Your privacy is important to us. We are committed to protecting and respecting your personal data, ensuring that when you choose us to use our services, you know what data we collect about you and how we use and protect that personal data. This Privacy Policy describes what types of personal data we collect about you when you choose to use our services, how we will use your personal data and how we will keep it safe. Please take the time to read and clearly understand our Privacy Policy.

  1. WHO WE ARE

1.1. Trader-coins is a trade name of Goldbay LTD company with number 104104, incorporated in the Republic Of The Marshall Islands, whose registered office is Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960), referred to in this Privacy Policy as “The Company”,Trader-coins”, “we” or “our” or “us”.

1.2. We are an online trading platform which assists retail and institutional investors to trade in the margin foreign exchange market (“Forex”) and other derivative instruments. Our online trading platforms operate through the following website: https:// www.trader-coins.com (our “Website”). 

1.3. “customer”, “client”, “you” or “your” means an individual who is the subject of the personal data that we process as a data controller.

  1. SCOPE OF THIS PRIVACY POLICY

2.1. This Privacy Policy (together with our Terms and Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Privacy Policy also sets out how you can instruct us if you prefer to restrict the use of your personal data and the procedures that we have to keep your privacy safe.

2.2. For the purpose of this Privacy Policy, Data Protection Legislation means: the General Data Protection Regulation 2016/679 (the “GDPR”) applicable in the European Union and data protection legislation applicable in other countries. For the purpose of the Data Protection Legislation, the data controller is GOLDBAY LTD.

2.3 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2.4 By using our Website, registering with us or submitting information to us you signify that you have read and understood our collection, use and disclosure of your personal data in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you must not use our Website, access our services or submit any information to us.

  1. DATA WE COLLECT (OR MAY RECEIVE) ABOUT YOU

3.1 The personal data we collect (or receive) about you may include your: (a) name and address; (b) e-mail address; (c) username, password; (d) your IP address; (e) your phone numbers (which could be your home, work or mobile numbers); (f) credit card details; (g) source of wealth information; (h) occupation; (i) bank account details, including institution name, branch, account name, bank id; (j) bank account number or IBAN; or (k) your trading experience information.

3.2 We are required by law to identify you if you are opening a new account or adding a new signatory to an existing account. Anti-money laundering laws require us to sight and record details of certain documents (i.e. photographic and non-photographic documents) in order to meet the standards, set under those laws. Identification documentation, as required under anti-money laundering legislation or other legislation relevant to the services we provide to you, includes: (a) passport; (b) driver’s license; (c) state identity card (if applicable); (d) utility bills; (e) trust deed; (f) a credit check on the individual; or (g) other information we consider necessary to our activities.

3.3 If it is necessary to do so, we also collect data regarding the following individuals: (a) trustees;                             (b) partners; (c) company directors and officers; (d) officers of co-operatives and associations; (e) client agents; or (f) representatives.

  1. HOW WE COLLECT YOUR PERSONAL DATA

4.1 We may collect (or receive) and process your personal data when:  (a) you contact us, whether through our Website, or otherwise (for example, via our online form, by e-mail, post, fax or phone), as we may keep a record of that correspondence. For example, if you submit a complaint, report a problem with our services, contacting with our customer service, technical support or any other department in our company. This includes information provided by you when you update a customer account such as your name, e-mail, address, password, etc.; (b) we ask you to complete surveys that we use for research purposes, although you do not have to respond to them; (c) you use and interact with our Website including your device’s IP address, time zone setting, browser plug-in types and versions, operating system type and version, web platform, and your ISP. We may collect details of your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data). We do this via email and website cookies, and cognate tracking technology built into our Website; (d) you use your customer account to login to and use our platform technology and other features and functionalities; (e) you use the online trading products we provide to you. Under no circumstances are these details disclosed to any third parties other than those who need to know this information in the context of the services we provide.

  1. HOW WE MAY USE YOUR PERSONAL DATA

5.1. We may process your personal data for one or more lawful bases of processing depending on the specific purpose for which we are using your data (see below).

5.2. We may process your personal data for the purpose of: (a) dealing with your inquiries and requests, including contacting you if necessary; (b) notifying you about important changes or developments to our Website, or to our products or services; (c) carrying out our obligations arising from any contracts connected to you; (d) providing and personalizing our services, enhancing customer experience and tailoring our services to you; (e) providing you access to all parts or features of our Website or our services; (f) where applicable, processing your payments; (g) administering your registration and/or membership and other customer accounts records; (h) market research, analysis and creating statistics; (i) sending you marketing communications, for instance, to contact you from time to time regarding things you have told us you want to hear about, such as new products, special offers, competitions and sponsored events; (j) preventing, detecting and investigating potentially prohibited or illegal activities, and enforcing our Terms and Conditions; (k) improving and developing our Website, our products and services, as well as collecting feedback from you about our Website and other activities; (l) ensuring that content from our Website is presented in the most effective manner for you and for your computer; (m) ensuring we have adequate security measures and services so you can safely access our Website; (n) complying with all the applicable laws and regulations; (o) debt recovery or debt tracing, crime, fraud and money laundering compliance;                  (p) monitoring how people use our Website to see if they are being abused or threatened; and (q) testing new systems and processes as we roll them out to make sure they work correctly. 

5.3 We may take steps to verify the data we collect to protect against impersonation.

5.4 We may check some of the information that you provide to us against third party databases to confirm that it is accurate.

5.5 We may have access to your financial information, such as your billing address, bank account details and payment history in order to allow us to take payments from you in connection with the online trading products you purchase, send you refunds or enable our customer service to deal with your enquiries. Under no circumstances are these details disclosed to any third parties except as required by law.

5.6 If you are an existing customer, we may contact you with information, products or services that you request from us or with information, products or services which are similar to the services we are providing to you (independently or jointly with others), unless you have opted out to be contacted for such purposes. We may contact you for this purpose by post, telephone and SMS as well as by email. If you change your mind about being contacted in the future, please let us know.

5.7 We do not sell, rent, or otherwise provide your personal data to third parties unless you consent to this or it is necessary to provide you with our services, conduct our associated business activities or as described in this Privacy Policy. We may share information with any member of our group of companies, which means our subsidiaries.

5.8 If you choose to post messages on any online forum or other message platforms that we may make available for this purpose on our Website, we may collect that information you provide to us. We may process this information as necessary to respond to any social media posts or other public comments you might make, whether they are directed to us or about us, our Website, or other activities, to resolve disputes, provide customer support and troubleshoot problems, as permitted by law. 

5.9 We may place a cookie on your device when you access our Website. These cookies will let us know when you have accessed our Website. We will share this information with our advertising providers. The cookies will let our advertising providers know when to serve ads and to whom, ensuring that our ads are served only to people who have previously visited our Website.

5.10 If you stop using our Website or our services, or your permission to use our Website and our services is terminated, we may continue to use and disclose your personal data in accordance with this Privacy Policy (as amended from time to time) and as permitted by law. However, if you wish us to stop e-mailing you with information in connection with our Website or our services, please unsubscribe or send your request.

  1. YOUR CONTACT INFORMATION

6.1 Where applicable, you can change your contact details at any time by updating your profile within your trading account. You can also update your communication preferences by changing your settings related to your choices of notification.

  1. DATA SECURITY

7.1 The Internet is not a secure source. Please be aware that communications over the Internet, such as                    e-mails/web mails, are not secure unless they have been encrypted. Your communications may route through a number of parties before being delivered. 

7.2 We cannot accept responsibility for any unauthorized access or loss of personal data that is beyond our control. However, the protection of your personal data is extremely important to us and we have put in place a range of security procedures to protect it, as set out in this Privacy Policy.

7.3 Where you have been allocated a trading account, this area is protected by your user name and password, which you should never disclose to anyone else.

7.4 We will use reasonable intention to implement appropriate policies, rules and technical measures to protect the personal data that we have under our control. 

7.5 We will ensure that your information will not be disclosed to government institutions or authorities except if required by law (e.g. when requested by regulatory bodies or law enforcement organizations in accordance with applicable legislation).

  1. TO WHOM WILL YOUR PERSONAL DATA BE DISCLOSED?

8.1 Your personal data may, for the purposes set out in this Privacy Policy, be disclosed for processing to: (a) our affiliated product and service; (b) any person acting on your behalf, including your financial adviser, solicitor, settlement agent, accountant, executor, administrator, trustee, guardian or attorney; (c) your nominated employment reference; (d) introducing brokers, affiliates and agents who refer your business to us; (e) credit reporting agencies; (f) our employees, our Affiliates and their employees; (g) auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;                                      (h) analytics and search engine providers that assist us in the improvement and optimization of our Website; (i) government bodies and law enforcement agencies where required by law and in response to other legal and regulatory requests; (j) to our advertising providers for re-targeting purposes; and (k) where you have consented to this, to selected third parties that may contact you about products and services which may be of interest to you in any jurisdiction where we operate. 

8.2 We use banking agents, for example, local businesses, to help provide you with banking services. These agents can collect personal data on your consent.

8.3 In all circumstances where personal data may become known to our contractors, agents and outsourced service providers, there are confidentiality arrangements in place. 

8.4 Before using or disclosing a government related identifier of an individual, we will ensure that such use or disclosure is: (a) reasonably necessary for us to verify your identity for the purposes of our activities or functions; or (b) reasonably necessary for us to fulfil our obligations to a government agency or authority; or (c) required or authorized by or under applicable law, regulation or a court/tribunal order; or (d) reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

  1. YOUR RIGHTS

9.1 Please note that these rights do not apply in all circumstances. You are entitled to: (a) request access to your personal data (commonly known as a “data subject access request”); (b) request correction of the personal data that we hold about you; (c) request erasure of your personal data; (d) object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms; (e) request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (f) request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine readable format. Note that this right only applies to automated information (i.e. not to hard copies) which you initially provided consent for us to use or where we used the information to perform a contract with you; and (g) withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. 

9.2 We will require proof of your identity before providing you with details of any personal data we may hold about you. 

9.3 We try to respond to all legitimate requests within 1 (one) month. Occasionally, it may take us longer than 1 (one) month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 1 (one) month of the receipt of your request and keep you updated.

9.4 We may charge you a reasonable fee to you when a request is manifestly unfounded, excessive or repetitive, or we receive a request to provide further copies of the same data. Alternatively, we may refuse to comply with your request in these circumstances. 

  1. 10. ACCESS TO A CREDIT REPORT ABOUT YOU

10.1 You have the right to ask for a copy of any credit report we have obtained about you from a credit reporting agency. 

10.2 You have a right to have any inaccuracies corrected or, if there is any dispute as to accuracy, to have a note added to your credit reporting agency file explaining your position.

10.3 If we decline your credit application wholly or partly because of unfavorable information on your credit report, we are required to tell you of that fact.

  1. COOKIES

11.1 We use cookies to store and collect information about your use of our Website. Cookies are small text files stored by the browser on your equipment’s hard drive. They send information stored on them back to our web server when you access our Website. These cookies enable us to put in place personal settings and load your personal preferences to improve your experience. 

  1. 12. WHERE WE STORE AND PROCESS YOUR PERSONAL DATA

12.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or Affiliate companies. Such staff may be engaged in, among other things, the fulfillment of your request, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

  1. 13. Your Consent and Changes to this Privacy Policy

13.1 We reserve the right to amend or modify this Privacy Policy and if we do so we will post the changes on our Website. It is your responsibility to check the Privacy Policy every time you submit your personal data to us.

  1. 14. Use of Your Personal Data Submitted to Other Websites

14.1 Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of personal data that we receive about you or collect from you.

14.2 If you disclose your personal data to others (e.g. websites we link to), different rules may apply to their use or disclosure of the data that you disclose to them. We are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from our website.

14.3 We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.

  1. DATA RETENTION

15.1 We will only retain your personal data for as long as you have consented to it or when is necessary to us to provide you with our services or fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or regulatory requirements. For instance, by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) typically for six years after they cease being customers for tax purposes.

15.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

15.3 In some circumstances you can ask us to delete your data.

15.4 In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. FURTHER INFORMATION

16.1 If you would like to let us know about something we have done, or failed to do in relation to your personal data, whether positive or negative, please let us know. Your comments enable us as an organization to learn and continuously improve our services.

  1. INFORMING US OF CHANGES

17.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

17.2 If your personal details change, please help us to keep your information up to date by notifying us at support@trader-coins.com