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1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the
personal data of our website visitors and service users; in other words, where we determine
the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for
the provision of our website and services, we will ask you to consent to our use of cookies
when you first visit our website.
1.4 In this policy, "we", "us" and "our" refer to Trademum. For more information about us,
see Section 13.
2. How we use your personal data
2.1 In this Section 2 we have set out:
- (a)the general categories of personal data that we may process;
- (b)the purposes for which we may process personal data; and
- (c)the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage
data may include your IP address, geographical location, browser type and version, operating
system, referral source, length of visit, page views and website navigation paths, as well
as information about the timing, frequency and pattern of your service use. The source of
the usage data is our analytics tracking system. This usage data may be processed for the
purposes of analysing the use of the website and services. The legal basis for this
processing is consent our legitimate interests, namely monitoring and improving our website
and services.
2.3 We may process your account data ("account data"). The account data may include your
nickname and email address. The source of the account data is you. The account data may be
processed for the purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our legitimate interests,
namely the the performance of an agreement between you and us and/or taking steps, at your
request, to enter into such an agreements.
2.4 We may process your information included in your personal profile on our website
("profile data"). The profile data may include your nickname, email address. The profile
data may be processed for the purposes of enabling and monitoring your use of our website
and services. The legal basis for this processing is our legitimate interests, namely the
performance of an agreement between you and us and/or taking steps, at you request, to enter
into such an agreement.
2.5 We may process information contained in any enquiry you submit to us regarding goods
and/or services ("enquiry data"). The enquiry data may be processed for the purposes of
offering, marketing and selling relevant goods and/or services to you. The legal basis for
this processing is consent.
2.6 We may process information relating to our customer relationships, including customer
contact information ("customer relationship data"). The customer relationship data may
include your nickname, your contact details, and information contained in communications
between us and you. The source of the customer relationship data is you. The customer
relationship data may be processed for the purposes of managing our relationships with
customers, communicating with customers, keeping records of those communications and
promoting our products and services to customers. The legal basis for this processing is our
legitimate interests, namely the proper management of our customer relationships.
2.7 We may process information relating to transactions, including purchases of goods and
services, that you enter into with us and/or through our website ("transaction data"). The
transaction data may include your contact details and the transaction details. The
transaction data may be processed for the purpose of supplying the purchased goods and
services and keeping proper records of those transactions. The legal basis for this
processing is the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract and our legitimate interests, namely the proper
administration of our website and business.
2.8 We may process information contained in or relating to any communication that you send
to us ("correspondence data"). The correspondence data may include the communication content
and metadata associated with the communication. Our website will generate the metadata
associated with communications made using the website contact forms. The correspondence data
may be processed for the purposes of communicating with you and record-keeping. The legal
basis for this processing is our legitimate interests, namely the proper administration of
our website and business and communications with users.
2.9 We may process your crypto currency exchange transactions information ("trading data").
This data may include openings and closures and other details of your deals on crypto
currency exchange markets. The source of this data is your accounts on crypto currency
exchange platforms which you shared with us deliberately. This data may be processed for the
purposes of providing relevant goods and/or services to you. The legal basis for this
processing is the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract.
2.10 We may process any of your personal data identified in this policy where necessary for
the establishment, exercise or defence of legal claims, whether in court proceedings or in
an administrative or out-of-court procedure. The legal basis for this processing is our
legitimate interests, namely the protection and assertion of our legal rights, your legal
rights and the legal rights of others.
2.11 We may process any of your personal data identified in this policy where necessary for
the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining
professional advice. The legal basis for this processing is our legitimate interests, namely
the proper protection of our business against risks.
2.12 In addition to the specific purposes for which we may process your personal data set
out in this Section 2, we may also process any of your personal data where such processing
is necessary for compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
2.13 Please do not supply any other person's personal data to us, unless we prompt you to do
so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means
our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as
reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar
as reasonably necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, obtaining professional advice, or the establishment, exercise or defence of
legal claims, whether in court proceedings or in an administrative or out-of-court
procedure.
3.3 We may disclose your trading data to our users insofar as reasonably necessary for
fulfilling our obligations as per an agreement with our users. The legal basis for this
disclosure is the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract.
3.4 Financial transactions relating to our website and services are handled by our payment
services providers. We will share transaction data with our payment services providers only
to the extent necessary for the purposes of processing your payments, refunding such
payments and dealing with complaints and queries relating to such payments and refunds.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we
may disclose your personal data where such disclosure is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital interests or the
vital interests of another natural person. We may also disclose your personal data where
such disclosure is necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1 This Section 6 sets out our data retention policies and procedure, which are designed to
help ensure that we comply with our legal obligations in relation to the retention and
deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
4.3 Notwithstanding the other provisions of this Section 4, we may retain your personal data
where such retention is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital interests of another
natural person.
5. Amendments
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this
policy.
6. Your rights
6.1 In this Section 6, we have summarised the rights that you have under data protection law.
Some of the rights are complex, and not all of the details have been included in our
summaries. Accordingly, you should read the relevant laws and guidance from the regulatory
authorities for a full explanation of these rights.
6.2 Your principal rights under data protection law are:
- (a) the right to access;
- (b) the right to rectification;
- (c) the right to erasure;
- (d) the right to restrict processing;
- (e) the right to object to processing;
- (f) the right to data portability;
- (g) the right to complain to a supervisory authority; and
- (h) the right to withdraw consent.
6.3 You have the right to confirmation as to whether or not we process your personal data
and, where we do, access to the personal data, together with certain additional information.
That additional information includes details of the purposes of the processing, the
categories of personal data concerned and the recipients of the personal data. Providing the
rights and freedoms of others are not affected, we will supply to you a copy of your
personal data. The first copy will be provided free of charge, but additional copies may be
subject to a reasonable fee. You can access your personal data when logged into our website.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking
into account the purposes of the processing, to have any incomplete personal data about you
completed.
6.5 In some circumstances you have the right to the erasure of your personal data without
undue delay. Those circumstances include: the personal data are no longer necessary in
relation to the purposes for which they were collected or otherwise processed; you withdraw
consent to consent-based processing; you object to the processing under certain rules of
applicable data protection law; the processing is for direct marketing purposes; and the
personal data have been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for exercising the
right of freedom of expression and information; for compliance with a legal obligation; or
for the establishment, exercise or defence of legal claims.
6.6 In some circumstances you have the right to restrict the processing of your personal
data. Those circumstances are: you contest the accuracy of the personal data; processing is
unlawful but you oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or defence of
legal claims; and you have objected to processing, pending the verification of that
objection. Where processing has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your consent; for the
establishment, exercise or defence of legal claims; for the protection of the rights of
another natural or legal person; or for reasons of important public interest.
6.7 You have the right to object to our processing of your personal data on grounds relating
to your particular situation, but only to the extent that the legal basis for the processing
is that the processing is necessary for: the performance of a task carried out in the public
interest or in the exercise of any official authority vested in us; or the purposes of the
legitimate interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal information unless we can demonstrate compelling
legitimate grounds for the processing which override your interests, rights and freedoms, or
the processing is for the establishment, exercise or defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you make such an
objection, we will cease to process your personal data for this purpose.
6.9 You have the right to object to our processing of your personal data for scientific or
historical research purposes or statistical purposes on grounds relating to your particular
situation, unless the processing is necessary for the performance of a task carried out for
reasons of public interest.
6.10 To the extent that the legal basis for our processing of your personal data is:
- (a) consent; or
- (b) that the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a contract,
- and such processing is carried out by automated means, you have the right to receive your
personal data from us 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.
6.11 If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your habitual
residence, your place of work or the place of the alleged infringement.
6.12 To the extent that the legal basis for our processing of your personal information is
consent, you have the right to withdraw that consent at any time. Withdrawal will not affect
the lawfulness of processing before the withdrawal.
6.13 You may exercise any of your rights in relation to your personal data by written notice
to us, in addition to the other methods specified in this Section 6.
7. About cookies
7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is
sent by a web server to a web browser and is stored by the browser. The identifier is then
sent back to the server each time the browser requests a page from the server.
7.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie
will be stored by a web browser and will remain valid until its set expiry date, unless
deleted by the user before the expiry date; a session cookie, on the other hand, will expire
at the end of the user session, when the web browser is closed.
7.3 Cookies do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information stored in and
obtained from cookies.
8. Cookies that we use
8.1 We use cookies for the following purposes:
- (a) authentication - we use cookies to identify you when you visit our website and as you
navigate our website;
- (b) status - we use cookies to help us to determine if you are logged into our website;
- (c) security - we use cookies as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login credentials, and to protect our
website and services generally;
- (d) analysis - we use cookies to help us to analyse the use and performance of our website
and services; and
- (e) cookie consent - we use cookies to store your preferences in relation to the use of
cookies more generally.
9. Managing cookies
9.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods
for doing so vary from browser to browser, and from version to version. You can however
obtain up-to-date information about blocking and deleting cookies via these links:
- (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
- (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- (d)
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
- (e) https://support.apple.com/kb/PH21411 (Safari);
- (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge);
9.2 Blocking all cookies will have a negative impact upon the usability of many websites.
9.3 If you block cookies, you will not be able to use all the full list of features on our
website.
10. Our details
10.1 This website is owned and operated by Trademum.
10.2 We are registered in Saint Vincent and the grenadines and our registered office is at
207Griffith center, Beachmont, Kingstown.
10.3 You can contact us:
- (a) by post, to the postal address given above;
- (b) using our website contact form;
- (c) by email, using the email address published on our website hello@trademum.com
It's quick and easy, and our support team is available 24/7 to assist you. Chat with us on LiveChat if you have any questions.