WE DEFINE “PII” TO MEAN ANY INFORMATION RELATING TO AN IDENTIFIED OR IDENTIFIABLE NATURAL PERSON; AN IDENTIFIABLE NATURAL PERSON IS ONE WHO CAN BE IDENTIFIED, DIRECTLY OR INDIRECTLY, IN PARTICULAR BY REFERENCE TO AN IDENTIFIER SUCH AS A NAME, AN IDENTIFICATION NUMBER, LOCATION DATA, AN ONLINE IDENTIFIER OR TO ONE OR MORE FACTORS SPECIFIC TO THE PHYSICAL, PHYSIOLOGICAL, GENETIC, MENTAL, ECONOMIC, CULTURAL OR SOCIAL IDENTITY OF THAT NATURAL PERSON.
First Trade Ltd. (the “Company” or “we“), we recognize that privacy is important. This policy applies to all of the software, services, information, tools, features and functionalities available as part of the Services offered by the Company or its subsidiaries or affiliated companies (collectively, the “Services”) and covers how PII that the Company collects and receives, including in respect of any use of the Services, is treated. If you have any questions about this policy, please feel free to contact us at: email@example.com
- Information We Collect and How We Use It
Unless stated otherwise, the Company will not share, sell, auction off or give away your PII to any third-party or other organization without first obtaining your prior written consent.
In order to provide, operate and improve our Services, including without limitation for the marketing and selling of our Services, we may collect and process PII, including the following types of information:
- Information you provide. For some features of the Services we ask you to provide PII, including: name, email address, age, and other personal information.
- Third Parties.We sometimes supplement the information that you provide with information that is received from third parties. If you access the Services through any social network or third party services (“App Platforms“), or interact with any App Platforms or other social media plug-in in the Services (such as a Facebook “Like” button) we may receive information from your respective social media or App Platforms account, including your name, photo, email address, friends list and any information defined as public pursuant to the policies of such App Platforms.
- Personal information. We process your PII only for specific and limited purposes, including the provision of the Services. We ask only for PII that is adequate, relevant and not excessive for those purposes. Some of these purposes may include to inform you of new services and features we will be providing, to send you requested information and additional materials in respect of the Services, for promotional purposes and market research, and internally to help us improve our Services and to help resolve any problems.
- User information. When you use the Services, we may automatically receive and record information from your device and browser, including without limitation PII such as information and statistics about your online/offline status, your IP address, cookie information, visitor traffic, page hits, site referral information, downloads, access times, internet service provider, search history, type of browser, track clickstream behavior (e.g. the pages you view, the links you click and any other actions you take using the Services), the address of the website from which you arrived at the Services, your regional and language settings and software and hardware attributes. Our systems may automatically record and store technical information regarding the method and nature of your use of the Services We use your IP address to help with server problem diagnosis and to administer the Services. An IP address is a numeric code that identifies your browser on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. The Company uses all of the PII that we collect to understand the usage trends and preferences of our users.
- User communications. When you send email or other communication to the Company, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. We may, at some time, also send you newsletters and promotional communications subject to joining a mailing list, at any time you may opt-out of such service by submitting a request at a link that will be provided. Please note that even if you opt out of receiving the foregoing communications, we may still send you a response to any “Contact Us” request as well as administrative e-mails (e.g. in connection with password reset request) necessary to facilitate your use of the Services.
- Financial Information. When you purchase/ subscribe to our services, you will be asked to provide credit card and/or billing information. We will use the credit card and/or billing information provided in connection with a user’s purchase to process your order and for no other purpose.
- Aggregate and Analytical Data. In an ongoing effort to better understand and serve the customers of the Services, we often conduct research on our customer demographics, interests and behavior based on the PII and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may freely share, disclose, transfer and exploit this aggregate data in any manner and at our sole discretion. This aggregate information does not identify you personally. We may also disclose aggregated user statistics to third parties, including without limitation to current and prospective business partners, and to other third parties for other lawful purposes. We also use aggregate data for monetization.
- Cookies and Web Beacons. In order to collect and analyze the data described herein, we may use temporary cookies that remain on your browser or device for a limited period of time and persistent cookies that remain on your browser or device until you clean cookies from your browser or device. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your browser or device. Cookies do not damage your browser or device. Most browsers may allow you to block cookies but you may not be able to use some features on the Services if you block them. You may set your preferences so that you will be notified when you receive a cookie (this enables you to decide if you want to accept it or not). We may also use web beacons via the Services to collect information. Web beacons or “gifs”, are electronic images that may be used in our Services or in our emails. We use web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon.
- If you are a child under the age of 18, you must obtain parental consent prior to using our Services. The Company will not knowingly contact or engage with children under the age of 18 without said parental consent. If you have reason to believe that a child under the age of 18 has provided us with their PII, please contact us at the address given above and we will endeavor to delete that PII from our databases.
- Information We may also share PII with third parties in the following circumstances: (a) with our affiliates, agents, representatives, trusted business partners and third party service providers that we use as subcontractors; (b) if we become involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of our assets, with any type of entity, whether public, private, foreign or local; and/or (c) to satisfy applicable law or prevention of fraud or harm or to enforce applicable agreements and/or their terms, including investigation of potential violations thereof.
- Information Security. We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.
- Data Retention. We retain your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
- Your Rights.
- Right of Access and Rectification. You have the right to know what PII we collect about you and to ensure that such data is accurate and relevant for the purposes for which we collected it. We allow our users the option to access and obtain a copy of their PII and to rectify such PII if it is not accurate, complete or updated. However we may first ask you to provide us certain credentials to permit us to identify your PII.
- Right to Delete PII or Restrict Processing. You have the right to delete your PII or restrict its processing. We may postpone or deny your request if your PII is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.
- Right to Withdraw Consent. You have the right to withdraw your consent to the processing of your PII. Exercising this right will not affect the lawfulness of processing your PII based on your consent before its withdrawal.
- Right of Data Portability. Where technically feasible, you have the right to ask to transfer your PII in accordance with your right to data portability.
You may exercise the above rights by sending a request to firstname.lastname@example.org
- Right to Lodge Complaint. You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your PII.
- Questions. If you have any questions about this policy or concerns about the way we process your PII, please contact us at email@example.com If you wish to delete all information regarding your use of the Services, please contact us at firstname.lastname@example.org
- Your California Privacy Rights and Do Not Track Notices. California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding the disclosure of their PII to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com Please note that we are only required to respond to one request per customer each year. You are also advised that Company does not respond to “Do Not Track” signals.
Last Date Updated: March 2020