Privacy Policy for the use of trade.io and our Websites.

When you are using trade.io’s Services and electronic media, we may collect, process and/or disclose data that identify you or make you identifiable ("Personal Data") in accordance with this privacy policy (“Policy”). Further, we may either receive your Personal Data directly from you when you are sending emails to us or provide your Personal Data otherwise in the course of other interactions with us, or indirectly from third parties who legally provide your Personal Data to us.

This Policy is meant to inform you, which Personal Data we collect, store, process, use and/or disclose, for which purposes and on which legal basis. We further inform you about your rights to protect your Personal Data.

The content of this Policy shall apply to you and shall form part of the terms and conditions set forth in our Terms of Use at https://legal.trade.io/terms-of-use. If there is any inconsistency between this Policy and the Terms of Use, this Policy shall prevail insofar as it relates to the protection of your Personal Data.

In the event you are a user of our Platform ("Platform User") or that you are an Authorized Person of a Platform User who is a Corporate Person, this Policy shall apply to you either as a Platform User or an Authorized Person of such Platform User and also form part of the terms and conditions set forth in our Terms of Service at https://legal.trade.io/terms-of-service. If you are a Platform User or an Authorized Person of a Platform User who is a Corporate Person and there is any inconsistency between this Policy and the Terms of Service, this Policy shall prevail insofar as it relates to the protection of your Personal Data.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy. Your continued use of our Services or Website constitutes your agreement to be bound by this Policy, as amended or updated from time to time.

Please note that trade.io collects your Personal Data directly from the country where you are based and stores it on servers in EU/EEA.

We may process your data outside of the EU. Regardless of where we process it, we will always conform to EU level data privacy and data protection standards. If you have questions, write to us at [email protected].

Which Personal Data we process

The categories of Personal Data about you that we may Process include:

  • Personal details: name and nickname

  • Contact details: email address

  • Password

  • Technical information (e.g. Device type, IP address)

If you are a Platform User, Personal Data to be collected from you include, but is not limited to, the following:

  1. Name

  2. Photograph of your government-issued identification

  3. Nationality

  4. Address

  5. Date of birth

  6. Email address

  7. Mobile number

  8. Taxpayers identification number (if applicable)

  9. Government identification number

  10. Other photographic proof of your identity

  11. Information regarding your bank account(s) related to your use of the Platform

  12. Current profession and industry/sector

  13. Annual Income

  14. Origin of funds used in transactions with trade.io

  15. Expected usual trading volume per month

If you are an Authorized Person of a Platform User who is a Corporate Person, Personal Data to be collected from you include, but is not limited to, the following:

  1. Name

  2. Photograph of your government-issued identification

  3. Nationality

  4. Address

  5. Date of birth

  6. Email address

  7. Mobile number

  8. Taxpayers identification number (if applicable)

  9. Government identification number

  10. Other photographic proof of your identity

  11. Information regarding your bank account(s) related to your use of the Platform

  12. Current profession and industry/sector

  13. Position in relations to the company

  14. Annual Income

  15. Origin of funds used in transactions with trade.io

  16. Expected usual trading volume per month

How we collect your Personal Data

We may collect Personal Data about you from the following sources:

  • When you contact us via e-mail, telephone or by any other means of contact;

  • When you apply to us to open an Account for the Platform;

  • When we provide you with access to Services provided by us;

  • When you participate in a promotion, survey or Competition for the purpose mentioned in the Section under Basis for Processing Personal Data;

  • Where you have chosen to make such Personal Data public, including via social media profiles;

  • When you visit our Websites (including the Platform) or use any features on, or through, our Websites. When you visit our Website (including the Platform), your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a website and other technical communications information), some of which may constitute Personal Data;

  • When you submit your resume/CV to us for a job application;

  • When you participate in whitelisting, KYC and our Token contribution processes. (Please note that acquirers are still subject to the Terms & Conditions and Privacy Policy from the pre-launch.)

If you decide to withhold certain Personal Data, it may limit our ability to provide you with our Services and/or your ability to access or use any or all of our Websites or allow you to participate in a promotion, survey or Competition as set out under the Section for Basis for Processing Personal Data, or if you wish to become a Platform User to access or use our Platform but withhold certain Personal Data, we may not be able to process your Account opening application or we may need to turn down your application, or if you are an Authorized Person of a Platform User who is a Corporate Person, we may not be able to approve your use, operation or control of such Platform User’s Account and/or we may need to turn down such Corporate Person’s application for an Account.

Creation of Personal Data

In the course of your interaction with the trade.io, we may also create Personal Data about you, such as records of your interactions with us and details of your transaction history. Further, your Personal Data may also be obtained from public domain through different channels such as a public register, a public search engine, a public directory or any social networks (this list is non-exhaustive).

For which purposes we use your Personal Data

We use your Personal Data to provide, maintain and improve our Services which include, but is not limited to, granting you access to our Websites and enabling you the access and use of our Services and the Platform, and if you are a Platform User or an Authorized Person of a Platform User who is a Corporate Person, our Services will also include trading Tokens on the Platform and transferring your funds and Tokens in and out of your account maintained with us for the Platform (the "Account"). Accordingly, for the purposes of providing our Services, it is necessary for you to supply us with your Personal Data.

For marketing purposes, we use your Personal Data only if and as long as we have received your explicit prior consent and in accordance with respectively applicable additional legal requirements in your jurisdiction.

We do not sell your Personal Data to third parties.

In addition to the purposes set out in this Policy, you acknowledge that the purpose of our Service is to provide information about us including but not limited to the Platform and its related services and other services provided by us.

If you submit Personal Data to us for the purpose of being whitelisted for participation in the Platform and/or as a potential acquirer of trade.io Token, you consent to our collection, processing, use and disclosure of such Personal Data for the purposes of such whitelisting and also the issuance, distribution, use and circulation of or exchange for trade.io Token.

If you submit Personal Data to us for the purpose of becoming a Platform User of the Platform or an Authorized Person of a Platform User who is a Corporate Person, you consent to our collection, processing, use and disclosure of such Personal Data for the purposes listed in this Policy.

Basis for Processing Personal Data

In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

  • we have obtained your explicit prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);

  • the Processing is necessary in connection with any contractual relationship that you may enter into with us;

  • the Processing is necessary and required for our compliance with the duties, obligations, requirements or arrangements for disclosing and using Personal Data that apply to us or that we are expected to comply pursuant to the following laws or regulations:

    • any law binding or applicable to us within or outside EU and Hong Kong in force from time to time;

    • any guidelines, guidance or codes of practice given, published or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial service providers within or outside EU and Hong Kong, by which we are bound due to our location or the locations of our businesses; and

    • any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;

  • the Processing is necessary to investigate any suspicious activities;

  • the Processing is necessary to protect the vital interests of any individual; or

  • we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

Your Personal Data will also be Processed and used by us for one or more of the following purposes, depending on the circumstances:

  • managing our Website and Services;

  • understanding our customers and their needs;

  • designing and improving our Website and our Services;

  • geo targeting, pixel targeting and optimization of our marketing funnels;

  • contacting you or responding to your inquiries and comments;

  • direct marketing services, products and other subjects as described in the Section for Direct Marketing Activities below;

  • protecting our rights and property;

  • providing you with information regarding the promotions or Competitions and conducting such promotions or Competitions;

  • complying with our internal policies, procedures, measures or arrangements for the use of data and information and for prevention or detection of money laundering, terrorist financing or other unlawful activities; or

  • comparing your data or other persons for data verification or otherwise producing or verifying data, whether or not for the purpose of taking action against you.

In addition to the foregoing purposes:

  • If you are also a Platform User,, your Personal Data will be Processed and used by us for one or more of the following purposes, depending on the circumstances:

    • processing the opening of your Account(s);

    • providing the Services related to the Platform as per your request;

    • day to day operation and maintenance of your Account(s);

    • managing our Token Exchange Website and related Services;

    • contacting you or responding to your inquiries and comments;

    • direct marketing services, products and other subjects as described in the Section for Direct Marketing Activities below;

    • determining the amounts of indebtedness owed to or by you; or

    • enabling the enforcement of your obligations, including without limitation, the collection of amounts outstanding from you.

  • If you are an Authorized Person of a Platform User who is a Corporate Person, your Personal Data will be Processed and used by us for one or more of the following purposes, depending on the circumstances:

    • processing the opening of such Corporate Person’s Account(s);

    • providing the Services related to the Platform as per your or such Corporate Person’s request;

    • day to day operation and maintenance of such Corporate Person’s Account(s);

    • managing our Token Exchange Website and related Services;

    • contacting you such Corporate Person or responding to your such Corporate Person’s inquiries and comments;

    • direct marketing services, products and other subjects as described in the Section for Direct Marketing Activities below;

    • determining the amounts of indebtedness owed to or by such Corporate Person; or

    • enabling the enforcement of your such Corporate Person’s obligations, including without limitation, the collection of amounts outstanding from such Corporate Person.

Disclosure of Personal Data

All your Personal Data held by us will be kept confidential but we may, for the purposes set out in this Policy, provide and disclose such information to the following parties:

  • our Group Companies, any agent, contractor, financial institutions or third party service provider (who may be Processors) who provide administrative, professional advisory, telecommunication, information service, computer, data processing, prepare and/or mail and/or email communications in connection with the operation of our business and our provision of the Website to you, wherever situated;

  • any person to whom we are under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applicable to us, or any disclosure under and for the purposes of any guidelines, guidance or codes of practice published, given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial service providers with which we are expected to comply, or any disclosure pursuant to any of our contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or relevant self-regulatory or industry bodies or associations, all of which may be within or outside Hong Kong and may be existing currently or in the future;

  • subject to us receiving your consent, we may provide and disclose your Personal Data held by us to external service providers (including mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that we may engage for the purposes set out in this Policy such as for the purpose of processing the direct marketing of our Services and products to you only (the direct marketing purposes are set out in this Policy under the section "Direct Marketing Activities"), wherever situated.

If you are a Platform User or an Authorized Person of a Platform User who is a Corporate Person, all your Personal Data held by us will be kept confidential but we may, for the purposes set out in this Policy, provide and disclose such information to the following parties (in addition to the parties stated above):

  • our Group Companies, any agent, contractor, financial institutions or third party service provider (who may be Processors) who provide administrative, professional advisory, KYC checks, telecommunication, information service, computer, payment, data processing, trade execution, payment or clearing, storing of Tokens, transferring of Tokens and funds in and out of your (or such Corporate Person’s) Account, prepare and/or mail and/or email communications, transaction confirmations in connection with the operation of our business and our provision of the Services to you and other Platform Users, wherever situated;

  • any person to whom we are under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applicable to us, or any disclosure under and for the purposes of any guidelines, guidance or codes of practice published, given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial service providers with which we are expected to comply, or any disclosure pursuant to any of our contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or relevant self-regulatory or industry bodies or associations, all of which may be within or outside Hong Kong and may be existing currently or in the future;

  • subject to us receiving your consent, we may provide and disclose your personal data held by us to external service providers (including mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that we may engage for the purposes set out in this Policy such as for the purpose of processing the direct marketing of our Services and products to you only (the direct marketing purposes are set out in this Policy under the section "Direct Marketing Activities"), wherever situated.

When we are involving third party Processors into the performance of our Services and contractual obligations and such involvement requires the sharing of Personal Data, we have entered with our third party Processors into data processing agreements according to Art. 28 of the European General Data Protection Regulation ("GDPR") and, as far as required, further appropriate safeguards according to Art. 46 – 49 GDPR. The list of third party Processors to which we disclose your Personal Data can be requested by e-mail to [email protected]. Specifically we can already name the following Data Processors:

Azure Portal

To store your Personal Data, we are also using Azure Portal, a service provided by our data processor Microsoft Corporation, Konrad-Zuse-Str.1; 85716 Unterschleißheim; Germany.

*For further information, please see **Azure's Privacy Policy*.

Amazon AWS

*To store your Personal Data, we are also using Amazon AWS, a service provided by our data processor **Amazon Europe Core SARL, Amazon EU SARL, Amazon Services Europe SARL and Amazon Media EU SARL, all four at 5 Rue Plaetis L-2338, Luxembourg and Amazon Video Limited of 1 Principal Place, Worship Street, London, EC2A 2FA, UK (together "Amazon Europe"). **For further information, please see **Amazon's Privacy Policy*.

Gsuite

To store your Personal Data, we are also using Gsuite, a service provided by our data processor Google LLC*., Gordon House Barrow St., Dublin 4, Ireland. *

For further information, please see **Gsuite Privacy Polic*y.*

LiveAgent

*To store your Personal Data, we are also using LiveAgent, a service provided by our data processor *Quality Unit, s.r.o., Vajnorská 100/A, 83104 Bratislava, Slovakia (European Union).

For further information, please see **LiveAgent’s Privacy Polic*y.*

Hubspot

*To store your Personal Data, we are also using Hubspot, a service provided by our data processor *HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA.

*For further information, please see **Hubspot's Privacy Policy*.

Processing your Sensitive Personal Data

We do not seek to collect or Process your Sensitive Personal Data, except where:

  • the Processing is required or permitted by applicable law

  • the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);

  • the Processing is necessary for the establishment, exercise or defence of legal rights;

  • the Processing is necessary for opening, maintaining your Account and for providing you access to and use of the Platform; or

  • we have obtained your explicit consent prior to Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Consent and withdrawal

Any consent is provided freely. If you give your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of Processing based on consent before its withdrawal. After your withdrawal we will stop to Process your Personal Data, including storage unless otherwise required by applicable law. This paragraph is only relevant for Processing that is entirely voluntary – it does not apply for Processing that is necessary or obligatory in any way.

To withdraw your consent, click the unsubscribe button on any newsletter your receive from us or you may write to us at the address or email address set out under the Section Our contact information, Data Controller.

Cookies

On our web properties, only Google Analytics and YouTube set cookies. We have to set a cookie of our own though, for remembering acceptance or rejection of our cookie banner.

If you have Do Not Track activated in your browser, or if you rejected our cookie banner, we don’t collect any information and won’t let Google set any cookies in your browser.

If you reject the cookie banner, all cookies set by Google Analytics will be removed from your browser. You also have the option of disabling Cookies in your browser setting, and deleting Cookies from your computer’s hard disk at any time.

In general, you can block cookies by using your browser’s settings, or by installing a browser add-on such as Privacy Badger or uBlock Origin.

Direct Marketing Activities

We may use your Personal Data for our direct marketing purposes, which purposes are set out in this Section.

We may also transfer your Personal Data to our following group companies (each a "Group Company" and any two or more of them are referred as ”Group Companies”) for use by them for direct marketing:

trade.io AG Ltd, Kolonakiou 37, Linopetra, 4103, Limassol, Cyprus, may use your name, email address, address and mobile number to inform you and offer you about upcoming opportunities that are similar to the Platform or advisory and consulting services, products and solutions related to Token investments and fund raising by Token Sales or other Token issuers

Trade.io AG, Piazza Santa Lucia 7, 6900 Lugano, Switzerland, may use your name, email address, address and mobile number to inform you and offer you about upcoming opportunities that are similar to the Platform or advisory and consulting services, products and solutions related to Token investments and fund raising by Token Sales or other Token issuers

trade.io Pte Ltd may use your name, email address, address and mobile number to inform and offer you about upcoming opportunities that are similar to the Platform or to market and promote Token Sales of other Token issuers

trade.io Technologies Limited, 5/F, Eaton Club, Champion Tower, 3 Garden Road, Central, Hong Kong may use your name, email address, address and mobile number to inform and offer you about upcoming opportunities that are similar to the Platform or to market and promote Token Sales of other Token issuers

**trade.io Consulting Limited, **5/F, Eaton Club, Champion Tower, 3 Garden Road, Central, Hong Kong, may use your name, email address, address and mobile number to offer you advisory and consulting services, products and solutions related to Token investments and fund raising by Token Sales

**trade.io Exchange Proprietary Limited, 205 Vineyard Centre, Vineyard Road, Claremont, 7780, South Africa **may use your name, email address and mobile number to inform and offer you about upcoming opportunities that are similar to the Platform or to market and promote Token Sales of other Token issuers

trade.io Financial Ltd, c/o Unit 2A, 2nd Floor, Landmark Square, Earth Close, West Bay Road, PO Box 31489, Grand Cayman, Cayman Islands, KY1-1206 may use your name, email address and mobile number to inform and offer you about upcoming opportunities that are similar to the Platform or to market and promote the Trade.io Liquidity Pool

We may not use your Personal Data for our own direct marketing and we may not transfer any of your Personal Data to any of our Group Companies without your consent. By clicking the "I Agree" button at the bottom of this page, you consent to us using your Personal Data for our direct marketing purposes and to transfer your Personal Data to any of our Group Companies listed in this Section for them to do direct marketing. You may opt out of us using your Personal Data for our direct marketing or providing your Personal Data to any of our Group Companies (other than us) for their direct marketing by writing to us at [email protected].

Links to Business Partner and Co-Branded Sites

Certain links contained on our Websites may direct you to co-branded websites maintained by trade.io or to companies which trade.io has established business relationships. When you submit information to one of these co-branded sites or partner companies, you may be submitting it to both trade.io and such co-branded sites or partner companies. Under no circumstances will trade.io be held responsible for the privacy practices of these business partners and we therefore strongly encourage you to read their respective privacy policies as they may differ from ours.

Your rights related to data privacy

You have the right to request:

  • access to and rectification of your Personal Data;

  • erasure of your Personal Data except if such erasure is prohibited under any applicable law or it is in the public interest (including historical interest) for such Personal Data not to be erased or as set forth below; or

  • restriction of their Processing or ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by us.

Furthermore, you have the right to object Processing as well as to request data portability.

If you are in Hong Kong, you do not have the right to request for erasure of your Personal Data and your Personal Data will be retained for as long as the purposes for which such Personal Data were collected continue. As a general rule, the maximum retention period is 7 years.

If you request to erase your Personal Data, it may limit our ability to provide you with any of our Services and/or your ability to access or use our Website or allow you to participate in a promotion, survey or Competition as set out under the Section for Basis for Processing Personal Data, or if you are a Platform User, we may not be able to continue to provide you with access to or use of the Platform or we may need to terminate our Account with us or we may limit your use or access to the Platform, or if you wish to become a Platform User, we may not be able to process your account opening application or we may need to turn down your application.

If you are in the EU you have the right to file a complaint to the responsible European Data Protection Authority.

If you are in Hong Kong, you have the right to file a complaint to the Privacy Commissioner for Personal Data.

Our contact information, Data Controller

If you have a direct business relationship with us, we are a Data Controller according to Art. 4 para. 7 GDPR.

For any requests relating to your Personal Data or if you have any information regarding this Policy, you can contact our Compliance Officer as follows:

Piazza Santa Lucia, 7

CH-6900 Lugano-Massagno

Ticino, Switzerland

[email protected]

Attention: Compliance Officer

Definitions

  • **Authorized Person **means a person that is authorized by a Platform User who is a Corporate Person as its representative to use, operate and control such Platform User’s Account and is approved by us in writing.

  • Competition includes different competitions, trials, games and any other type of events held by us, our business partners, or contractors from time to time.

  • Controller means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

  • **Corporate Person **includes body corporate, trust, partnership, joint venture and unincorporated association.

  • Crypto-Currency means a digital or virtual currency that uses cryptography for security.

  • Data Protection Authority means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

  • EEA means the European Economic Area.

  • Hong Kong means the Hong Kong Special Administrative Region of the People’s Republic of China.

  • Personal Data means information that is about any individual, or from which any individual is identifiable. Examples of Personal Data that we may Process are provided above in this Policy.

  • Platform means the token exchange platform provided by us which may be access through the Token Exchange Website or our mobile application.

  • Process, Processing or Processed means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • Processor means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

  • Services mean any services provided by trade.io including but not limited to trading of Tokens via the Platform and its related services and consulting and advisory services, products and solutions related to Token investments and fund raising by Token Sales or other Token issuers.

  • Sensitive Personal Data means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under applicable law.

  • Token means Crypto-Currency, cryptographic tokens and other digital rights or assets which are supported by us and listed on the Platform.

  • **Token Exchange Website **means https://exchange.trade.io

  • Token Sale is a means by which funds are raised for a new Crypto-Currency venture.

  • trade.io means trade.io Technologies Limited and trade.io Consulting Limited and any reference to "we", “our” or “us” is also a reference to trade.io.

  • **Websites **to include Token Exchange Website, https://trade.io, https://angels.trade.io, https://otc.trade.io, https://education.trade.io, and any other websites provided by us and the reference to "Website" means any one of these websites.

This Policy is translated into different languages. In case of discrepancies between the English and other translated versions, the English version shall prevail.