Effective Date: 1 July 2025

1. Introduction

Trader365® Ltd (“Trader365®”, “we”, “us”) is committed to protecting the privacy and fundamental rights of our users and ensuring the lawful, fair, and transparent processing of all personal data under the UK General Data Protection Regulation (UK GDPR). This Policy explains in detail what personal data we collect, how and why we process it, with whom we may share it, and how we ensure its protection throughout its lifecycle.

2. Data Controller

Trader365® Ltd acts as the Data Controller for all personal information collected and processed through our services and affiliated platforms. Users can contact us for any data-related inquiries at support@trader365.co.uk.

3. What Data We Collect

We may collect and process a broad range of personal data, including but not limited to:

• Personal identifiers: full name, email address, phone number, postal address (if required).
• Account information: usernames, encrypted passwords, sign-in history.
• Payment and financial details: payment methods, transaction history (handled securely by third-party processors).
• Device and technical data: IP addresses, geolocation data, device IDs, browser types, operating system versions.
• Usage and behavioural data: interaction logs, feature usage statistics, clickstream data, preferences.
• Marketing preferences and consent records.
• Any additional information voluntarily provided when contacting support or through feedback forms.

4. How Data is Collected

Personal data is collected in several ways:

• Direct collection: provided directly by the user during registration, subscription, or communication with support.
• Automated collection: gathered via cookies, tracking pixels, and other technologies.
• Third-party collection: through integrations with payment processors (Stripe, Apple Pay) and authentication services (Google, Apple ID).

5. Purpose and Legal Basis for Processing

We process your personal data under multiple lawful bases, including:

• Contractual necessity: to fulfil our obligations to deliver the Trader365® service to you.
• Consent: where required for optional services, such as marketing communications.
• Legitimate interests: to maintain, develop, and improve our services, detect fraud, and ensure security.
• Compliance with legal obligations: retaining records for financial auditing and legal reporting.
• Vital interests: where necessary to protect users from harm or fraud.

Our legitimate interests are assessed to ensure they do not override your fundamental rights and freedoms.

6. Categories of Recipients

Your personal data may be shared with:

• Cloud infrastructure providers for secure data hosting.
• Payment processors to handle transactions.
• Analytics and marketing services for performance measurement (e.g., Google Analytics).
• External legal or professional advisors if required by law.
• Law enforcement or regulatory bodies when legally obligated.
  All third-party recipients are contractually obliged to handle your data securely and lawfully.

7. International Transfers

Where personal data is transferred outside the UK or EEA, we implement appropriate safeguards, such as Standard Contractual Clauses approved by the UK Information Commissioner’s Office or rely on adequacy decisions to ensure data remains protected.

8. Data Security

Trader365® implements strict technical and organisational security measures, including but not limited to:

• Encryption of sensitive data in transit and at rest.
• Secure user authentication and access controls.
• Firewalls, intrusion detection, and routine security audits.
• Staff training and confidentiality agreements.
• Regular testing and updates of security protocols.

9. Data Breach Response

We maintain an internal breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the ICO within 72 hours and inform affected individuals without undue delay.

10. Data Retention and Deletion

We store your personal data only for as long as it is necessary for the purposes outlined in this Policy:

• Account and payment records: up to 6 years after account closure to comply with tax and legal obligations.
• Marketing data: retained until you withdraw consent.
• Backup copies: held securely for limited periods in accordance with our backup policy.
  When data is no longer required, it is securely deleted or anonymised. Users may request early deletion where legally permissible.

11. Your Data Rights

Under UK GDPR, you have the following rights:

• Right to Access: Request a copy of your personal data.
• Right to Rectification: Request corrections to incomplete or inaccurate data.
• Right to Erasure: Request deletion of your data under certain circumstances.
• Right to Restriction: Request limits on how we process your data.
• Right to Data Portability: Request transfer of your data in a structured, commonly used format.
• Right to Object: Object to processing based on legitimate interests or direct marketing.
• Rights related to automated decision-making and profiling: Request human intervention if applicable.

Requests should be sent to support@trader365.co.uk. We aim to respond within one calendar month.

12. Exercising Your Rights

You may exercise your rights free of charge, subject to applicable exceptions under UK law. We may request proof of identity to verify your request.

13. Supervisory Authority and Complaints

If you believe your rights under UK GDPR have been violated, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk. We encourage you to contact us first to resolve any concerns directly.

14. Children’s Data

Trader365® does not knowingly collect data from individuals under 18. Users under 18 are prohibited from registering an account. If we become aware of such data, we will take prompt steps to delete it.

15. Data Protection Governance

Trader365® maintains records of processing activities and performs Data Protection Impact Assessments (DPIAs) where required. We review our data protection procedures regularly to ensure ongoing compliance with changing laws and regulations.

16. Changes to This Policy

We may update this Data Protection Policy periodically to reflect legal requirements or operational changes. Significant updates will be communicated via our website or app with a revised effective date.

For all data protection queries, please contact us at support@trader365.co.uk.