Privacy Policy

1. INTRODUCTION

1.1. At Supertrade Ltd. ("Company," "We," "Us," or "Our"), we are committed to protecting your privacy and securing your personal data (as defined below). As part of this commitment, we aim to be transparent about the information we collect, when we collect it, and how we use it.

1.2. This Privacy Policy ("Policy") explains how we collect, use, and process personal data when you use our website and services, including any products or features provided by the Company (collectively, the "Services"). By accessing or using our website or Services, you confirm that you have read, understood, and agree to the terms of this Policy.

1.3. " Personal Data " refers to any information relating to an identified or identifiable individual. This includes data that, alone or in combination with other information, could be used to identify you.

1.4. This Policy is an integral part of our Terms and Conditions , which can be accessed here: https://supertrade.com/en/terms-and-conditions

1.5. We use cookies to enhance your experience on our website. Where cookies are not strictly necessary for providing our Services, we will request your consent before using them. For more details, please refer to our Cookie Notice , available at: https://supertrade.com/en/cookie

2. WHO CONTROLS YOUR PERSONAL DATA AND HOW TO CONTACT US

The Controller responsible for processing your personal data is Supertrade Ltd., registered under company number 2024-00699 , with its registered office at:

Top Floor, Rodney Court Building, Rodney Bay, Gros Islet, Saint Lucia.

If you have any questions regarding the processing of your personal data or wish to exercise your rights under applicable data protection laws, you can contact Supertrade Ltd. at:

📍 Address : Top Floor, Rodney Court Building, Rodney Bay, Gros Islet, Saint Lucia
📧 Email :  [email protected]

3. PERSONAL DATA WE COLLECT

3.1. This section outlines the categories of personal data we process. If we collect personal data from sources other than you directly, we also specify the origin and type of such data.

3.2. Contact Data : We may process data that enables us to contact you, including your n ame, email address, telephone number, postal address, and social media identifiers . This data is provided by you. If you log into our website via a social media account, we may receive elements of Contact Data from the relevant social media provider.

3.3. Account Data : We may process data related to your website account, such as your account identifier, name, email address, business name, account creation and modification dates, website settings, and marketing preferences. The primary source of Account Data is you, though some data may be generated automatically by our website. If you log in using a social media account, we may receive relevant Account Data from that provider.

3.4. Profile Data : We may process the personal information you provide in your website profile, including name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests, hobbies, education, and employment details. This data is collected from you, but elements may also be obtained from your linked social media account.

3.5. Customer Relationship Data : We may process information related to our interactions with you as a customer, including your name, contact details, classification within our customer relationship system, and records of communications between us. This data is provided by you.

3.6. Service Data : We may process personal data provided and generated through your use of our services, including records of previous purchases . This data originates from you and/or our systems.

3.7. Transaction Data : We may process data related to transactions made with us or via our website, including your name, contact details, payment card details (or other payment methods), and transaction details . This data is provided by you.

3.8. Communication Data : We may process data contained in or related to communications between you and us, including message content and associated metadata . Metadata from website contact forms is generated automatically.

3.9. Usage Data : We may process data related to how you interact with our website and services, including IP address, geographical location, browser type and version, operating system, referral source, visit duration, page views, navigation paths, and usage patterns. This data is collected through our analytics tracking system.

3.10. Third-Party Data : Please do not provide us with personal data belonging to other individuals unless we explicitly request it.

3.11. You are not obligated to provide us with any personal data about you. However, in some instances, not providing such personal data will prevent us from providing uou with the Services you requested us to provide you and will prevent your use of the Services or a part thereof.

3.12.  Personal Data of Minors

Our Services are not intended for individuals under the age of 18. We do not knowingly collect or solicit personal information from minors. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately so we can delete the information from our records.

4. PURPOSES OF PROCESSING AND LEGAL BASES

4.1. We process Your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis. We will not process personal data about you unless there is a legal basis for such processing.

The legal bases according to which the Company may process personal data about you are as follows:

- Legitimate Interests. Processing is necessary for the purposes of provision of the Services, or any other legitimate interests pursued by the Company or by a third party.

- Consent. Your consent that the Company will process personal data about you for one or more specific purposes.

4.2. We may use personal data about you for the following purposes:

4.2.1. Operations – We process your personal data to operate our website, fulfill orders, provide services, generate invoices, and manage payments, including credit control. The legal basis for this processing is our legitimate interest in ensuring the proper administration of our business, or the necessity of processing for the performance of a contract with you or in preparation for entering into such a contract at your request.

4.2.2. Publications – We may process account data, profile data, and service data for publication on our website or other platforms in accordance with your express instructions.

4.2.3. Relationships and Communications – We process contact data, account data, customer relationship data, transaction data, and communication data to manage relationships, communicate with you (excluding direct marketing), provide support services, and handle complaints. The legal basis is our legitimate interest in maintaining business relationships, ensuring service accessibility, and administering our business properly.

4.2.4. Personalisation – We process account data, service data, and usage data to personalise content and advertisements, ensuring that you see only relevant material. The legal basis is our legitimate interest in providing an optimal user experience

4.2.5. Direct Marketing – We process contact data, account data, profile data, customer relationship data, and transaction data to create, target, and send direct marketing communications via email, SMS, post, fax, or telephone. The legal basis is our legitimate interest in promoting our business and communicating relevant marketing offers to our users.

4.2.6. Research and Analysis – We process usage data, service data, and transaction data to analyse the use of our website and services, as well as other interactions with our business. The legal basis is our legitimate interest in monitoring, improving, and securing our business operations.

4.2.7. Record Keeping – We process personal data to create and maintain business records, including backup copies of databases. The legal basis is our legitimate interest in ensuring efficient business operations and compliance with this policy.

4.2.8. Security – We process personal data to maintain security, prevent fraud, and mitigate criminal activities. The legal basis is our legitimate interest in protecting our website, services, business, and stakeholders.

4.2.9. Insurance and Risk Management – We process personal data as necessary for obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice. The legal basis is our legitimate interest in protecting our business against potential risks.

4.2.10. Legal Claims – We process personal data as necessary for establishing, exercising, or defending legal claims, whether in court, administrative, or alternative dispute resolution procedures. The legal basis is our legitimate interest in protecting and asserting legal rights for both our users and the Company.

4.2.11. Legal Compliance and Vital Interests – We may process personal data to comply with legal obligations or to protect your vital interests or those of another natural person.

5. SHARING YOUR PERSONAL DATA

5.1 Disclosure Within Our Corporate Group

We may share your personal data with other companies within our corporate group, including our subsidiaries, our ultimate holding company, and its subsidiaries, where necessary for the purposes and legal bases outlined in this Policy.

5.2 Disclosure to Insurers and Professional Advisers

We may disclose your personal data to our insurers and professional advisers when necessary for purposes such as obtaining or maintaining insurance coverage, managing risks, or seeking professional advice.

5.3 Data Storage on Our Website

Your personal data is stored in our website database.

5.4 Disclosure to Third-Party Suppliers and Trade Funding Partners We may share your personal data with third-party suppliers on our trading portal and with third-party trade funding partners.

5.5 Financial Transactions and Payment Processing We may share your personal data with our payment service providers only to the extent necessary for processing payments, issuing refunds, and handling related queries or complaints.

5.6 Sharing Data with Third-Party Suppliers of Goods and Services

If you make an inquiry through our website or services, we may share your contact details and relevant personal data with selected third-party suppliers of goods and services listed on our website. This enables them to contact you with offers or information about their products and services. Each third party acts as a data controller regarding the personal data we provide and will supply you with its own privacy policy, which governs its use of your data.

5.7 Legal and Compliance-Related Disclosures

In addition to the above, we may disclose your personal data if required to comply with a legal obligation, protect your vital interests or those of another person, or establish, exercise, or defend legal claims in court, administrative, or out-of-court proceedings.

5.8. We do not sell, rent, or lease your personal data to third parties for their marketing purposes. 5.9. International Data Transfer Protocols

Safeguards are implemented to ensure the security and integrity of your data, particularly during international transfers. These measures encompass encryption, pseudonymization and contractual agreements with recipients to uphold data protection standards.

5.9. International Data Transfer Protocols

Safeguards are implemented to ensure the security and integrity of your data, particularly during international transfers. These measures encompass encryption, pseudonymization and contractual agreements with recipients to uphold data protection standards.

6. RETAINING AND DELETING PERSONAL DATA

6.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

6.2. We will retain your personal data for a maximum of 10 years from the end of your last contract with us or until you object or unsubscribe from the business communications; if we need to fulfill our legal obligations, we keep your personal data for the period set out by the relevant law.

6.3. Personal data is stored on computers and other devices in an encrypted database. Organisational and technical safeguards have been put in place to protect the data that we collect and handle from unauthorised access, modification, disclosure, or destruction. We may store your data on servers provided by third-party hosting vendors with whom we have contracted.

6.4. Where your personal data is no longer required by us, we will either securely delete or anonymise the personal data in question.

7. DATA SECURITY

7.1. We have implemented appropriate technical and organisational precautions and security policies, rules and procedures to secure your personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification, or unlawful destruction, and to prevent the loss, misuse or alteration of your personal data.

7.2. To comply with the law, we employ industry-standard encryption techniques to encrypt data during transit and at rest, ensuring confidentiality and integrity at all times.

7.3. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know business requirements. They will only process your personal data on our instructions or subject to a lawful ground, as well as their duty of confidentiality.

7.4. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.5. We cannot provide absolute assurance of safeguarding against unauthorised access or breaches. In the event of a data breach, we will conduct a thorough risk assessment and notify impacted individuals in accordance with applicable local laws.

8. THIRD-PARTY WEBSITES

8.1. We provide links to external websites or information as a service. Clicking these links redirects users away from our website.

8.2. It is important to note that we neither endorse nor sponsor these third parties or their sites. Users are solely responsible for their use of these external links, which is subject to the terms and privacy notices of the respective third-party websites.

9. USER FORUMS

9.1. Participation in user forums on our website or through links redirecting to third-party platforms like Discord or Telegram implies acknowledgment that shared information may be accessible and utilised by other individuals.

9.2. We disclaim responsibility for the practices or actions of third parties who gather and employ data publicly disclosed by users on the website forums.

9.3. Users are advised to exercise prudence and discretion when divulging personal or sensitive information in such forums.

10. MOBILE DEVICE INFORMATION

10.1. We rely on trusted third-party service providers for in-depth analysis of mobile applications. This analysis aims to optimise performance, track usage patterns, and promptly rectify any errors detected within mobile applications.

10.2. Reports generated encompass aggregate usage data, browsing patterns, device information and details on application errors.

11. USAGE OF AUTOMATED CHATBOTS

11.1. We may utilise chatbots as an initial point of contact between the Company and its users to facilitate customer service interactions.

12. YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

12.1. In accordance with the GDPR, you have the right to request confirmation from us regarding the processing of your personal data and we will provide you with access to the following information with reasonable intervals:

• what personal data we have about you;

• the reasons why we are processing your data;

• the recipients to whom your data may have been disclosed;

• the duration for which we intend to keep your data (if possible);

• whether we transfer your data and the safeguards we have to protect your data;

• your rights with respect to your personal data;

• the process for making a complaint;

• the source of your personal data;

• whether we have used any automated decision-making or profiling and any related information.

12.2. Right to Rectification – Although all reasonable efforts will be made to keep your personal data updated, you are kindly requested to inform us of any changes. With respect to your residential address and phone number, you can notify us of the change by amending your profile of any changes to your personal data. If the change pertains to data that cannot be amended by changing your profile, please contact us. To this end you have the right to ask us to rectify inaccurate personal data and to complete incomplete personal data concerning you. We may seek to verify the accuracy of the data before rectifying it.

12.3. Right to Erasure – You have the right to ask us to delete your personal data and we shall comply without undue delay but only where:

• the personal data are no longer necessary for the purposes for which they were collected; or

• you have withdrawn your consent (in those instances where we process on the basis of consent) and we have no other legal ground to process your personal data; or

• you have successfully exercised your right to object (as explained below); or

• your personal data have been processed unlawfully; or

• there exists a legal obligation to erase the data to which we are subject.

12.4. Right to Data Restriction – You have the right to ask us to restrict (that is, store but not further process) your personal data but only where:

the accuracy of your personal data is contested (see the right to data rectification above), for a period enabling us to verify the accuracy of the personal data; or

• the processing is unlawful and you oppose the erasure of your personal data; or

• we no longer need the personal data for the purposes for which they were collected but you need the personal data for the establishment, exercise or defense of legal claims; or

• you exercised your right to object and verification of our legitimate grounds to override your objection is pending.

12.5. Following our request for restriction, except for storing your personal data, we may only process your personal data:

• where we have your consent; or

• for the establishment, exercise or defense of legal claims; or

• for the protection of the rights of another natural or legal person; or

• for reasons of important public interest.

12.6. Right to Data Portability – You can request us to give you your personal data in a format that is easy to read by machines, or directly transfer it to another data controller if possible without harming others’ rights and freedoms. This right only applies if: a) the processing is based on your consent or on the performance of a contract with you; and b) the processing is carried out by automated means.

12.7. Right to Object to Certain Processing – In those cases where we process your personal data for the performance of a task carried out in the public interest or when processing is necessary for the purposes of the legitimate interest pursued by us or by a third party, you shall have the right to object to processing of your personal data by us.

12.8. When your data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data, which includes profiling to the extent that it is related to such direct marketing.

12.9. Right to Withdraw Consent – In situations where we handle your personal data based on your consent, we will never assume your consent but rather obtain it from you in a clear and explicit way. You have the right to withdraw your consent at any time and the process of doing so should be the same as providing it. If you decide to withdraw your consent, we will check if we have an alternative legal basis for processing your personal data, such as a legal obligation. If we do, we may still process your data without your consent and will inform you accordingly.

12.10. Right to lodge a Complaint – You are entitled to file complaints with the relevant Data Protection Supervisory Authority. If you reside in an EU member state, you can file a complaint with the Data Protection Authority of that particular state. However, we request that you first attempt to resolve any issues with us before contacting the competent authority, even though you have the right to do so at any time, as mentioned above.

13.YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)

13.1. For California residents under 18 years old who are registered users of any Sites featuring this Privacy Notice, California Business and Professions Code Section 22581 allows the request and removal of publicly posted content or information.

13.2. In compliance with the CCPA, this Privacy Notice outlines the personal data categories collected, processed and disclosed by FunderPro, along with the data sources and business purposes for such actions.

13.3. Under California law, you may also request, up to twice within a 12-month period, information regarding our collection, usage and disclosure of your Personal Data. This includes:

• Categories of personal data collected and their sources in the preceding 12 months.

• Commercial or business reasons for collecting, using, or disclosing that data.

• Categories of third parties to whom the data was disclosed in the preceding 12 months.

13.4. Furthermore, upon receiving a verifiable request confirming your identity, you may inquire about the specific pieces of personal data collected about you and/or shared with third parties in the previous 12 months.

13.5. You also retain the right to request deletion of personal data collected or maintained by us, subject to certain limitations specified in California law.

13.6. To process your request, you must provide specific personal data to verify your identity as required by the CCPA. This may include your full name, email address, physical address, telephone number and details about your relationship with us.

13.7. We do not engage in discriminatory practices based on the exercise of these rights.

1 4. COOKIES AND TRACKERS

14.1. We may use certain third-party services, such as analytics companies or companies delivering advertisements, which may also use cookies or other technologies, and those practices and providers are subject to their own policies.

14.2. For more information regarding the use of cookies in our website please see our Cookie Notice available at: https://supertrade.com/en/cookie .

15. CHANGES TO THE POLICY

15.1. We may amend the terms of this Policy, from time to time. Whenever we amend this Policy, We will notify you of such amendments by publishing the updated Policy on the website. In addition, when we make significant amendments to this Policy, We will strive to inform you about such amendments via means of communication We believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on our website. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our website or the designated page on the website.

16. CONTACT US

16.1. For inquiries pertaining to the retention period of the data you provide to us or for any other questions related to data privacy, please direct your correspondence to our customer support at  [email protected].

By using our platform and services, you consent to the collection, use, and processing of your personal data as described in this Privacy Policy.