Privacy and Security
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
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.
! 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.
! 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
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
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,
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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
Privacy Policy.
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.
Some of this information may be collected using
cookies and similar tracking technology. For detailed
information on the cookies we use and the purposes
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
vital interests.
If we ask you to provide personal information to
comply with a legal requirement or to perform a
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
information for purposes that are described
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.
To browse without cookies, you can configure your
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.
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
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
details, please email your request to us. We will
endeavor to meet your request within 5 working
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.
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
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
erase your personal information and we will
comply, unless there is a lawful reason for
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
contact us about any questions or if you have
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
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
will then correct out records and notify any
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
clear and accurate information about the
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”
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
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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
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
track your particular ‘session’ on our site. This is not
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
only be used for the specific purposes for which it was
collected (as per the Data Protection Act 1998 (UK)).
We may, occasionally, send surveys or even direct
one-to-one mail in order to manage our customer
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
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
payments from China or Hong Kong, as they are
example, the prevention or detection of crime).
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,
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.
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.
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.
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
Privacy Policy - Updated November 2019.
Contact: 1TradeMarket Ltd.
Griffith Corporate Centre,
Beachmont, Kingston, St. Vincent and the
E-mail: support@1trademkt.com
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