🔍Privacy & Cookie Policies

Below is our Privacy & Cookie Policies that applies to your use of OpenTrade.

Privacy Policy

Welcome to the Open Trade Technology Ltd's (“OTT”) privacy policy. OTT respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our “Services” (our website(s), app(s), protocols, tools, and systems) or interact with us in any other way. We are the controller and responsible for the processing of your personal data.

If you have any questions about this privacy policy or our privacy practices, please contact us by emailing [e-mail]. This privacy policy was last updated on July 25, 2023. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

Our Services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy statements. When you leave our Services, we encourage you to read the privacy policy of every third party service you visit.

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, maiden name, last name, passport/ID details, title, date of birth and gender.

• Contact Data includes email address and telephone numbers.

• Financial Data includes source of wealth, wallet addresses and wallet balances.

• Transaction Data includes details about transactions made through our platform, such as amounts, wallet addresses, and fees paid by you or due to you

• 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.

• Usage Data includes information about how you use our 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.

If you fail to provide personal data

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 our Services to you).

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 Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

• Cookies. We use cookies to improve your experience of using the Website and to improve our range of products and services. See Cookie Policy below for more information.

• Third parties or publicly available sources. We will receive personal data about you from various public sources (such as sanctions lists) and third parties including public databases, KYC and ID verification service providers, and credit reference agencies.

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.

• Where you have given your consent. 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.

Purposes for which we will use your personal data

• To register you as a new customer and provide you with our Services, which includes carrying out mandatory financial crime compliance checks.

• To manage our relationship with you.

• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

• To use data analytics to improve our Services, marketing, customer relationships and experiences.

• To make suggestions and recommendations to you about Services that may be of interest to you.

Disclosures of your personal data

We may share your personal data with the parties set out below.

• Service providers who provide IT services and KYC services.

• Professional advisers including lawyers, bankers, auditors and insurers.

• HM Revenue & Customs, regulators and other authorities.

International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data or alternatively, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Data retention

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• 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.

• 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:

  • If you want us to establish the data's accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• 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 which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to deliver our Services to you. We will advise you if this is the case at the time you withdraw your consent.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Cookie Policy

Scope of This Policy

1. Open Trade Technology Ltd (we or us or our) uses cookies when you visit our website, www.open-trade.io, (the Website) to help customise the Website and improve your experience using the Website.

2. This Policy applies between you, the user of this Website, and us, Open Trade Technology Ltd, the owner and provider of this Website.

3. When you visit the Website, and before your Website places cookies on your computer, you will be presented with a message bar requesting your consent to set those cookies. By giving your consent to the placing of cookies, you are enabling us to provide a better experience and service. You may, if you wish, deny consent to the placing of these cookies; however, certain features of the Website may not function fully or as intended.

4. This Cookie Policy should be read alongside, and in addition to, our Privacy Policy, which can be found above.

What Are Cookies?

5. A cookie is a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website.

6. This Website may place and access certain cookies on your computer. We use these cookies to improve your experience of using the Website and to improve our range of products and services.

7. Cookies do not usually contain any information that personally identifies you, as the Website user. However, personal information that we store about you may be linked to the information obtained from and stored in cookies. For more information on how such personal information is handled and stored, refer to our Privacy Policy which above.

Types of Cookies

1. Our websites use the following cookies

Type of Cookie	Purpose
Strictly necessary cookies	These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website, use a shopping cart or make use of e-billing services
Functionality cookies	These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookies.

1. You can find a list of the cookies that we use in the Cookie Schedule.

2. We have carefully chosen these cookies and have taken steps to ensure that your privacy is protected and respected at all times.

How To Control Your Cookies

1. You can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please see the help menu in your internet browser.

2. You can switch off cookies at any time, however, you may lose information that enables you to access the Website more quickly and efficiently.

3. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

4. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

Changes To This Policy

1. Open Trade Technology Ltd reserves the right to change this Cookie Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Cookie Policy on your first use of the Website following the alterations.

Contact Details

1. The Website is owned by Open Trade Technology Ltd incorporated in England and Wales with registered number 14583521 whose registered office is at 3rd Floor, 1 Ashley Road, Altrincham, Chesire, WA14 2DT, England.

2. You may contact us by emailing [e-mail].

Cookie Schedule

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Name	Purpose	Duration	Type
XSRF-TOKEN	Used for security reasons	Session	Strictly necessary
hs	Used for security reasons	Session	Strictly necessary
svSession	Used in connection with user login	12 months	Strictly necessary
SSR-caching	Used to indicate the system from which the site was rendered	1 Minute	Strictly necessary
_wixCIDX	Used for system monitoring/debugging	3 months	Strictly necessary
_wix_browser_sess	Used for system monitoring/debugging	Session	Strictly necessary
consent-policy	Used for cookie banner parameters	12 months	Strictly necessary
smSession	Used to identify logged in site members	Session	Strictly necessary
TS*	Used for security and anti-fraud reasons	Session	Strictly necessary
bSession	Used for system effectiveness measurement	30 minutes	Strictly necessary
fedops.logger.X	Used for stability/effectiveness measurement	12 months	Strictly necessary
wixLanguage	Used on multilingual websites to save user language preference	12 months	Functionality