Trade Way
        Privacy Policy

                        Privacy Policy
                        

What is the purpose of this policy? 

1. Purpose of This Privacy Policy

The purpose of this Privacy Policy is to explain what personal information we collect from users of the Trade Way application and how we use, store, process, and protect such information.

2. Scope of Application

This Privacy Policy describes how Trade Way collects and processes your personal information through the Trade Way mobile application, and any related websites or services that explicitly reference this Privacy Policy.

This Privacy Policy applies only to the Trade Way application and does not apply to any other applications, platforms, or services operated by the same company unless explicitly stated otherwise.

3. Definitions

For the purposes of this Privacy Policy:

- “Trade Way”, “we”, “our”, or “us” refers to the company operating the Trade Way mobile application and related services.

- “Personal Information” means any information that identifies or can reasonably be linked to an identifiable individual.

Legal Entity and Regulatory Information:

TRADEWILL GLOBAL MARKETS LTD, (legal entity code: 16034448, registered office address:Suite 8695 61 Bridge Street, Kington,United Kingdom, HR5 3DJ) is the Data Controller for personal information collected and processed in connection with provision of Trade Way Services. 

1. What Personal Information About Users Does Trade Way Collect? 

Trade Way collects your personal information in order to provide and continually improve our products and services. 

Here are the types of personal information we collect: 

Information you give us: we receive and store any information you provide in relation to Trade Way. You can choose not to provide certain information, but then you might not be able to use some Trade Way Services. Examples of information that you give us include: 

• email address 

• name 

• gender 

• date of birth 

• home address 

• nationality 

• country code 

• IP address  

• operating system 

other information to help us identify you 

Automatically Collected information: we automatically collect and store certain types of information about your use of Trade Way Services including your interaction with content and services available through Trade Way Services. Like many websites, we use cookies and other unique identifiers and we obtain certain types of information when your web browser or device accesses Trade Way Services. Examples of the information we collect and analyse include: 

the Internet protocol (IP) address used to connect your computer to the Internet, 

login, e-mail address, password and location of your device or computer; 

Trade Way Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences); 

version and time zone settings; 

transaction history. 

Information from other sources: we may receive information about you from other sources such as credit history information from credit bureaus, which we use to help prevent and detect fraud. 

2. Can Children Use Trade Way Services? 

Trade Way does not allow anyone under the age of 18 to use Trade Way Services. 

3. For What Purposes Does Trade Way Process My Personal Information? 

We process your personal information to operate, provide, and improve the Trade Way Services that we offer our users. These purposes include: 

Transaction services. We use your personal information to take and handle orders, process payments, and communicate with you about orders and services, and promotional offers. 

Provide, troubleshoot, and improve Trade Way Services. We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of Trade Way Services. 

Recommendations and personalisation. We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with Trade Way Services. 

Comply with legal obligations. In certain cases, we collect and use your personal information to comply with laws and regulations. For instance, we collect bank account information for identity verification and other purposes. 

Communicate with you. We use your personal information to communicate with you in relation to Trade Way Services. 

Fraud prevention and credit risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our users, Trade Way Services and others. We may also use scoring methods to assess and manage credit risks. 

Purposes for which we seek your consent. We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose. 

4. What About Cookies and Other Identifiers? 

We use cookies and similar tools to enhance our user experience, provide our services, and understand how customers use our services so we can make improvements. To enable our systems to recognise your browser or device and to provide Trade Way Services to you, we use cookies. 

We use operational cookies and similar tools (collectively, "cookies") to provide our services, for example: 

Recognising you when you sign-in to use our services. 

Providing customised features and services. 

Displaying features and services which might be of interest to you, including ads on our services. 

Preventing fraudulent activity. 

Improving security. 

Keep track of your preferences, such as currency and language. 

We also use cookies to understand how users use our services, so we can make improvements. 

The settings on your browser will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable and remove cookies, and when cookies will expire. 

Operational cookies allow you to take advantage of some of Trade Way's essential features. If you block or otherwise reject operational cookies through your browser settings some features and services may not work. 

5. Does Trade Way Share My Personal Information? 

Information about our users is an important part of our business and we are not in the business of selling our users' personal information to others.   Trade Way shares users' personal information only as described below and with the subsidiaries or affiliates of Trade Way that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice. 

Third party service providers: We employ other companies and individuals to perform functions on our behalf.  Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk.  These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as only permitted by applicable data protection laws. 

Third-party SDKs integrated within our App:

Our app also integrates several third-party software development kits (SDKs) that help us provide essential functions such as analytics, attribution, optimisation, login, customer support, and crash reporting.

These SDKs may collect limited technical or device-related information (such as advertising identifiers, device type, app version, usage statistics, or performance data) to improve app stability and measure marketing effectiveness.

We do not share any sensitive user-uploaded materials — including identity verification (KYC) documents, proof of address, proof of payment, physical address, or phone number — with these SDKs.

All KYC and related verification materials remain securely stored on our own protected servers and are never transmitted to any third-party analytics, advertising, or support provider.

Third-party SDKs used by the app include:

Google Play Services — Core Android service support

Google Analytics for Firebase — App analytics and usage statistics

Firebase Crashlytics — Crash diagnostics and performance monitoring

Google Sign-In SDK — Quick login with Google account authentication


Adjust SDK —— Marketing attribution, Performance, Campaign Tracking


Facebook SDK  —— Login and Marketing attribution.

Zendesk — Customer support chat and ticket management

We have entered into appropriate data processing agreements with these SDK providers to ensure that any personal data they process is handled solely for the specified purposes and in compliance with applicable data protection laws.

Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that Trade Way or substantially all of its assets are acquired, user information will be one of the transferred assets. 

Protection of Trade Way and others: We release account and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of Trade Way, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. 

6. International transfers of personal data 

Trade Way may transfer your data outside of the European Economic Area (“EEA”). Trade Way puts in place suitable safeguards to ensure that such transfer is carried out in compliance with applicable data protection rules, except where the country to which the data is transferred has already been determined by the European Commission to provide an adequate level of protection. 

Where Trade Way transfers personal data to affiliates or service providers, Trade Way relies on the standard contractual clauses approved by the European Commission. 

7. How Secure is My Information? 

We design our systems with your security and privacy in mind.  We work to protect the security of your personal information during transmission by using encryption protocols and software. 

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may ask you to verify your identity before we disclose personal information to you. 

It is important for you to protect against unauthorised access to your account password. We recommend using a unique password for your Trade Way account that is not utilized for other online accounts. Be sure to sign off when you finish using a shared computer. 

8. What About Advertising? 

We may share your personal information with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising. Direct marketing 

If you receive newsletters or other email messages from us, you can opt out at any time free of charge by contacting us via tradew2012@gmail.com. 

9. What Information Can I Access? 

You can access your information, including your name, address, payment options, profile information, and transaction history in the "Your Account" section of the website. 

10. What Choices Do I Have? 

If you have any questions or objections as to how we collect and process your personal information, please contact tradew2012@gmail.com 

When you consent to our processing of your personal information for a specified purpose, you may withdraw your consent at any time and we will stop any further processing of your data for that purpose. 

In addition, subject to applicable law, you have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances. If you wish to do any of these things, please contact via tradew2012@gmail.com. 

11. How Long Does Trade Way Keep My Personal Information? 

We keep your personal information to enable your continued use of Trade Way Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Notice, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to you. 

12. ERASING YOUR PERSONAL INFORMATION  

12.1 When can you request erasure?  

12.1.1 You have a right to have your personal information erased, and to prevent processing,  

12.1.2 The personal information is no longer necessary for the purpose it was originally collected/processed  

12.1.3 You withdraw consent (where previously provided)  

12.1.4 You object to processing and our legitimate interests in being able to keep processing your personal information do not take priority  

12.1.5 we have been processing your personal information in breach of data protection laws  

12.1.6 the personal information has to be erased in order to comply with a legal obligation.  

12.2 When can we refuse erasure requests?  

The right to erasure does not apply where we are required to retain it for legal or regulatory purposes or where your personal information is processed for certain specified reasons, including for the exercise or defence of legal claims.More importantly, if we have to erase your data, we may not be able to provide you with part or all of our services.  

12.3 Do we have to tell other recipients of your personal information about your erasure request?  

Where we have provided the personal information you want to erase to third parties, we need to inform them about your erasure request, so they can erase the personal information in question. We will take reasonable steps to do this, but this may not always be possible or may involve a disproportionate effort. It may also be that the recipient is not required/able to erase your personal information because one of the exemptions above applies. 

13. EU GDPR and UK Data Protection Laws - Legal Basis 

The EU GDPR and UK data protection laws require a legal basis for our use of personal information. Our basis varies depending on the specific purpose for which we use personal information. We rely on: 

Performance of a contract when we provide you with products or services, or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments. 

Our legitimate business interests and the interests of our users when we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others. 

Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose. 

Compliance with a legal obligation when we use your personal information to comply with laws. For instance, we collect bank account information for identity verification purposes. 

These and other legal bases depending on the purpose for which we use personal information. 

14. Contact Information 

Our data protection officer can be contacted at tradew2012@gmail.com and will work to address any questions or issues that you have with respect to the collection and processing of your personal information. 

15. Conditions of Use, Notices and Revisions 

If you choose to use Trade Way Services, your use and any dispute over privacy is subject to this Notice and our Terms of Use. If you have any concerns about privacy at Trade Way, please contact us with a thorough description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority. 

Our business changes constantly, and our Privacy Notice will change also. You should check our websites frequently to see recent changes. If you do not agree with the revised content, you should stop accessing Trade Way immediately. When an updated version of the Privacy Policy is released, your continued access to Trade Way means that you agree to the updated content and agree to abide by the updated Privacy Policy. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account. 

If we can show compelling legitimate grounds for processing your personal information that overrides your interests, rights, and freedoms, or we need your personal information to establish, exercise, or defend legal claims, we can continue to process it. Otherwise, we must stop using relevant personal information. 

What are your privacy rights? 

This section explains your rights in relation to your personal information in more detail.  

To exercise any of the rights described below, please contact us via tradew2012@gmail.com 

16. ACCESSING YOUR PERSONAL INFORMATION 

When can you request access? 

You have the right to: 

confirm that your personal information is being processed 

access your personal information. 

You can request copies of the paper and electronic records about you that we hold, share, or use. To deal with your request, we can request proof of identity and enough personal information to enable us to locate the personal information you request.  

When will access not be provided? 

We can only provide you with your personal information, not personal information about another person. Also, where access would adversely affect another person’s rights, we are not required to provide this. Due to legal privilege, we may not be able to show you anything that we learned in connection with a claim or legal proceeding. 

Please clearly set out in your access request the personal information that you are requesting. If this is not clear, we may come back to you to ask for further personal information by way of clarification. 

If you receive newsletters or other email messages from us, you can opt out at any time free of charge by contacting us via tradew2012@gmail.com 

17. ERASING YOUR PERSONAL INFORMATION 

When can you request erasure? 

You have a right to have your personal information erased, and to prevent processing, where: 

Personal information is no longer necessary for the purpose it was originally collected/processed 

you withdraw consent (where previously provided) 

 You object to the processing and our legitimate interests in being able to keep processing your personal information do not take priority 

We have been processing your personal information in breach of data protection laws 

Personal information has to be erased in order to comply with a legal obligation. 

When can we refuse erasure requests?  

The right to erasure does not apply where we are required to retain it for legal or regulatory purposes or where your personal information is processed for certain specified reasons, including for the exercise or defence of legal claims. 

 More importantly, if we have to erase your data, we may not be able to provide you with part or all of our services. 

 Do we have to tell other recipients of your personal information about your erasure request? 

Where we have provided the personal information you want to erase to third parties, we need to inform them about your erasure request, so they can erase the personal information in question. We will take reasonable steps to do this, but this may not always be possible or may involve a disproportionate effort. 

 It may also be that the recipient is not required/able to erase your personal information because one of the exemptions above applies. 18. Data Deletion Requests

You may request the deletion of your personal data at any time through the following methods:

In-App: Go to Settings > Account and Security > Delete Account

Email: Send your request to tradew2012@gmail.com

 with the subject line “Data Deletion Request”.

Once we receive your verified request, we will delete your personal data within a reasonable period unless retention is required by law or regulation.

18. RESTRICTING PROCESSING OF YOUR PERSONAL INFORMATION 

When is restriction available? 

You have the right to restrict the processing of your personal information: 

If you disagree with the accuracy of personal information, we need to restrict the processing until we have verified the accuracy of the personal information 

when processing is unlawful and you oppose erasure and request restriction instead 

if we no longer need personal information, but you need this to establish, exercise, or defend a legal claim 

where you have objected to the processing in the circumstances detailed in paragraph (a) of ‘Objecting to Processing’, and we are considering whether those interests should take priority. 

Do we have to tell other recipients of your personal information about the restriction? 

Where we have disclosed your relevant personal information to third parties, we need to inform them about the restriction on the processing of your personal information, so that they do not continue to process this.  

We will take reasonable steps to do this, but this may not always be possible or may involve a disproportionate effort.  

We will also let you know if we decide to lift a restriction on processing. 

TAKING YOUR PERSONAL INFORMATION WITH YOU 

When does the right to data portability apply? 

The right to data portability only applies: 

to the personal information you have provided to us (which means, not any other information) 

where the processing is based on your consent or for the performance of a contract 

when processing is carried out by automated means. 

When can we refuse requests for data portability? 

We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal information concerns more than one individual, we may not be able to transfer this to you if doing so would prejudice that person’s rights. 

OBJECTING TO PROCESSING 

You can object to processing in the following circumstances: 

Legitimate interests 

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal information concerning you which is based on legitimate interests.  

If we can show compelling legitimate grounds for processing your personal information that overrides your interests, rights, and freedoms, or we need your personal information to establish, exercise, or defend legal claims, we can continue to process it. Otherwise, we must stop using relevant personal information. 

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us by tradew2012@gmail.com.

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