This Privacy Policy describes how our company collects and processes your personal information through the websites and applications that reference this Privacy Notice. Our company refers to an ecosystem comprising websites, mobile applications, clients, and other applications that are developed to offer our services, and includes independently-operated platforms, websites, and clients within the ecosystem (e.g., our company’s Open Platform). “Our company Operators” refer to all parties that run our services, including but not limited to legal persons, unincorporated organizations, and teams that provide services and are responsible for such services. “Our company” as used in this Policy includes our company Operators.
This Privacy Policy applies to all platforms, websites, and departments of our company and our company Operators. By using our services, you are consenting to the collection, storage, processing, and transfer of your personal information as described in this Privacy Policy.

Legal Entity and Regulatory Information

1. TRADEV MARKETS LIMITED

Register Number: HE 419268

Registered Address: IRIS HOUSE, Floor 7, Flat 740B, John Kennedy, Limassol 3106, Cyprus

2. DEEPAK PAL PROPRIETOR INVESTOGAINER RESEARCH

Register Number: INH000012856

Registered Address: Office No. 101, Sairam Plaza, 63 Mangal Nagar, A.B. Road, Indore, Madhya Pradesh, 452001, India.
(Content Analysis Provided)
      Statement: This registered entity provides content analysis exclusively for the TW Trade application (Package name: com.tw.pro). We only provide research content support and compliance guidance for TRADEV MARKETS LIMITED’s business activities targeting users in India, and do not participate in the design, development, operation, or client fund management of any of its financial products.

 TRADEV MARKETS LIMITED shall bear sole responsibility for all its business activities and operations within the scope of the financial services it provides.

1. What Personal Information About Users Do We Collect?  

We collect 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 We. You can choose not to provide certain information but then you might not be able to use some Our services. Examples of information that you give us include email address, name, gender, date of birth, home address, nationality, country code, and other information to help us identify you.  When you register and log in to your account, depending on the method of registration, you may need to provide the following information:

We collect your personal information in order to provide and continually improve our products and services.

(a) Information You Provide Directly

We receive and store any information you provide in relation to our services. You can choose not to provide certain information, but this may limit your ability to use some features.

Examples include:

Email address, name, gender, date of birth, home address, nationality, and country code.

Information required to identify you and set up your account.

Registration and login details:

Register using email: email address and password.

Register/login using a third-party account (Google, Facebook): email address only.

Google login: we only collect the email address associated with your Google account.

Facebook login: we only collect the email address associated with your Facebook account.

(b) Information Collected Automatically

We may automatically collect and store certain types of information about your use of our services, including your interactions with content and features. Like many websites, we use cookies and similar identifiers.

Examples include:

Internet Protocol (IP) address used to connect your device to the Internet (for security, fraud prevention, and regional service availability).

Service metrics (e.g., technical errors, feature usage, and settings preferences).

Version and time zone settings.

Transaction history.

Note: We do not collect precise location data or device identifiers directly. Certain technical data may be processed by third-party SDKs or service providers (see section 6).

(c) Information From Other Sources

We may also receive information about you from other sources.

Examples include:

Credit history information from credit bureaus, which we use to help prevent and detect fraud.

Publicly available information from social media platforms and public registers.

(d) User Rights

You have the right to access your personal information, except in cases provided by laws and regulations. We implement measures to protect the security of your information and prevent unauthorized access or disclosure.

2. Can Children Use Our Services?  

  We do not allow anyone under the age of 18 to use our Services. 

3. For What Purposes Do We Process My Personal Information?  

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

· where that information has been made publicly available, social media platforms and public information service providers such as public registers (this information may be used to supplement our customer databases and for marketing and business development purposes);  

• 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 ouring, and improve our services. We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of Our services.  

• Recommendations and personalization  

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 our 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 Our 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, Our 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 process identity documents, financial information, and contact details to perform Know Your Customer (KYC) checks and comply with Anti-Money Laundering (AML) requirements.

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 your 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 Our 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.  

· Keeping 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 We's essential features. If you block or otherwise reject operational cookies through your browser settings, some features and services may not work. 

5. Does Our Company 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. We share users' personal information only as described below and with the subsidiaries or affiliates of We that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.  

5.1 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.  

5.2  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 We or substantially all its assets are acquired, user information will be one of the transferred assets. 

5.3 Protection of We 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 We, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. 

6. Third-Party SDKs and Analytics Tools

To provide our services, improve functionality, and enhance user experience, our application integrates with certain third-party SDKs and analytics tools. These third-party providers may process device information, identifiers, usage data, or crash logs as required for their functions. They are contractually restricted from using this data for any other purposes, and are required to handle it in compliance with applicable data protection laws.

6.1 Customer Support

Zendesk (Zendesk Inc.) — Data storage location: United States, Asia-Pacific, or European Union. Used to provide customer service, manage tickets, and support communications.

6.2 Messaging & Email Delivery

Benchmark Email (Benchmark Email, Inc.) — United States. Used for email delivery and customer communications.

6.3 Analytics & Crash Reporting

 Google Play Services — provides core Android services for authentication, updates, and app functionality.

Firebase Analytics (Google LLC) — may process advertising identifiers (e.g., GAID/IDFA), IP address, and app usage data for performance analysis, attribution reporting, and fraud prevention.

Firebase Crashlytics (Google LLC) — collects crash logs, device model, OS version, and app version information to improve stability and user experience.

6.4 Marketing & Attribution

Facebook SDK (Meta Platforms, Inc.) — may collect advertising identifiers (e.g., GAID/IDFA), device information, and app events to support ad targeting, campaign measurement, and analytics.

Adjust SDK (Adjust GmbH) — processes advertising identifiers (GAID/IDFA), IP address, and device-related information for mobile attribution, campaign optimization, and fraud detection.

7. Where Your Data is Stored

  Your personal information may be processed and stored on servers located outside your country of residence. We implement appropriate safeguards to ensure your data remains protected in accordance with applicable laws.

8. 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 We account that is not utilized for other online accounts. Be sure to sign off when you finish using a shared computer.  

9. 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.  

10. 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.  

11. What Choices Do I Have?  

If you have any questions or objection as to how we collect and process your personal information, please contact us onetrader2008@gmail.com

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 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 us onetrader2008@gmail.com

12. How Long Do We Keep My Personal Information?  

We keep your personal information to enable your continued use of Our 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.  

13. 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 Or the purpose for which it was originally collected or processed.  

12.1.3 You withdraw consent (where previously provided)  

12.1.4 you object to the 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 be erased 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.  

14. 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 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 apply depending on the purpose for which we use personal information.  

15. Contact Information  

Our data protection officer can be contacted at onetrader2008@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.  

16. Conditions of Use, Notices and Revisions  

If you choose to use Our 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 We, 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 shall stop accessing We immediately. When an updated version of the Privacy Policy is released, your continued access to We 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.