Privacy Policy

Privacy Policy

INTRODUCTION

1. SCOPE 

TradeBuddies, a company established under the laws of the British Virgin Islands (“Company,” “we,” “us,” and “our”), values your privacy and is committed to safeguarding it by adhering to the terms outlined in this Privacy Policy (the “Policy”). The terms “you” or “your” refer to users of the Platform, including visitors, registered customers, or employees of a Company customer.

This Policy outlines:

  1. The types of information we collect from you or that you may provide when you access or use our TradeBuddies platform and services (collectively referred to as the “Platform”).

  2. Our practices regarding the collection, use, maintenance, protection, and disclosure of your information.

This Policy applies to your information we collect on the Platform, in emails, and other electronic communications such as chat messages and support tickets, between you and the Platform, or any information you choose to provide to us.

This Policy does not cover personal information collected offline, through other websites operated by the Company or third parties, or by third parties through applications or content (including ads) linked to or accessible from the Platform. Additionally, the Company does not control the blockchain protocols used for digital assets or regulate the activities or data associated with those protocols.

If you are an individual, you must be at least eighteen (18) years old, or the minimum age required under applicable laws in your country, whichever is higher, to be considered a user. Therefore, we do not intentionally collect or use information from individuals under the age of 18 without the consent of a parent or guardian. We encourage parents and guardians to take appropriate measures to prevent minors from unintentionally sharing personal information online. If we become aware that we have collected personal information from individuals under 18 without parental or guardian consent, we will take immediate action to securely remove it from our systems.

Please read this Policy carefully to understand our practices for handling your personal data. If you do not agree with this Privacy Policy, please do not use our services or share your personal data with the Platform. Please be aware that we may amend or revise this Policy at any time. Continued use of our Platform following any amendments constitutes your acceptance of the changes, so we encourage you to review the Policy periodically for updates.

2. PURPOSE

This Privacy Policy aims to inform you about the following aspects:

  • Who is responsible for safeguarding your information;

  • The types of personal data we may collect about you and the ways it may be used;

  • The sources from which we collect your information;

  • The circumstances under which we may share your personal information with third parties;

  • Your rights as a data subject;

  • The Company’s obligations as a data controller;

  • The security measures implemented to protect against the loss, misuse, or modification of personal information under our control.

3. REGULATORY FRAMEWORK

This Policy has been prepared in compliance with the Data Protection Act, 2021, No: 3 of the British Virgin Islands (“DPA”). It establishes the requirements for the lawful processing of personal data, outlines the rights of data subjects, and defines the obligations of data users and processors. This policy aligns with the principles and requirements outlined in the DPA and international data protection standards.

By adhering to the principles outlined in this Policy and relevant regulations, we aim to foster trust and confidence for our users while upholding the highest standards of data protection and privacy.

4. PERSONAL INFORMATION THE COMPANY COLLECTS

You may engage with us anonymously or under a pseudonym, except where it is impractical or where legal requirements, such as for Know Your Customer (“KYC”) purposes. As part of these requirements, we will collect your information.

To ensure we provide the best possible experience, any additional personal information you voluntarily provide will be stored, utilized, and disclosed in accordance with this Policy. Personal information refers to any data that identifies, describes, or can be linked to a specific person, household, or device.

Please provide only relevant information and avoid sharing sensitive data such as Social Security numbers, credit card details, or other sensitive personal information, unless it is specifically required for our services.

We collect personal information from various sources and interactions to provide and enhance our services. This information will be obtained directly from you.

When you sign up for an account with TradeBuddies, we may collect and use specific details to ensure optimal service delivery. Personal information includes, but is not limited to, the following:

  • Full name, 

  • Contact details (phone number and email address), 

  • Residential address;

  • Date of birth, 

  • Gender;

  • Signature; and

  • Identity verification information, such as your passport or driver’s license.

We may also gather indirect information from you, solely for verification, security, or to enhance browsing and functionality purposes. This may include:

  • Your IP address

  • Browser type and history

  • Operating system

  • Mobile device ID

  • Device ID

  • Internet service provider (ISP)

  • Cookies

5. USAGE OF YOUR INFORMATION

The information we collect, including what you provide, is gathered to deliver the information and services you request, as well as for various other purposes, including but not limited to:

  • Ensuring security, preventing fraud, or assessing credit risk;

  • Providing effective customer service, including monitoring, managing, and updating your devices and products;

  • Offering a personalized experience when using the Platform;

  • Developing new products and services;

  • Sending you special offers and relevant information that we believe will interest you (in accordance with your privacy preferences);

  • Contacting you with important information and notices regarding your use of the Platform;

  • Inviting you to participate in surveys and provide feedback (in line with your privacy preferences);

  • Gaining a better understanding of your needs and interests;

  • Enhancing the content, functionality, and usability of the Platform;

  • Improving our products and services;

  • Optimizing our marketing and promotional strategies; and

  • Any other purpose stated at the time of data collection, in an applicable privacy notice, in a click-through agreement, or in any other agreement between you and us.

The Company will retain your personal information, including sensitive personal information, for as long as reasonably necessary to fulfill the business purposes for which it was collected.

6. DISCLOSURE OF YOUR INFORMATION

We do not sell or lease your personal information to third parties. However, we may share your personal information with third parties for business purposes, including the following:

  • Our Affiliates: We may share your information with our affiliates to provide our products, services, and effective customer support.

  • Businesses: We may disclose your information to businesses, such as when managing accounts under a business's subscription with us. We are not responsible for how your information is used by those businesses.

  • Selected Business Partners: From time to time, we may share your information with carefully selected third parties for specific purposes, such as contests or promotions. Where required by law, we will offer you the option to opt in or out prior to sharing your information.

  • In Aggregate or De-Identified Form: We may anonymize or aggregate the data we collect for analysis, research, marketing, or other business purposes. This will not include any personally identifiable information.

  • Third-party Service Providers: We may disclose your information to third-party service providers that assist us in business operations, such as those performing KYC verification. These providers may need access to your information to perform their tasks. Service providers include suppliers, consultants, payment processors, IT support, and customer service.

Please note that sometimes disclosure of your information is necessary to comply with applicable laws, regulations, subpoenas, or court orders. Therefore, we may disclose information to respond to duly authorized requests from law enforcement or other government authorities, enforce our agreements or policies, and investigate or prevent security threats, fraud, or other malicious activities. In cases of emergency, where we believe, in good faith, that disclosing the information is required to prevent death or serious injury to any person or Company employee, we may also share your information.

In the event that the Company decides to buy, sell, or reorganize its business, it may be necessary to disclose or receive personal information with prospective or actual purchasers, acquisition targets, partners, or affiliates. In these cases, the Company will ensure your information is used in accordance with this Policy.

7. THE SECURITY OF YOUR INFORMATION

The Company takes reasonable steps to protect your personal information by implementing precautions to prevent loss, misuse, unauthorized access, modification, or disclosure.

If you choose to communicate with the Company online, please be aware of the inherent risks of transmitting information over the internet. While we make every effort to secure your data, we cannot guarantee the complete security of information sent via the internet.

When personal information is no longer needed for its intended purpose or legal requirements, the Company will take appropriate measures to either securely delete or de-identify the information.

8. COOKIES

A cookie is a small text file that a web page server deposits on your computer's hard drive. These cookies can later be accessed by our web server and contain information about your usage of our website. Additionally, cookies enable us to offer you a more personalized experience while using our website.

The Company uses cookies for the following purposes: 

  • Checking if you have previously visited the Company’s website;

  • Identifying the pages you have viewed; and

  • Streamlining site administration and enhancing security measures.

We may use different types of cookies on our Platform:

  • Strictly Necessary Cookies: These are essential for you to navigate and use features on our Platform. Without them, certain services can't be provided.

  • Performance Cookies: These collect anonymous data on how you use our Platform, such as how you arrived and navigated through it. This helps us improve areas like navigation but does not reveal any personal details.

  • Functionality Cookies: These remember your preferences, like your location, language, or search settings, to give you a more tailored experience. The data is often anonymized, and these cookies don’t track your activity on other sites.

  • Targeting/Advertising Cookies: These track your browsing habits to show ads relevant to your interests, limit how often you see them, and measure ad effectiveness. They are typically set by third-party ad networks and share data with other parties, such as advertisers.

If you prefer not to have cookies stored on your devices, you can disable them at any time by adjusting your browser settings. However, please note that disabling cookies may prevent you from fully using certain features of the Platform or restrict access to some functionalities.

9. MANAGING YOUR PRIVACY PREFERENCES AND CHOICES

We aim to provide you with the information you need and have requested. Whenever possible, we offer choices regarding what data we collect and how you can manage your preferences related to this information.

For any subscription-based services we may offer, you will have the opportunity to specify your data preferences either during the initial data collection process or at any point after receiving a communication while subscribed. Certain service-oriented or transactional messages, such as delivery confirmations, may not offer preference options as they are necessary for fulfilling your requests or delivering services and are not intended for marketing purposes.

From time to time, we may send newsletters or marketing emails. You can opt out of receiving these communications at any time by clicking the “unsubscribe” link at the bottom of the email. Please be aware that opting out or unsubscribing may impact other services that require email communication to function as requested. Even if you choose not to receive marketing materials, we may still need to contact you regarding important updates about your account or in response to any of your inquiries or requests.

10. QUALITY OF PERSONAL INFORMATION 

The Company endeavors to maintain accurate, up-to-date, and complete personal information about you. We verify personal information when collected to ensure its accuracy.

We encourage you to assist us by promptly informing us of any changes to your contact details (such as phone number, address, or email) or if any details require correction or updating. If you need to update your personal information, you can contact us using the contact details provided in the Section 13.

The Company believes that the information it possesses about you is inaccurate, outdated, incomplete, irrelevant, or misleading, or if you request correction of your information, we will make every reasonable effort to rectify such information as quickly as possible. There are no fees associated with such requests. If you ask us to inform a relevant third party of the correction, we will facilitate that notification unless it is impractical or unlawful for us to do so.

11. YOUR DATA SUBJECT RIGHTS

Under Part III (provisions 14 to 20) of the DPA, you have certain rights in specific situations:

  • You have the right to be informed about how your personal information is processed and to access it.

  • You can request the correction or deletion of your personal information held by us.

  • You have the right to object to further processing of your personal information, including for marketing purposes.

You may request the transfer of your personal information to a third party. However, depending on the nature of your request, such as the deletion of your personal information, we may not be able to grant access to some or all of the website services and/or the Company’s services or products, as we need your information to provide those services.

You have the right to withdraw your consent. If we process your personal information based on your consent, you have the right to withdraw that consent at any time by contacting us.

Requests related to your personal information can only be made by you or someone legally authorized to act on your behalf. If an authorized agent submits a request for you, we may ask for verification that you have granted them permission to do so.

Once we receive your request, we will acknowledge it by sending you a confirmation email. To protect your privacy and ensure security, we may take steps to verify your identity before providing access to your Personal Information. In certain cases, such as requests to delete personal information, we may confirm separately that you indeed wish to have your personal information deleted before proceeding with your request.

We will respond to your request within sixty (60) days. If we need additional time, we will notify you in writing, explaining the reason and the extended timeframe.

12. OUR RESPONSIBILITIES AS A DATA CONTROLLER

We may need to retain and process your personal data to fulfill our legal obligations, ensure the security of your data, and address situations where it is deemed necessary or appropriate to:

  • Comply with applicable laws and regulations.

  • Respond to requests from legal, regulatory, or government authorities.

  • Monitor and enforce compliance with our terms of service.

  • Perform anti-money laundering, sanctions checks, or KYC verification as required by law.

  • Protect your rights, privacy, safety, property, or the rights and safety of others.

Additionally, we may need to retain and process your personal data even after you have closed your TradeBuddies account for purposes related to legal obligations, regulatory requirements, and compliance, such as crime prevention, fraud detection, or loss prevention.

13. AMENDMENT OF THIS POLICY

This Policy outlines our current practices regarding the information we collect through the Platform. As we continuously enhance and expand the features and functionality of the Platform, as well as the products and services offered, any updates to this Policy will be posted on this page. You can access this page from any of our webpages by clicking the "Privacy Policy" link.

14. EXTERNAL WEBSITES

This Policy does not cover websites or domains operated or maintained by third parties or our affiliates. Our Platform may contain links to third-party websites and services. For instance, if you click on an advertisement on our Platform, you may be redirected to a website that we do not control. Please note that these links do not imply any endorsement of these third-party sites, and this Policy does not extend to them. As we do not govern the privacy practices of these external websites, we encourage you to review their posted privacy policies before using their services or providing any personal information.

15. HOW TO CONTACT US

If you have any questions, requests, or concerns about how we use your personal information or regarding this Privacy Policy, please reach out to us by the "Contact Us" section on the Platform.

If you have any concerns regarding a breach or potential breach of your privacy, please reach out to us immediately. We will make every effort to address your complaint internally as promptly as possible, aiming to resolve it within 60 days of receiving your complaint.