PRIVATE POLICY

1. Introduction

This Privacy Policy is an overview of how we collect, use, and process your personal data when you use our Website and our App.

This policy details the personal information we collect and use, how we look after it, and the circumstances in which we may share it with someone else. It also sets out your rights around how we handle your information and lets you know how to contact us if you have any concerns.

Please read this Policy carefully, as it becomes legally binding when you use our Services and access our Website. We take privacy and protection of your data very seriously and are committed to responsibly handling the personal information of those we engage with and in a way that meets the legal requirements of the countries in which we operate. By agreeing to use our Services, you agree that your personal data will be handled by Trading Games Ltd. If you have any questions about how we protect or use your data, please email us at Support@thefxtradingchallenge.com.

2. Definitions

Agreement - means Trading Games Ltd Terms of Service and its Schedules, as amended from time to time and made available in the App and the Website

App - means our mobile or web application through which we will provide to you the Services.

Data controller - means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data processor - means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.

Data processing - means activities which are performed on personal data, 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.

GDPR - means the Regulation (EU) 2016/679, referred to as “the General Data Protection Regulation”

UK GDPR - mean regulation Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419)

Trading Games, we, us, our - means Trading Games Ltd

Services - means the services that we provide to you under the Agreement.

KYC - means “know-your-client”, a regulatory obligation to identify and verify the clients who use our services.

personal data - means any information relating to an identified or identifiable physical person - an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the identity of that natural person.

Policy - This privacy policy, as amended from time to time and made available in the App and the Website

Website - Means the website of Trading Games, currently: www.thefxtradingchallenge.com

3. What data we collect about you

When you sign up to use our Services, we need to process your personal data. On a high level, we use and process the following data:

• Personal details 
  • such as your full name, personal identification number (or an equivalent identifying code), date of birth, age.
• Contact information 
  • such as your email address, residence address and supporting documentation thereof (for example utility bills), phone number.
• Background information to fulfil our regulatory requirements 
  • such as bank account information (and information in the bank statements), IP address, tax residency and tax identification numbers, citizenship, employment information, source of wealth, information provided in the identification documents (date of issue, expiry date, picture, country of issuance, etc.).
• Data on how you use the Services – various statistics and information on your Service usage, for example how many times a month you use the Services and what features do you use and how.
• Data to facilitate the usage of Services – for example you login details and the password, payment information (your bank account number to make the deposits and withdrawals), browser type and version, time zone settings, operating system of your device to access the Services.

To learn how specifically we process your personal data, please find a detailed overview of personal data processing in the Annex 1 below. Please be aware that we may collect the information provided in the Annex 1 but depending on specifics, we do not always collect all of those data points in respect to each individual data subject.

4. Why do we use your data

It is necessary for us to process your data in order to provide the Services to you and to fulfil our legal requirements. If you decline to share with us the data we request, we are unable to provide the Services to you. We use your personal data in order to:

• carry out our obligations relating to your Agreement (Terms of Service) with us and to provide you with the information, products and Services, as well as facilitate social features connected to our Services.
• comply with any applicable legal and/or regulatory requirements.
• notify you about changes to our Services.
• keep our Services safe and secure.
• administer our Services and for internal operations.
• improve our Services.
• measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you.
• analyse, identify and categorise customers who use or may be interested in the Services.
• combine information we receive from other sources with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

5. Legal basis for using your data

To use the information as provided in section 4, we rely on following data processing grounds:

• Consent ((UK) GDPR Article 6 (1)(a)). We can process your data based on your consent. We for example may send you marketing materials based on your consent.
• Performance of a contract ((UK) GDPR Article 6 (1)(b)). We may process your data to perform our obligations pursuant to the Agreement to provide the Services to you. This might for example be the case if you contact customer support with any questions you might have.
• Legal obligations ((UK) GDPR Article 6 (1)(c)). We may process your data if it is necessary to meet legal obligations, we are subject to. This for example might be data processing we conduct during our anti-money laundering activities.
• Legitimate interest ((UK) GDPR Article 6 (1)(f)). We may process your data if we have a legitimate interest to do so. Such necessity might arise for example for business development, to ensure information security, during fraud investigations, if required so by our external cooperation partners or if necessary to protect our legal interest.

6. Sharing data

We aim to share as little personal data on your as possible to service providers, especially outside the EEA region. Whenever possible, we anonymize the shared data so that you cannot be identified based on that data. In addition to that, we may transfer your personal data to countries outside the EEA area if it is necessary for the purposes as provided in Annex 1 of this Policy. In such cases we shall ensure that adequate safeguards are in place to protect your rights. You may request a copy of such safeguards we have put in place by contacting us via email.

We may also share your personal data if we are legally required to do so, for example in cases of financial supervisory authority, financial intelligence unit, tax authority or other relevant authority requesting personal data from us.

7. Publicly available data

We may also share your personal data with other Trading Games customers that you know. Customers can sync their contact list with our App to help them connect to their contacts that also use the App, as well as invite people via SMS to download the App. You are visible to persons that use the App and that have your phone number or email stored in their contact list. By default, your personal profile is set to private. You may choose to turn it public to disclose such information to your friends and other contacts. You can always adjust your profile privacy settings via the App.

If you wish to not be discoverable by persons who have your contact details stored in the phone's contact list, please contact the Customer Support here: help@thefxtradingchallenge.com.

In case of syncing the contact list, the personal information (phone number and email) accessed via the contact list sync will be cryptographically hashed so that only information we store is a hash value derived from the phone number and/or email. We do not collect names or any other information associated with your contacts and we do not share hash values we collect or make available to others. The process of hashing the information is irreversible.

8. Where we store your data

Protection of personal data is very important to us. We use various technical and organisational measures to ensure that your data is safe with us.

Your personal data is stored either in our databases or in databases of our service providers. In some instances, we may share your data with service providers located outside the EEA region, please see section 6 for more details.

9. How long we keep your data

We generally store your personal data as long as necessary for the purpose under which we collected the information. As a regulated financial institution, we are required by law to store some of your personal and financial data beyond the closure of your account with us. We will delete data that is no longer required by a relevant law or jurisdiction in which we operate. Our general data retention period is 5 years after ending the business relationship with you. This is a statutory data retention period which we have to follow to be compliant with our legal obligations. In some cases we may need to hold your personal data for longer to meet our legal obligations or if we have a legitimate interest (if longer data retention is for example required by our cooperation partners) to do so.

10. Your data protection rights

Under relevant data protection laws and this Policy, you have various rights related to your personal data as provided below:

• Right to access. You have the right to request access to the information we hold about you. Please be aware that this right can sometimes be limited by our regulatory obligations. We are unable to provide you access to personal data that would cause us to break the law, for example.
• Right to rectification. You have the right ask us to update any of the information about you that you think is inaccurate or incorrect.
• Right to erasure and restriction of processing. You have the right to ask us to delete, stop processing or limit our use of your information that we hold. Please be aware that if we have a regulatory obligation to still retain this information, we might be unable to facilitate this request until the required retention period has elapsed.
• Right to data portability. You have the right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format and you have the right to request us to transmit this data to another data controller if the data was gathered by your consent, pursuant to the Agreement between us or via automated means.
• Right to withdraw your consent. Your consent is voluntary, and you have the opportunity to withdraw your consent at any time. Please be aware that in such cases we may not be able to provide Services to you. In addition to that, you always have the right to withdraw your consent from receiving marketing materials from us. We provide you with the option to unsubscribe from such communications in each email, via the unsubscribe link. We still shall send you relevant information regarding the Services and our Agreement.

11. Automated decisions

We may make automated decisions about you. This means that we may use technology that can evaluate your personal circumstances and other factors to predict risks or outcomes. We do this for the efficient running of our services and to ensure decisions are fair, consistent and based on the right information. Most of the automated decisions we make are connected to providing the Services to you. If we make automated decisions about you that limit your rights or access to the App, we will review those decisions manually as soon as possible.

Our App can only be accessed from regions in which we have decided to operate in. We automatically restrict access to our App in regions that we do not operate in.

12. Complaints

If you have any concerns about our use of your personal data, you can make a query or a complaint to us and we will do our best to address the issue.

If you feel that we have not addressed your questions or concerns adequately, or you believe that your data protection or privacy rights have been infringed, you can complain to:

• the Information Commissioner’s Office (ICO) in the UK. The ICO’s contact details: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom, Helpline number: 0303 123 1113, ICO website: https://www.ico.org.uk.

More information can be found at https://ico.org.uk/make-a-complaint/ You have a right to bring an action before a court.

13. Applicable law and jurisdiction

In respect to Trading Games Ltd, this Policy will be governed by and construed in accordance with English law. Without prejudice to any rights, you may have to refer a complaint to the authorities, the courts of England and Wales have exclusive jurisdiction to settle any dispute arising in connection with this Agreement and for such purposes we and you irrevocably submit to the jurisdiction of English courts.

14. Changes to this Policy

We continuously review our policies and procedures. We’ll post any changes we make to this policy on this page and let you know about any significant changes via email.