INTRODUCTION 

Tradeapp.com (the “Website”) is owned and operated by SPARTUM TECH LIMITED, registration number HE368296 and registered address Arch. Makariou III, 66 Cronos Court, Office 82, 1070, Nicosia, Cyprus (the “Company”). It is our policy to respect the confidentiality of information and the privacy of individuals.  Should you have any queries in relation to this Privacy Policy, your personal data held by us, or any other general questions in relation to the Company or the services it provides, do not hesitate to contact us through the contact details provided on this Website. 

The purpose of this Privacy Policy is to provide information on the collection, process and security of any data transmitted to and collected by us through the Website or within the scope of the provision of any related services (the “Service”), as per our legal obligations under the applicable data protection laws.  

 INFORMATION COLLECTED 

This Privacy Policy applies to the personal data collected by us in general or to any person who contacts us through the Website or use the Service. In general, personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where an individual cannot be identified or the identity has been removed (i.e. anonymous data).  

We collect a limited amount of data from users who visit the Website in order to view any information with regard to the services offered by the Company and/or any other relevant information of the Company that can be found on the Website, which we use to help us to improve your experience during the use of the Website. We also maintain website usage data, that is information on the frequency which you access our website and how you use the Website. 

Personal data you provide to us yourself when wishing to use the Service may include your first and last name, email address, date of birth, phone number, tax registration number, IP address, a unique identifier for your computer or other access devices, company information if applicable and payment data. 

USE OF YOUR PERSONAL DATA 

Most commonly we will use your personal data to help us manage the provision of the Service and exercise rights and obligations under the contract between us; to communicate with you about any queries you may have through the provision of the Services; and, in general for any other administrative, customer and technical support matter that may be needed.   

DATA SHARING 

We may disclose your personal data to our group or affiliated companies or to third parties that help us provide the Service, and/or to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request. For example, we use third party payment processors to assist in processing your payment information securely as part of the Service. We also use a technology platform provider to enable you to use the Service. Such third-party processor’s use of your personal data is governed by their respective privacy policies. 

SECURITY 

Personal data is processed in a manner that ensures appropriate security and confidentiality, including preventing unauthorised access to or use of personal data. We shall protect all data from loss, misuse, unauthorised access or disclosure, alteration, or destruction. The Company shall not be liable for unlawful or unauthorised use of any personal information due to misuse or misplacement of the passwords, negligent or malicious use.   

We maintain policies and procedures and have measures in place in order to ensure high levels of protection of personal data which include, inter alia, appropriate restrictions on permissions of access to personal information, controls and monitoring of storing and distribution of data. 

All our employees and associates are required to follow our privacy and security policies and procedures. The Company is not responsible for the security and privacy of any third party and/or social networking services or any information collected by them.   

HOW LONG WE KEEP YOUR PERSONAL DATA 

We retain personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, we take into consideration local applicable laws and contractual obligations. When information is no longer needed, we proceed with destruction or anonymisation, and in any event, subject to the specific processing purpose, personal data generally shall be kept for a minimum period of 6 years from termination of the last contract.  

RIGHTS 

Note that under the relevant data protection laws, in certain circumstances you have inter alia the below rights in relation to your personal data: 

Right to access your personal data 

You may request from us to receive a copy of the personal data that are being processed. If your data is being processed, we will provide you with further details on the processing. The Company hereby reserves its right to charge a relevant fee for providing such record of personal data to the person requesting this, except where this is not allowed under local legislation.    

Right to correction of the personal data in our records 

You may request us to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us. You may be able to rectify and amend your personal data by editing your user account data as part of the Service. 

Right to erasure of your personal data 

You have the right to request that we erase or remove your personal data in certain circumstances. This applies where there is no good reason for us continuing to process it, or where you have successfully exercised your right to object to processing (as per below), or where you believe we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.  

Right to object to the processing of your personal data 

Where we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object.  

Right to request restriction of processing of your personal data 

You have the right to request that we restrict and/or suspend our processing of your personal data in certain circumstances: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you prefer us to restrict our processing of it rather than erasing it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Right to request the transfer of your personal data to you or to a third party 

Upon your request we can provide you with your personal data or provide these to a third party you have chosen. 

Right to withdraw consent at any time 

Where we have obtained your consent to process your personal data, you may withdraw your consent at any time. Note that this will not affect the lawfulness of any processing carried out before you withdraw your consent. 

ACCEPTANCE OF THE PRIVACY POLICY 

By using the Website and/or the Service, you consent to all such terms and conditions provided for in this Privacy Policy, as well as other information found on the Website, in addition to consenting to the collection and processing of your personal data. You, therefore, agree to waive all rights in holding the Company liable for any claim arising out of or in connection with the processing of your data, as mentioned herein, unless such data has been fraudulently or negligently processed against the terms of this Privacy Policy. You further warrant that all personal data and information provided by you is accurate and up-to-date.  

By accepting this Privacy Policy, you are, accepting the data processing and relevant collecting provisions herein and you are giving your consent to the processing of your personal data as per this Privacy Policy. 

MODIFICATIONS TO THE PRIVACY POLICY 

 The Company is entitled to modify this Privacy Policy at its sole discretion from time to time and you should refer to our page regularly to stay up to date.