TRADE INDEX, is a company abiding by the laws applicable in Malta (hereinafter TRADE INDEX). TRADE INDEX is the controller and responsible for the data of its Client disclosed to it in order to register for a Trading Account, Demo Account and/or to make use of any other services offered by the TRADE INDEX (as defined in Appendix A) through the website (hereinafter “Website”) (this term shall at all times include Website’s desktop and mobile versions). TRADE INDEX exercises control over the processing of data in undertakings affiliated to it and which belong to the TRADE INDEX.
The Company takes measures to implement advanced data protection policies and procedures and to update them from time to time for the purpose of safeguarding its Client's data and the Client’s account. Your data is protected by the legal, administrative and technical measures that we take to ensure the privacy, integrity and accessibility of data. To prevent security incidents with your data, we use a mixed organizational and technical approach based on the results of annual risk assessment.
The Company shall not divulge any private information of its Clients and former Clients unless the Client approves in writing such disclosure or unless such disclosure is required under applicable law or is required in order to verify the Client's identity or it is required for TRADE INDEX to perform its contractual obligations under any agreement concluded with the Client. The Clients' information is processed only by the employees of the Company and/or employees of TRADE INDEX and/or trusted third parties which provide specific support services, dealing with the specific Client's Accounts and necessary for the provision of our services. All such information shall be stored on electronic and physical storage media according to applicable law.
We may collect, use, store and transfer different kinds of data about you which we have grouped together as follows:
We use different methods to collect data from and about you including through:
Direct Interactions. You will provide to us your Identity, Contact and Financial Data online through the Website and/or by filling in online forms and/or by corresponding with us by emails or otherwise. Data may be submitted to us by you when you wish to:
We process the aforementioned data in compliance with the applicable legislation as amended from time to time in order to (i) be able to perform our contractual obligations towards the Client and offer them the best possible service, (ii) provide our Services efficiently, (iii) comply with our legal and regulatory obligations, including, inter alia, (a) to prevent fraud and money laundering acts and/ or (b) conduct the assessment of suitability and appropriateness test, and (iv) protect our legitimate interests and your vital interests.
We process all data based on the following legal basis:
|PURPOSE ACTIVITY||TYPE OF DATA||LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST|
|b.||1. To perform our Scoring Processing under which a Client is scored on a scale basis with regard to the level of risk he is to TRADE INDEX||1. Cryptocurrency Data 2. Economic Profile Data||1. Necessary to perform our contract with you 2. Necessary to comply with our legal obligations|
|c.||1. To confirm the information provided by You under (a) above in relation to your location. 2. To comply with our legal obligations||1. Location Data||1. Necessary to perform our contract with you 2. Necessary to comply with our legal obligations|
|d.||1. To secure authentication, identification and support services via social networks protocols and use the links to your accounts in social networks for these purposes||1. Technical Data||1. Necessary to perform our contract with you 2. Necessary to comply with our legal obligations|
|e.||1. To process and deliver your transactions and requests (Deposits; Trades; Withdrawals) 2. Manage payments, fees and charges; 3. To collect and recover money owed to us.||1. Cryptocurrency Data 2. Transaction Data||1. Necessary to perform our contract with you 2. Necessary for our legitimate interest (recover charges owed to us, make a refund in case of breach of our contract)|
|f.||1. To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||1. Identity Data 2. Contact Data 3. Technical Dat||1. Performance of our contract with you 2. Necessary to comply with our legal obligations 3. Necessary for our legitimate interests (take reasonable steps to confirm that you do not use any ways to manipulate our platform & for running our business, provision of administration and IT services, network security, to prevent fraud)|
|g.||1. To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you 2. To provide you with an optimal operation on our web application, mobile and/or desktop versions of our application and monitor your behavior for the purpose of improving the efficiency and usability of our services.||1. Identity Data 2. Contact Data 3. Profile Data 4. Usage Data Technical Data 5. Marketing and Communication Data||1. Necessary to perform our contract with you 2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business)|
|h.||1. to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy; 2. statutory limitations||1. Transaction Data||1. Necessary for our legitimate interests (including statutory limitations provisions by applicable laws)|
|i.||1. To inform you about any of the following: — new services and/or products we may offer; — Any new development and/or features of the current products/services we offer||1. Identity Data 2. Profile Data 3. Contact Data 4. Technical Data 5. Usage Data 6. Transactions 7. Marketing and Communication Data||1. Necessary to perform our contract with you 2. Necessary for our legitimate interests (to study how customers use our products/services, to develop our products/services and grow our business)|
|j.||1. To send direct marketing of our services to you always within the boundaries of our legitimate interests. 2. To send to you newsletters, push-messages and calls to keep you in touch with our new feature and new development of the current products/services we offer, news and events and the efficient provision of the full scope of our services. Please note that we will never use your data to communicate to you and/or promote any third party marketing material.||1. Identity Data 2. Profile Data 3. Contact Data 4. Data that may be provided by you during your activity at the Website. Marketing and Communication Data||1. Necessary to perform our contract with you 2. Necessary for our legitimate interests (to provide effective and personalized customer services to you and to update you in relation to our services that are available to you.|
|k.||1. To allow us to provide you with the optimal operation on our Website, mobile and desktop versions of our application and monitor your behavior for the purpose of improving the efficiency and usability of our Services. 2. To use analytics tools to track performance of the Website and marketing source of our Clients in order to optimize our marketing costs and provide you with better experience.||1. Location Data 2. Technical Data 3. Usage Data 4. Marketing and Communication Data||1. Necessary to perform our contract with you 2. Necessary for our legitimate interests (to provide effective and personalized customer services to you and to update you in relation to our services that are available to you).|
|i.||1. to allow us to monitor and train our employees for your benefit 2. to safeguard your or our interests in case of a dispute 3. to take steps for fraud prevention 4. to improve the services provided to you||Audio Data||1. Necessary to perform our contract with you 2. Necessary to comply with our legal obligations 3. Necessary for our legitimate interests|
|m.||1. To confirm that your annual income corresponds with your employment status 2. To confirm that you have no criminal history.||Sensitive Data||1. Necessary to comply with our legal and regulatory obligations 2. Necessary to protect your vital interests.|
If you do not want to receive any marketing newsletters or transmit your data to the third-parties for marketing purposes, you can configure your preferences. Such configuring can be done when (i) opening an account or (ii) when receiving such advertising content or (iii) by logging in and going to My Account > Personal Details. You may also send to the Company, at any time, an email to email@example.com asking the Company to cease from sending such advertising content or sending your data to the third-parties for marketing purposes. The aforesaid mark removal and/or e-mail received by TRADE INDEX will oblige us to cease sending advertisement content to you within 7 (seven) business days.
We may share your data with the parties set out below for the purposes set out above.
We require TRADE INDEX and any third parties processing data on our behalf to respect your data and to treat it in accordance with the provisions of the General Data Protection Regulation and applicable local legislation as amended from time to time. We take all reasonable steps so that our third-party service providers do not use your personal data for their own purposes and only permit them to process your data for specific purposes and in accordance with our instructions.
TRADE INDEX. In general, your data is used by the processors of TRADE INDEX. We include here (not an exhaustive list) the names of the companies as per Appendix A:
TRADE INDEX SOFTWARE
TRADE INDEX MALTA
Trade Index Indonesia
We note that these may change from time to time and we will do our best to update the relevant sections in due course.
In addition, a transfer of your data to another legal entity may occur as part of a transfer of our business or parts thereof in form of a reorganization, sale of assets, consolidation, merger or similar.
With regard to the transfer of data to recipients outside TRADE INDEX, we note that we strive to maintain discretion with respect to client related matters and assessments of which we acquire knowledge. We may disclose data that concerns you only if (i) we are legally required to do so; (ii) if required when you expressly order us to process a transaction or any other service and (iii) it is required for the provision of our services under our contractual relationship and/or (iv) protection of our legitimate interests and applicable legislation as amended from time to time.
External Third Parties. Your data is shared with third party organisations/entities including but not limited to:
We store your data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for your data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting and other requirements.
By law we have to keep your data (including call recordings) during our contractual relationship and for a minimum period of 5 (five) years from the date of termination of the Platform/Service used by the Client. The data storage period may be extended from 5 years to 7 years upon the request of the competent authority (regulator of the Company’s licensed activities).
In general, all other data is stored for a period of 30 (thirty) business days after the date of termination of the provision of our services unless there is any other legal or regulatory reason to keep it.
At the expiration of the data retention period the data is erased by irreversible destruction and we also inform all third parties, to whom the data was transferred, regarding such erasure and request implementation of similar actions on their part.
yourself to be another individual or legal entity. Any changes in your identifying details shall be notified to the Company immediately and in any case no later than the 7th day from the date of such changes. If your data is incorrect or incomplete, please contact our support services at the contact details listed in the section OUR CONTACT DETAILS below in order to change your data.
Under certain circumstances, you have rights in accordance with applicable legislation and our policies as amended from time to time. Some of the rights are rather complex and include exemptions, thus we strongly advise you to contact us (at the contact details listed in the section OUR CONTACT DETAILS below) and/or seek guidance from the regulatory authorities for a full explanation of these rights. You can find a summary of your rights below in this section.
We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data breach and will notify you and the competent regulator of a breach where we are legally required to do so.
Your help is always valuable in ensuring that your data is kept safe. Upon registration to the Website (or its mobile version), the Client will be asked to choose a username and password to be used by the Client on each future login and for the performance of transactions and use of the Company's Services. In order to protect the Client's privacy and operation with the Website sharing registration details (including without limitation, username and password) by the Client with other persons or business entities is strictly prohibited. The Company shall not be held responsible for any damage or loss caused to the Client due to improper use (including prohibited and unprotected use) or storage of such username and password, including any such use made by a third party, and whether or not known to or authorized by the Client.
Any use of the Website with the Client's username and password is Client's sole responsibility. The Company shall not be held responsible for any such use, including for validation that Client is actually operating in his/her account.
The Client is obliged to forthwith notify the Company's client service of any suspicion for unauthorized use of the Client’s account. You may contact us at any time through the points of contact listed in the Section OUR CONTACT DETAILS below.
Encryption of your data in transit. Encryption provides a high level of security and privacy for your data. When you enter your data in our platform we use strong encryption technologies (such as Transport Layer Security) to protect your data during transmission from your devices to our servers.
For providing more trust and security we use digital EV (Extended Validation) Certificates issued by trusted Certificate Authorities. You can see the ‘Green Bar’ in the supported browser versions which confirms what all transmitted data is secure.
Protection of your data in our infrastructure. We make it a priority to develop services that are secure "by default". The "default" security of our services means that every new services and features are designed with strict security requirements in mind before we even begin development. This is the key to guaranteed protection and privacy of all data that our services handle and store, once the service or new feature is released.
For secure your data we use the pseudonymisation which allows most of our services to operate without using your actual data. Instead of that, our services use a system ID that can't be traced back to identify you.
The Company is always vigilant about the security of your data stored in our infrastructure. Because of that we locate all our equipment which used for your data processing in secure data centres. Network access to this equipment is isolated from the Internet. We use network segmentation for isolation of services which need different level of security from each other. In addition, we restrict logical access to your data for our employees on "need to know" basis. So, only personnel, who really requires access to your data for the purpose of providing you with our best service, will have access to it.
Threats protection. Our Company is highly knowledgeable about modern threats to data security and privacy, and we are well prepared to combat them. All events that occur in our infrastructure are continuously monitored, analysed and responded, which allows us to ensure proper protection of your data, keeping it safe from threats, vulnerabilities, and the effects of malware.
In the event of a failure that affects the accessibility of your data, we have data backup and recovery procedures in place that will us help to restore your data in short time. For guarantee the quick recovery we use high availability mode enabled for most critical databases which allows us to minimize downtime.
Employee awareness of data security. Our employees may handle your data in order to provide you with the first-class service. To guarantee the security and confidentiality of your data, we monitor all employees’ actions with access to your data in our systems and grant access strictly on a "need to know" basis: only employees who need access will receive it. We hold regular training sessions to make sure that each employee understands the principles that the Company follows to achieve robust data security and privacy.
If you choose not to give your personal information. In the context of our business relationship we may need to collect data by law, or under the terms of a contract we have with you. Without this data, we are, in principle, not in a position to close or execute a contract with you.
If you choose not to give us this data, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies.
To what extent we carry automated decision-making and profiling. In establishing and carrying out a business relationship, we generally do not use automated decision-making. If we use this procedure in individual cases, we will inform you of this separately. In some cases, we may proceed with profiling in order to evaluate certain personal aspects. We shall inform you accordingly in case we perform any profiling. In general, any data collection that is optional would be made clear at the point of collection.
Who is responsible for the data processing and who you can contact.
The entity responsible for your data processing is TRADE INDEX and you can contact us using the details set out below:
We may provide links to third party websites in our Website. These linked websites are not under our control, and we therefore cannot accept responsibility or liability for the conduct of third parties linked to our websites, including without limitation to the collection or disclosure of your data. Before disclosing your data on any other website, we encourage you to examine the terms and conditions of using that website and its privacy policies.
In relation to a company, that company, any subsidiary or subsidiary undertaking or any holding company or holding undertaking or any connected company from time to time of that company.
An undertaking is a parent undertaking in relation to another undertaking, a subsidiary undertaking, if a. it holds a majority of the voting rights in the undertaking, or b. it is a member of the undertaking and has the right to appoint or remove a majority of its board of directors, or c. it has the right to exercise a dominant influence over the undertaking— d. by virtue of provisions contained in the undertaking's articles, or e. by virtue of a control contract, or f. it is a member of the undertaking and controls alone, pursuant to an agreement with other shareholders or members, a majority of the voting rights in the undertaking.
For the purposes of the above an undertaking shall be treated as a member of another undertaking— a. if any of its subsidiary undertakings is a member of that undertaking, or b. if any shares in that other undertaking are held by a person acting on behalf of the undertaking or any of its subsidiary undertakings.
A parent undertaking shall be treated as the parent undertaking of undertakings in relation to which any of its subsidiary undertakings are, or are to be treated as, parent undertakings; and references to its subsidiary undertakings shall be construed accordingly.
A company is connected with another company if: a. the same person has direct or indirect control of both companies, b. a person (“A”) has control of one company and persons connected with A have control of the other company, c. A has control of one company and A together with persons connected with A have control of the other company, or d. a group of two or more persons has control of both companies and the groups either consist of the same persons or could be so regarded if (in one or more cases) a member of either group were replaced by a person with whom the member is connected.Service Providers. We may share your
We use the collected data for various purposes:
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
TermsFeed may process your Personal Data because:
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. TermsFeed aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
© 2018 Trade Index, Inc.