Privacy Policy

1. Introduction

TradeCircle ("we", "us", or "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, trading platform, and services (collectively, the "Services").

This policy applies to all clients, website visitors, and users of our Services. By using our Services, you consent to the collection and use of information as described in this policy. If you do not agree to this policy, please do not use our Services.

2. Data Controller

The data controller responsible for your personal data is TradeCircle. Our Data Protection Officer can be contacted at privacy@tradecircle.com.

3. Information We Collect

3.1 Personal Identification Information

• Full name, date of birth, and nationality
• Government-issued identification documents (passport, national ID, driver's licence)
• Proof of address (utility bill, bank statement)
• Photograph or selfie for identity verification

3.2 Financial Information

• Bank account details and payment card information
• Trading history and account balance
• Source of funds and source of wealth documentation
• Tax identification numbers

3.3 Technical and Usage Information

• IP address, browser type, and operating system
• Device identifiers and hardware information
• Pages visited, time spent on pages, and navigation patterns
• Trading activity and platform usage data
• Location data (country/region level)

3.4 Communications

• Email correspondence and support tickets
• Live chat transcripts
• Telephone call recordings (where permitted by law)

4. How We Use Your Information

We use your personal data for the following purposes:

• Account management: To open, maintain, and administer your trading account
• Identity verification: To comply with KYC and AML regulatory requirements
• Trade execution: To process your orders and manage your positions
• Risk management: To assess and monitor trading risks
• Regulatory compliance: To comply with applicable laws, regulations, and regulatory requirements
• Customer support: To respond to your enquiries and provide assistance
• Service improvement: To analyse usage patterns and improve our platform and services
• Marketing: To send you information about products and services that may interest you (with your consent where required)
• Security: To detect and prevent fraud, unauthorised access, and other illegal activities

5. Legal Basis for Processing

We process your personal data under the following legal bases:

• Contractual necessity: Processing is necessary for the performance of our contract with you
• Legal obligation: Processing is required to comply with applicable laws and regulations
• Legitimate interest: Processing is necessary for our legitimate business interests, balanced against your rights
• Consent: Where you have given explicit consent for specific processing activities

6. Data Sharing

We may share your personal data with the following categories of recipients:

• Regulatory authorities: As required by law or regulation
• Financial institutions: Banks, payment processors, and liquidity providers for trade execution and fund management
• Service providers: Technology providers, cloud hosting services, analytics providers, and customer support platforms
• Legal and professional advisors: Lawyers, auditors, and accountants
• Law enforcement: When required by law, court order, or governmental regulation

We do not sell your personal data to third parties.

7. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence, including jurisdictions that may not provide the same level of data protection. Where we transfer data internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Enable core platform functionality and security
• Remember your preferences and settings
• Analyse platform usage and performance
• Deliver relevant marketing communications

You can manage cookie preferences through your browser settings. For detailed information, please see our Cookie Policy.

9. Data Retention

We retain your personal data for as long as necessary to:

• Maintain your account and provide our services
• Comply with legal and regulatory obligations (typically 5-7 years after account closure)
• Resolve disputes and enforce our agreements

10. Your Rights

Under applicable data protection laws, you have the following rights:

• Access: The right to request a copy of the personal data we hold about you
• Rectification: The right to request correction of inaccurate or incomplete data
• Erasure: The right to request deletion of your personal data (subject to legal obligations)
• Restriction: The right to request restriction of processing in certain circumstances
• Portability: The right to receive your data in a structured, commonly used, machine-readable format
• Objection: The right to object to processing based on legitimate interests or direct marketing
• Withdraw consent: The right to withdraw consent at any time where processing is based on consent

To exercise these rights, contact our Data Protection Officer at privacy@tradecircle.com.

11. GDPR Compliance

For clients in the European Economic Area (EEA), United Kingdom, and Switzerland, we comply with the General Data Protection Regulation (GDPR) and equivalent national legislation. Our Data Protection Officer oversees GDPR compliance across all operations.

You have the right to lodge a complaint with your local data protection supervisory authority if you believe your data protection rights have been infringed.

12. Data Security

We implement robust technical and organisational measures to protect your personal data, including:

• AES-256 encryption for data at rest
• TLS 1.3 encryption for data in transit
• Multi-factor authentication for account access
• Regular penetration testing and security audits
• Staff training on data protection and security
• Incident response and breach notification procedures

13. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will take steps to delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or through a prominent notice on our platform. The "Last updated" date at the top of this page indicates when this policy was last revised.

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

• Email: privacy@tradecircle.com
• Data Protection Officer: dpo@tradecircle.com
• Address: TradeCircle UK, 63 Gibson Road, Lincoln, Lincolnshire, United Kingdom, LN2 4NW