PRIVACY AND SECURITY

OUR COMMITMENT

WHAT PERSONAL INFORMATION DOES 1TradeMarket

COLLECTS

1TradeMarket

Ltd.

(“1TradeMarket”)

operates

https://www.1trademkt.com and may operate other

The personal information that we may collect about

websites. 1TradeMarket is committed to providing you with the

you broadly falls into the following categories:

highest levels of client service. We recognize that

your privacy is very important to you and we respect

Information that you provide us voluntarily:

the confidentiality of information and the privacy of

You may give us your identity, contact and financial

individuals.

data etc. by filling in forms or by corresponding with

1TradeMarket believes that this Privacy Policy discloses how

us by post, phone, e-mail or otherwise. This includes

the personal information you provide to us and our

personal information you provide when you:

representatives, is collected, used, held, disclosed

and disseminated. We are committed to being open

•! Apply for our products or services.

and transparent about how we use your personal

•! Create an account on our website.

information.

•! Subscribe to our or related third party

We encourage you to check our website regularly

service or publications.

for any updates to our Privacy Policy.

•! Request marketing to be sent to you.

•! Enter a competition, promotion or survey.

YOUR PERSONAL INFORMATION

•! Give us some feedback.

Due to the nature of the products we provide, we are

In addition to the above, certain parts of our website

required to collect personal information from

may ask you to provide personal information

customers which can include, but is not limited to, the

voluntarily (for example, we may ask you to provide

below:

your contact details in order to register an account

•! Name, address, telephone number(s)

with us, to subscribe to marketing communications

•! Date of birth

from us, and/or to submit enquiries to us). The

•! Email address

personal information that you are asked to provide,

•! Occupation and job title

and the reasons why you are asked to provide it, will

•! Transaction details associated with your

be made clear to you when we ask you to provide

trading through us

your personal information.

•! Additional information provided to us and

recorded by telephone

Information that we collect automatically:

•! Information you provided to us on client

When you visit our website, we may collect certain

agreement forms

information automatically from your device. In some

countries, including countries in the European

•! Nominated bank account details

Economic Area

(EEA), this information may be

•! Statement of assets and liabilities

considered personal information under applicable

•! Information regarding guarantees of

data protection laws. Specifically, the information we

company accounts

collect automatically may include information like

•! Employer

your IP address, device type, unique device

•! Voluntary information

identification

numbers, browser-type, broad

You are not required to provide us with any of the

geographic location (for example, country or city-

personal information requested; however, without

level location) and other technical information. We

the information required 1TradeMarket will not be able to

may also collect information about how your device

provide you with any of the services or assistance you

has interacted with our website, including the pages

have sought.

accessed and links clicked.

Collecting this information enables us to better

understand the visitors who come to our website,

2 | Privacy & Security | 1TradeMarket

where they come from, and what content on our

only for the purposes disclosed in this

website is of interest to them. We use this information

for our internal analytics purposes and to improve the

•! to any other person with your consent to the

quality and relevance of our website to our visitors.

disclosure.

Some of this information may be collected using

cookies and similar tracking technology. For detailed

LAWFUL BASIS FOR PROCESSING PERSONAL

information on the cookies we use and the purposes

INFORMATION

for which we use them, see our Cookie Policy.

Our lawful basis for collecting and using the personal

Information we obtain from third parties or

information described above will depend on the

publicly available sources:

personal information concerned and the specific

From time to time, we may receive personal

context in which we collect it. However, we will

information about you from third party sources, but

normally collect personal information from you only

only where we have checked that these third parties

where we have your consent to do so, where we need

either have your consent or are otherwise legally

the personal information to perform a contract with

permitted or required to disclose your personal

you, or where the processing is in our legitimate

information to us.

interests and not overridden by your data protection

We use the information we receive from these third

interests or fundamental rights and freedoms. In

parties to enhance the services we provide to you,

some cases, we may also have a legal obligation to

such as providing curated content that is relevant to

collect personal information from you or may

services we provide you or topics you are interested

otherwise need the personal information to protect

in.

vital interests.

If we ask you to provide personal information to

WHO DOES 1TradeMarket SHARE MY INFORMATION

comply with a legal requirement or to perform a

WITH?

contract with you, we will make this clear at the

relevant time and advise you whether the provision of

We may disclose your personal information to the

your personal information is mandatory or not (as

following categories of recipients:

well as of the possible consequences if you do not

provide your personal information).

•!

to our group companies, third party services

Similarly, if we collect and use your personal

providers and partners who provide data

information in reliance on our legitimate interests (or

processing services to us (for example, to

those of any third party), we will make clear to you at

support the delivery of, provide functionality

the relevant time what those legitimate interests are.

on, or help to enhance the security of our

website), or who otherwise process personal

HOW WE STORE AND SECURE YOUR PERSONAL

information for purposes that are described

INFORMATION

in this Privacy Policy or notified to you when

we collect your personal information.

We use appropriate technical and organisational

•!

to any competent law enforcement body,

measures to protect the personal information that we

regulatory, government agency, court or

collect and process about you. The measures we use

other third party where we believe

are designed to provide a level of security

disclosure is necessary (i) as a matter of

appropriate to the risk of processing your personal

applicable law or regulation, (ii) to exercise,

information. In particular, we:

establish or defend our legal rights, or (iii) to

protect your vital interests or those of any

•! Hold personal information in secure facilities

other person.

and where the information is held

•!

to a potential buyer (and its agents and

electronically, on secure servers.

advisers) in connection with any proposed

•! Use encrypted transmission links whenever

purchase, merger or acquisition of any part

we can.

of our business, provided that we inform the

•! Use other safeguards such as firewalls,

buyer it must use your personal information

authentication systems

(e.g., passwords),

3 | Privacy & Security | 1TradeMarket

and access control mechanisms to control

stream” activity (i.e., the paths taken by visitors to our

unauthorised access to systems and data.

site as they move from page to page.) Cookies do not

•! Regularly review our information collection,

capture your individual email address or any private

storage and processing practices, including

information about you.

physical security measures, to guard against

We also use standard web server log files to help us

unauthorised access to systems.

count visitors and evaluate our site’s technical

•! Restrict access to personal information to

capacity. We use this information to find out how

our employees, contractors and agents who

many people visit our site, help us arrange the pages

need to know that information in order to

in the most user-friendly way, keep the site browser-

friendly, and to make our pages more useful to our

process it for us and who are subject to strict

contractual confidentiality obligations. 1TradeMarket

visitors. We record information on site traffic but not

may discipline or terminate individuals who

information on individual visitors to our site, so no

maliciously acquire information, without

information about you in particular will be kept or

being entitled to its access.

used.

To browse without cookies, you can configure your

OUR WEBSITE

browser to reject all cookies, or to notify you when a

cookie is set. (Each browser is different, so check the

1TradeMarket website provides links to third party websites.

“Help” menu of your browser to learn how to change

The use of your information by these third party sites

your cookie preferences.)

is not within the control of 1TradeMarket and we cannot accept

responsibility for the conduct of these organizations.

COOKIE PREFERENCES

Other websites are not subject to our privacy

standards, policies and procedures. You will need to

Some of the cookies that 1TradeMarket sets when you visit any

contact or review those websites directly to ascertain

of our websites are essential to the working

their privacy stands, policies and procedures. Please

functionality of the site. Without these cookies, you

Note 1TradeMarket does not collect and store credit card

would not be able to chat online, fill out a trading

information.

application, or deposit funds. Performance cookies

You may register with us to receive newsletters and

are another type of cookies 1TradeMarket uses to provide with

other information. By doing so, your name and email

you a better user experience and to improve how

address will be collected and stored on our database.

content on our website is presented. Marketing

We take care to ensure that the personal information

cookies are also set usually by third party advertising

you give us on our website is protected. For example,

networks to ensure we are providing you with

our website has electronic security systems in place,

targeted adverts more relevant to you and your

interests. If you do not want to receive non-

including the use of firewalls and data encryption.

If you do not wish to receive any further information

mandatory cookies, you can manage your

from us, or you wish to update your registration

preferences.

details, please email your request to us. We will

endeavor to meet your request within 5 working

CROSS BORDER DISCLOSURES

days.

Subject to certain conditions, we may transfer your

We may use cookie technology as part of our

websites statistical reporting. A cookie is a small

personal information to a third party in different

piece of information sent by a website that is saved

jurisdictions for further processing in accordance

on your hard disk by your computer’s browser. It

with the purposes set out in this Privacy Policy. In

holds information a site may need to personalize your

these circumstances we will, as required by

experience and to gather website statistical data,

applicable law, ensure that your privacy rights are

such as which pages are visited, what is downloaded,

adequately protected by appropriate technical,

the internet provider’s domain name and country that

organisation, contractual or other lawful means.

our visitors come from and the addresses of sites

These include putting in place data transfer

visited immediately before, and after, coming to our

agreements for transfers of personal information

site. However, none of this is associated with you as

between our group companies, which require all

group companies to protect personal information

an individual. It is measured only in aggregate. The

information in the cookies lets us trace your “click

4 | Privacy & Security | 1TradeMarket

they process from the EEA in accordance with

your personal information at any time. Such

European Union data protection law.

withdrawal will not affect the lawfulness of

processing based on your previous consent.

DATA RETENTION

Please note that if you withdraw your

consent, you may not be able to benefit from

Your personal information will be retained for as long

certain service features for which the

as it is necessary to carry out the purposes set out in

processing of your personal information is

this Privacy Policy (unless longer retention is required

essential.

by law). However, we will not retain any of your

•!

Right to object to processing. You may

personal information beyond this period and the

request that we stop processing your

retention of your personal information will be subject

personal information. Please note you may

to periodic review. We may keep an anonymised

not be able to benefit from certain service

form of your personal information, which will no

features for which the processing of your

longer refer to you without time limits, to the extent

personal information is essential.

that we have a legitimate and lawful interest in doing

•!

Right to erasure. You may request that we

so.

erase your personal information and we will

comply, unless there is a lawful reason for

YOUR DATA PROTECTION RIGHTS

not doing so.

•!

Your right to lodge a complaint with the

Subject to certain conditions, data protection law

supervisory authority. We suggest that you

provides individuals with rights, including the right

to: access, rectify, withdraw consent, erase, restrict,

a complaint in relation to how we process

transport, and object to the processing of, their

your personal information. However, you do

personal information. Individuals also have the right

have the right to contact the relevant

to lodge a complaint with the relevant information

supervisory authority directly.

protection authority if they believe that their personal

information is not being processed in accordance

’DO NOT CALL’ REGISTER

with the law. Further information about your rights is

set out below:

Unless you ask us not to contact you about products

or services and not to disclose your information to

•!

Right to obtain a copy of your personal

others for that purpose, by accessing this website you

information. You have the right to obtain a

consent to us contacting you by telephone while you

copy of the personal information we hold

hold any product or receive any services from us

about you.

notwithstanding registration at any time of your

•!

Right to rectification. You may request that

telephone number on the ‘do not call’ register.

we rectify any inaccurate and/or complete

any incomplete personal information. We

INTERNAL PROCEDURE FOR DEALING WITH

will then correct out records and notify any

COMMUNICATIONS

third parties to whom such personal

information may have been transmitted as

The three key steps 1TradeMarket follows:

described above.

•!

Right to data portability. You may request a

•! Consent

- Only commercial electronic

copy of all personal information you have

messages are sent with the addressee’s

provided to us after which we will transmit

consent, either express or inferred.

those data to another data controller of your

•! Identify - Electronic messages will include

choice.

clear and accurate information about the

•!

Right

opt-out

marketing

person and the company that is responsible

communications. You can exercise this right

for sending the commercial electronic

by clicking on the “unsubscribe” or “opt-out”

message.

link in the marketing e-mails we send you.

•! Unsubscribe - We ensure that a functional

•!

Right to withdraw consent. You may

unsubscribe facility is included in all our

withdraw your consent to the processing of

5 | Privacy & Security | 1TradeMarket

commercial electronic messages and deal

cover third party sites we link to or which link to us.

with unsubscribe requests promptly.

Those sites should have their own privacy policies.

There are pages where you will be requested to enter

CONSENT TO SUCH COMMUNICATIONS

private information in order to receive specific

benefits of information in response. This data may

Commercial messages will only be sent to you when

include your name, email address, and street

you have given consent. This may be express consent

address. If you are signing up to a paid service from

- a direct indication that it is okay to send the

us, we (or our payment provider) may additionally

message, or messages of that nature or inferred

request your billing information, such as card details

consent based on our business or other relationship

and billing address.

with you and your conduct.

We also may use cookies on our site(s) in order to

COMPLY WITH THE LAW REGARDING VIRAL

track your particular ‘session’ on our site. This is not

MESSAGES

used for contextual advertising purposes and, in

general, is not directly traceable to you.

1TradeMarket ensures that Commercial Communications that

We may use your information in order to track your

include a Forwarding Facility contain a clear

recommendation that the Recipient should only

relationship with us and our site(s) as well as to send

forward the Commercial Communication to persons

you emails about information you have requested or

with whom they have a relationship, where that

other information or promotions specifically relevant

relationship means that person could be said to have

to 1TradeMarket and its activities. Essentially, your data will

consented

receiving

Commercial

only be used for the specific purposes for which it was

Communications.

collected (as per the Data Protection Act 1998 (UK)).

We may, occasionally, send surveys or even direct

COMPLY WITH THE AGE SENSITIVE CONTENT OF

one-to-one mail in order to manage our customer

COMMERCIAL COMMUNICATION

service processes. We do NOT share your

information with third parties, we do NOT share your

Where the content of a Commercial Communication

email addresses with sponsors or any third parties,

seeks to promote or inspire interaction with a

and we do NOT run exclusive ‘sponsored’ emails on

product, service or event that is age sensitive, 1TradeMarket

behalf of third parties. Please note that we do not

takes reasonable steps to ensure that such content is

store credit/debit card numbers nor do we share

sent to recipients who are legally entitled to use or

customer details with any third parties.

participate in the product service or event.

Information will not be disclosed to other parties

PAYMENT PROCESSING

without the consent of the individual whom it is

about, unless there is legislation or other overriding

Please note we do not process Visa and MasterCard

legitimate reason to share the information

(for

payments from China or Hong Kong, as they are

example, the prevention or detection of crime).

restricted.

Merchant will not sell, purchase, provide, exchange

1TradeMarket Ltd. is determined to protect and maintain

or in any other manner disclose Account or

your privacy. We are privileged to be trusted with

Transaction data, or personal information of or about

your personal information and do not wish to

a Cardholder to anyone, except, it’s Acquirer,

jeopardize that trust. However, in order to use some

Visa/Mastercard Corporations or in response to valid

of our services, it’s necessary for you to give us details

government demands.

such as your name and email address or, potentially,

REFUND POLICY

your street address. Please note that we do NOT

store credit/debit card numbers, nor do we share

A refund request will only be considered if it is

customer details with any third parties.

requested within the first twenty-four (24) hours of the

alleged transaction, or within thirty (30) days if a user

This statement explains how and why we collect

alleges that another individual

(or a minor) has

information from our users, how we use it, and how

accessed his/her account. A refund will be paid out

you can access or change it. This statement does not

6 | Privacy & Security | 1TradeMarket

within three (3) working days once refund conditions

are met. A refund will be processed only the same

way it was received.

COMPLAINTS RESOLUTIONS

Please contact our Privacy Officer if you wish to

complain about any breach or potential breach of

your privacy rights. Your complaint will be responded

to within 7 days. If you are not satisfied with the

outcome of your complaint, you are entitled to

engage legal counsel.

1TradeMarket may record telephone conversations between

you and persons working for 1TradeMarket. Such recordings,

or transcripts from such recordings, may be used for

training purposes and to assist with the resolve of any

dispute between you and 1TradeMarket.

UPDATES TO THIS PRIVACY POLICY

We may update this Policy from time to time in

response to changing legal, technical or business

developments. When we update our Policy, we will

take appropriate measures to inform you, consistent

with the significance of the changes we make.

You can see when this Policy was last updated by

checking the “updated” date displayed below.

DISCLAIMER

1TradeMarket Ltd. registered in St. Vincent and the

Grenadines, is an issuer of

Derivatives: Exchange traded and Over the Counter

(OTC) Margin FX Contracts, CFD products and

Options.

CONTACT DETAILS

Contact: 1TradeMarket Ltd.

Address:

Griffith Corporate Centre,

Beachmont, Kingston, St. Vincent and the

Grenadines

Telephone:

E-mail: support@1trademkt.com

7 | Privacy & Security | 1TradeMarket