercial purpose without the user’s explicit consent. 9.7. Shared information may be accessible to third parties depending on the privacy settings users configure on external social media platforms. TradeLocker is not responsible for any third-party use or processing of shared information once it is made publicly available. 9.8. Users have the right to disable the social sharing feature at any time by contacting TradeLocker at [email protected]. Disabling the feature will prevent future sharing, but it will not affect any content already shared on external platforms. 9.9. By using the social sharing feature, users acknowledge that they have read, understood, and agree to the terms set forth herein, including the sharing of their information as described.

10. Retention

10.1. 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. 10.2. 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. 10.3. Where your Personal Data is no longer required by us we will either securely delete or anonymize the Personal Data in question.

11. Usage of Automated Chatbots

11.1. TradeLocker utilizes chatbots as an initial point of contact between TradeLocker and its users to facilitate customer service interactions. 11.2. TradeLocker exclusively utilizes chatbots as the primary contact point for triaging inquiries from users. Inquiries falling beyond predetermined parameters such as those not addressed in the FAQ section or similar resources are directed to human agents for further assistance. As such the utilization of chatbots is overseen by human supervision.

12. Data Security

12.1. 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. 12.2. 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. 12.3. TradeLocker cannot provide absolute assurance of safeguarding against unauthorized access or breaches. In the event of a data breach TradeLocker will conduct a thorough risk assessment and notify impacted individuals in accordance with applicable local laws. 13.1. 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.

13.2. 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. 13.3. 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.

13.4. 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.

13.5. 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.

13.6. 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:

the processing is based on your consent or on the performance of a contract with you; and
the processing is carried out by automated means.

13.7. 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. 13.8. 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. 13.9. 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. 13.10. 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.

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

14.1. 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. 14.2. In compliance with the CCPA this Privacy Notice outlines the Personal Data categories collected processed and disclosed by TradeLocker along with the data sources and business purposes for such actions. 14.3. Under California law you may also request up to twice within a 12-month period information regarding TradeLocker’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.

14.4. 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. 14.5. You also retain the right to request deletion of Personal Data collected or maintained by us subject to certain limitations specified in California law. 14.6. 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. TradeLocker does not engage in discriminatory practices based on the exercise of these rights.

15. Cookies

15.1. TradeLocker 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.

16. Amendments to TradeLocker’s Privacy Notice

16.1. 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. 16.2. We retain the prerogative to modify this Privacy Notice periodically. Notification of such alterations shall be disseminated by means of updating this Privacy Notice. 16.3. 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.

17. Contact Details

17.1. 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]. Alternatively you may contact our Data Protection Officer (DPO) at [email protected].

18. Acceptance

18.1. By using TradeLocker services you explicitly agree to our Privacy Notice and Cookies Notice which outline how we collect process and utilize personal data as well as how cookies are deployed. This acceptance is required to access and utilize TradeLocker services.