Privacy Policy

We are committed to protecting your personal data. This privacy policy will inform
you as to how we look after your personal data when you visit our website
www.tradeteq.com (“Website”) (regardless of where you visit it from) and tell you
about your privacy rights and how the law protects you.

1. PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how we collect and process your
personal data through your use of this Website, including any data you may provide
through this Website.

This Website is not intended for children and we do not knowingly collect data
relating to children.

This privacy policy will inform you how you can verify which of your personal
information is collected by us through the Website and how you can request that we
delete, update or transfer it.

It is important that you read this privacy policy together with any other privacy
policy or fair processing policy we may provide on specific occasions when we are
collecting or processing personal data about you so that you are fully aware of how
and why we are using your data. This privacy policy supplements other notices and
privacy policies and is not intended to override them.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual
from which that person can be identified. It does not include data where the identity
has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you
which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier,
title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other
details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in types and
versions, operating system and platform, and other technology on the devices
you use to access this Website.
• Profile Data includes your username and password, your interests,
preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website, products and
services.
• Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data could be derived from your personal data but
is not considered personal data in law as this data will not directly or indirectly reveal

your identity. For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific website feature. However, if we combine or
connect Aggregated Data with your personal data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used in
accordance with this privacy policy.

We do not collect any Financial Data (this includes bank account and payment card
details) or any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your
health, and genetic and biometric data). Nor do we collect any information about
criminal convictions and offences.

3. IF YOU FAIL TO PROVIDE PERSONAL DATA
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Where we need to collect personal data by law, or under the terms of a contract we
have with you, and you fail to provide that data when requested, we may not be able
to perform the contract we have or are trying to enter into with you (for example, to
provide you with goods or services). In this case, we may have to cancel a product or
service you have with us but we will notify you if this is the case at the time.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes personal
data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Website,
we will automatically collect Technical Data about your equipment, browsing
actions and patterns. We collect this personal data by using cookies and other
similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data
about you from various third parties and public sources as set out below:
• Technical Data from analytics providers
• Contact and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators
• Identity and Contact Data from publicly available sources

5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation. Generally, we do not rely on
consent as a legal basis for processing your personal data although we will get
your consent before sending third party direct marketing communications to you
via email or text message. You have the right to withdraw consent to marketing
at any time by contacting us.

6. USE OF COOKIES
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Our Website uses certain cookies, pixels, beacons, log files and other technologies of
which you should be aware. Please see our Cookie Policy to find out more about the
cookies we use and how to manage them.

7. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any legal,
regulatory, tax, accounting or reporting requirements. We may retain your personal
data for a longer period in the event of a complaint or if we reasonably believe there
is a prospect of litigation in respect to our relationship with you.

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
unauthorised 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, regulatory, tax, accounting or other
requirements.

8. THIRD PARTY LINKS AND SERVICES
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It is likely that the Website will contain links to third party websites and services.
Please remember that when you use a link to go from our Website to another
website or you request a service from a third party, this privacy policy no longer
applies.
Your browsing and interaction on any other website, or your dealings with any other
third-party service provider, is subject to that website’s or third party service
provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website
you visit or third party service provider that you deal with and to contact them if you
have any questions about their respective privacy policies and practices.
This privacy policy applies solely to personal information collected by us through our
Website and functionality and does not apply to these third party websites and third
party service providers.
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9. TRANSFERS

The EEA, UK and other countries outside the EEA and the UK have differing data
protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside
the UK and EEA. In those cases we will comply with applicable UK and EEA laws
designed to ensure the privacy of your personal data.
As we are based in the UK we will also transfer your personal data from the EEA to
the UK.
Other than as set out above, we do not transfer your personal information outside of
the EEA or UK.
If you would like further information about data transferred outside the UK/EEA,
please contact us via legal@tradeteq.com.

10. SECURITY OF YOUR PERSONAL INFORMATION
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We are committed to keeping the personal information you provide us secure and we
will take reasonable precautions to protect your personal information from loss,
misuse or alteration.
We have implemented information security policies, rules and technical measures to
protect the personal information that we have under our control from:
ounauthorised access;
oimproper use or disclosure;
ounauthorised modification; and
ounlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal
information on our behalf, for the purposes listed above), who have access to, and
are associated with the processing of personal information, are obliged to respect
the confidentiality of the personal information of all users of the Site.

11. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER
RIGHTS?
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You have the following rights in relation to the personal information we hold about
you:

Your right of access.
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If you ask us, we’ll confirm whether we’re processing your personal
information and, if so, provide you with a copy of that personal
information (along with certain other details). If you require additional
copies, we may need to charge a reasonable fee.

Your right to rectification.
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If the personal information we hold about you is inaccurate or
incomplete, you’re entitled to have it rectified. If we’ve shared your
personal information with others, we’ll let them know about the
rectification where possible. If you ask us, where possible and lawful to do so,
we’ll also tell you who we’ve shared your personal information with so that you
can contact them directly.

Your right to erasure.
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You can ask us to delete or remove your personal information in some
circumstances such as where we no longer need it or you withdraw
your consent (where applicable). If we’ve shared your personal
information with others, we’ll let them know about the erasure where
possible. If you ask us, where possible and lawful to do so, we’ll also
tell you who we’ve shared your personal information with so that you
can contact them directly.
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Your right to restrict processing.
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You can ask us to ‘block’ or suppress the processing of your personal
information in certain circumstances such as where you contest the
accuracy of that personal information or object to us processing it. It
won’t stop us from storing your personal information though. We’ll tell
you before we lift any restriction. If we’ve shared your personal
information with others, we’ll let them know about the restriction
where possible. If you ask us, where possible and lawful to do so, we’ll
also tell you who we’ve shared your personal information with so that
you can contact them directly.
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Your right to data portability.
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With effect from 25 May 2018, you have the right, in certain
circumstances, to obtain personal information you’ve provided us with
(in a structured, commonly used and machine readable format) and to
reuse it elsewhere or ask us to transfer this to a third party of your
choice.
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Your right to object.
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You can ask us to stop processing your personal information, and we
will do so, if we’re:
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- relying on our own or someone else’s legitimate interests to
process your personal information except if we can demonstrate
compelling legal grounds for the processing;
- processing your personal information for direct marketing; or
- processing your personal information for research unless such
processing is necessary for the performance of a task carried
out in the public interest.
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Your rights in relation to automated decision-making and profiling.
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You have the right not to be subject to a decision when it’s based on
automatic processing, including profiling, and it produces a legal effect
or similarly significantly affects you unless such profiling is necessary
for entering into, or the performance of, a contract between you and
us.

Your right to withdraw consent.
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If we rely on your consent (or explicit consent) as our legal basis for
processing your personal information, you have the right to withdraw
that consent at any time.
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Your right to lodge a complaint with the supervisory authority.
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If you have a concern about any aspect of our privacy practices,
including the way we’ve handled your personal information, you can
report it to the UK Information Commissioner’s Office (ICO). You can
find details about how to do this on the ICO website
at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123
1113.

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12. CHANGE TO THIS PRIVACY POLICY
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We may make changes to this privacy policy from time to time.
To ensure that you are always aware of how we use your personal information we
will update this privacy policy from time to time to reflect any changes to our use of
your personal information. We may also make changes as required to comply with
changes in applicable law or regulatory requirements. We may notify you by e-mail
of any significant changes. However, we encourage you to review this privacy policy
periodically to be informed of how we use your personal information.

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13. HOW TO CONTACT US?
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If you have any questions about this privacy policy or want to exercise your rights,
please contact us by:
Sending an e-mail to privacy@tradeteq.com; or to address 15 Bishopsgate, London EC2N 3AR

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Last update: September 2023