Last Updated: 12 Dec, 2023
Welcome to Future-Trade (the "Crypto Trading Platform"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines our practices regarding the collection, use, and disclosure of your information when you use our services.
Changes to This Privacy Policy
We reserve the right to update this Privacy Policy. The most recent version will be posted on our website with the effective date.
why we are using your data.
In this Privacy Policy, unless the context otherwise requires, expressions defined herein shall have the meaning ascribed to them in the Terms & Conditions.
Please note that this Privacy Policy is addressed to Clients and potential customers. If you are an Trades Point Capital employee, a contractor to Trades Point Capital or a third-party service provider, your personal information will be used in
connection with your employment contract, your contractual relationship or in accordance with our separate policies which are available by contacting us at the contact details listed in the section OUR CONTACT DETAILS
below.
1. User Information:
When you create an account, we collect information such as your name, email address, and other relevant details.
the controller and responsible for the data of the Client disclosed to us in order to register for a Trading Account, Demo Account and/or to make use of any other services offered by the Trades Point Capital Group (as defined in
Appendix A) through the website (hereinafter “Website”) (this term shall at all times include Website’s desktop and mobile versions).
2. Transaction Data:
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- To facilitate cryptocurrency transactions, we may collect transaction details, including wallet addresses and transaction amounts.
3. Verification Information:
- In compliance with regulatory requirements, we may collect additional information to verify your identity, such as government-issued identification documents.
- About Cookies.
A cookie is a small amount of data that often includes a unique identifier that is sent to your computer or device browser from a website's computer and is stored on your
device's hard drive for tracking site usage. A website may send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits a website to
access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows. When you visit
our Website, our system automatically collects information about your visit, such as your Technical Data, including inter alia to, your browser type, your IP address and the referring website.
Cookies
stored may determine the path the Client took on our site and used to anonymously identify repeat users of the website and what pages were most popular for Clients. However, the Company protects the Client’s
privacy by not storing the Client’s names, personal details, emails, etc. Using cookies is an industry standard and is currently used by most major websites. Stored cookies allow the Website to be more user-friendly
and efficient for Clients by allowing Trades Point Capital to learn what information is more valued by Clients versus what isn’t. You can set your browser not to save any cookies of this website and you may also delete
cookies automatically or manually. However, please note that by doing so you may not be able to use all the provided functions of our website in full.
Please see our Cookies
Policy for further details.
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How We Use Your Information |
TYPE OF DATA |
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1. Account Management: To create and manage your account, authenticate your identity, and provide customer support.
2. Transaction Processing: To process cryptocurrency transactions and ensure the security of your funds.
3. Compliance: To comply with legal and regulatory requirements, including identity verification and anti-money laundering (AML) checks.
4. Communication: To communicate with you regarding your account, transactions, and important updates.
jurisdiction
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. Identity Data 2. Profile Data 3. Contact Data 4. Data in KYC
5. Financial Data 6. Economic Profile Data
|
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5. Analytics: To analyze and improve the performance and functionality of our Platform. |
1. Banking Data 2. Economic Profile Data |
c. |
1. To confirm the information provided by You under (a) above in relation to your location. |
1. Location Data |
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 |
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. Banking Data 2. Transaction Data |
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 Data |
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.
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1. Identity Data 2. Contact Data 3. Profile Data 4. Usage Data Technical Data 5. Marketing and Communication Data |
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
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1. Transaction Data |
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
|
|
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 |
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.
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1. Location Data 2. Technical Data 3. Usage Data 4. Marketing and Communication Data |
|
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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 |
|
m. |
1. To confirm that your annual income corresponds with your employment status
2. To confirm that you have no criminal history.
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Sensitive Data |
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- If you are an existing Client of the Website where we have a legitimate interest in communicating with you, or if you have given us your consent we will collect and process your personal data to communicate with you
in case of support and/or sending newsletters, push-messages and calls to keep you in touch with our new features, news and events and the efficient provision of the full scope of our services. We will also use
your data to send you marketing information regarding our services that we believe may be of interest to you via email or otherwise.
- Our Website is not intended for children and we do not knowingly collect data relating to children. As we do not allow users under the age of 18 to use our services, we need to obtain your birth date in order to confirm
the Clients’ age checks.
5. OPTING OUT
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 > Notification Settings. You may also send to the Company, at any time, an email to support@tradespointcapital.com using the registered email address you disclosed and registered with us through your Account 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 Trades Point Capital will oblige us to cease sending advertisement content to you within 7 (seven) business days.
6. DISCLOSURE OF DATA
- We may share your data with the parties for the purposes set out above.
- We require all Trades Point Capital Group companies 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.
- Trades Point Capital group companies. In general, your data is used by the processors of the Trades Point Capital group.
- 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 the Trades Point Capital group, 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:
- A. Service Providers. We may share your data with our trusted third party service providers, who, on our behalf, operate, maintain, and/or support our IT systems and IT infrastructure, our websites,
manage our payment solutions, perform statistical analysis, marketing and advertising purposes, sending newsletters, provide customer support and perform other important services for us.
- B. Other Trades Point Capital Affiliates. We may also disclose your data to other Trades Point Capital Affiliate companies in order for them to provide us with the relevant services.
- C. State authorities. The Client's details that are provided and/or that will be provided by the Client during his/her activity on the site may be disclosed by the Company to official authorities.
The Company will make such disclosure only if required to be disclosed by the Company by applicable law or court order and to the minimum required extent.
- D. Other disclosures. In addition to where you have consented to a disclosure of the data or where disclosure is necessary to achieve the purpose(s) for which, it was collected, data may also
be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally
or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise or defence of legal claims.
- Where reasonably possible, management shall ensure that third parties collecting, storing or processing personal information on behalf of the Company have:
- a. Signed agreements to protect personal information consistent with this Privacy Policy and information security practices or implemented measures as prescribed by applicable laws;
- b. Signed non-disclosure agreements or confidentiality agreements which includes privacy clauses in the contract; and
- c. Established procedures to meet the terms of their agreement with third party to protect personal information.
- Remedial action shall be taken in response to misuse or unauthorized disclosure of personal information by a third party collecting, storing or processing personal information on behalf of Trades Point Capital.
- If you want to obtain further information on any data transfers mentioned above please contact us using the registered email address you disclosed and registered with us through your Account through the points of contact
listed in the Section OUR CONTACT DETAILS below.
7. DATA RETENTION
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, 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, tax, accounting and other requirements.
We shall 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.
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 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.
8. YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE
- We ask you to provide us with true, accurate and updated information on your identity and not misrepresent 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). You can find a summary of your rights below in this section.
- A. The right to access. You have a right to obtain the confirmation as to whether or not your data are being processed by us. In addition, you have a right to obtain more detailed information
about the data kept and the processing undertaken by us and under certain circumstances the right to receive a copy of this data.
- B. The right to rectification. You have the right to have inaccurate data about you rectified, and, taking into account the purpose of the processing, to have incomplete data completed.
- C. The right to erasure. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please 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. In case if you want to obtain complete erasure of your
data (to apply the “right to be forgotten”), please note 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.
- D. The right to restriction of processing. You have the right to request the restriction of processing of your personal data (a) if it is not accurate;(b) where processing may be unlawful but
you do not want us to erase your data; (c) where you need us to hold the data even if we no longer require it; or (d) where you may have objected to our use of your data but we need to verify whether we
have overriding legitimate grounds to use it.
- E. The right to data portability. To the extent the legal basis for the processing is your consent, and such processing is carried out by automated means, you have the right to receive your
data in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others and/or in case it may be technically
impossible to do so.
- F. The right to object. Subject to the legal basis on which the processing activity is based, you may object to processing of your personal data. Please note that in some cases, we may have
compelling legitimate grounds to process your information which we need to comply with.
- G. The right to withdraw consent. To the extent that the legal basis for the processing is your consent, you have the right to withdraw from that consent at any time. This may apply to marketing
purposes and/or with regards to the transfer of your data to third parties. In case you withdraw from a consent given, then we will cease to process your data, unless and to the extent the continued processing
is permitted or required according to the applicable data regulation or other applicable laws and regulations. The withdrawal from your consent will in no event affect the lawfulness of processing based
on consent before its withdrawal.
- H. The right to complaint to data protection supervisory
authority. We do our best to ensure that we protect your data, keep you informed about how we process your data and comply with the applicable data protection regulation. In case you are not
satisfied with the processing and protection of your data or the information you have received from us, then we urge you to inform us in order for us to improve. Please also do not hesitate to contact us,
if you want to make use of your rights.
- If you want to exercise any of your rights mentioned above and/or obtain more information regarding your rights and/or our policies and procedures please contact us through the points of contact listed in the Section
OUR CONTACT DETAILS below. Please also provide us with relevant information to take care of your request, including your full name and email address so that we can identify you. We will respond to your request without
undue delay.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal
data is not disclosed to any person who has no right to receive it. We may also contact you to ask you further information in relation to your request to speed up our response.
- We try to respond to all legitimate requests within one month. Occasionally it could take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify
you and keep you updated.
- We may charge you a reasonable administrative fee for any unreasonable or excessive requests we may receive, and for any additional copies of the data you may request.
9. DATA SECURITY
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 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 all 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.
To 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 is 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 levels of security from each other. In addition, we restrict logical access to your data for our employees
on a "need to know" basis. So, only the personnel that 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 help us restore your data in a short time. To guarantee 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.
10. OUR CONTACT DETAILS
- Who is responsible for the data processing and who you can contact.
- The entity responsible for your data processing is Trades Point Capital LLC and you can contact us using the details set out below:
- Hinds Building, Kingstown, St. Vincent and the Grenadines
- Data Protection Officer
- We have appointed a data protection officer (hereinafter DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this privacy policy, including
requests relating to the data, please contact the DPO using the details set out below:
- Hinds Building, Kingstown, St. Vincent and the Grenadines
- internationaldpo@tradespointcapital.com
- To enable us to process your request, please contact us using the registered email address you disclosed and registered with us through your Account. We may require that you provide us with proof of your identity, such
as by providing us with a copy of a valid form of identification. This is to ensure that we appropriately protect the personal data we hold from unauthorised access requests and comply with our security obligations.
- If you have any questions, or want more details about how we use your data, you may contact us at the above contact details and we will be happy to provide you with further details.
11. LINKS TO OTHER WEBSITES
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.
12. CHANGES TO THIS PRIVACY POLICY
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- This Privacy Policy was last updated 09 November 2020. We reserve the right, at our discretion, to add, modify or remove portions of this Privacy Policy in the future to ensure that the information herein provides
relevant and adequate information about our collecting and processing of your data.
- This privacy policy may be supplemented by other information received from the Trades Point Capital group and other terms and conditions applicable to the Website or which you have agreed to as part of your interaction
with us.
- In case of updates, we will post the revised Privacy Policy on our website. Changes will take effect as soon as the revised version is made available on our website. Your comments and feedback are always welcome.
You may contact us at any time through the points of contact listed in the Section OUR CONTACT DETAILS above.
APPENDIX A
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- 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.