TRADETEQ PRIVACY POLICY

We respect the privacy of every person who visits, registers with and/or is an Originator or Funder member of https://tradefinancedistribution.com (the “Site”) and uses the Site’s functionality to stay abreast of developments and trends in the trade finance sector and/or to connect with Funders and/or Originators to explore business opportunities (the “Functionality”).

Please note that in this Privacy Policy when we refer to use of the Site we are referring to use of the Site and the Functionality.

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PURPOSE OF THIS POLICY

1. This privacy policy explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of the Site and sets out your rights in respect of our processing of your personal information.
2. This privacy policy will inform you how you can verify which of your personal information is collected by us through the Site and how you can request that we delete, update or transfer it.
3. This privacy policy is intended to assist you in making informed decisions when using the Site. Please take a moment to read and understand it. Please note that it should be read in conjunction with our General Terms.
4. Please also note that this privacy policy only applies to the use of personal information collected by us from your use of the Site or during your communications with us. It does not apply to personal information collected during your communications with third parties.

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WHO ARE WE AND WHAT DO WE DO?

1. The Site is operated by Tradeteq Limited (“we” “us” or “our”) whose principal activity is provision of the Site for the purposes of reporting on developments and trends in the trade finance sector and assisting Funders and Originators connect and to explore business opportunities.
2. Tradeteq Limited is the data controller responsible for your personal information. Tradeteq Limited is registered at the UK Information Commissioner’s Office with registration number: ZA265460.
3. Tradeteq Limited is an English company with registered company number: 10234056 and whose principal address is 10 Devonshire Square, London, EC2M 4YP, United Kingdom.

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HOW TO CONTACT US?

1. If you have any questions about this privacy policy or want to exercise your rights, please contact us by:
2. sending an e-mail to privacy@tradeteq.com; or
3. writing to us at Tradeteq Limited, 10 Devonshire Square, London, EC2M 4YP, United Kingdom.

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WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

1. Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve the Site and the Functionality; (iii) carry out requests made by you on the Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties, including our users of and subscribers to the Site; (viii) provide support for the provision of the Site and the Functionality; and (ix) use as otherwise required or permitted by law.
2. In particular, we use your personal information for the following purposes:

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Fulfilment of registration and membership requests.

1. We collect and maintain personal information that you voluntarily submit to us during your use of the Site. We use the contact and payment details you have provided to us so that we can provide the Functionality you have subscribed to on our Site, or through correspondence with us. This includes subscriptions and registrations that we arrange offline where we have dealt with each other in person, on the phone or otherwise.
2. If you are a Funder or an Originator registering to use the networking functionality of the platform we will request further personal information from you for “know your client purposes”. This will include requesting identification documentation which is likely to include details of your nationality, date of birth, residential address and your photograph.

Who do we share your personal information with for this purpose?

1. We will share your personal information with the following categories of third parties:

To verify card payments and process refunds – credit card companies and other payment providers;

To provide you with the Functionality – our website development, hosting and maintenance providers

To comply with applicable law – we use an external accounting firm to collect and process KYC information.

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What is our legal basis?

1. It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.

User services.

1. Our Site has different user interfaces to allow you to request information about us, the Site and the trade finance sector generally: Contact information may be requested in each case, together with details of other personal information that is relevant to your user service enquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal information with for this purpose?

1. We do not share your personal information for this purpose.

What is our legal basis?

1. It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best user experience we can to you.

Your feedback about the Site and Functionality.

1. From time to time, we will contact you to invite you to provide feedback about our products and services in the form of online surveys. You may also contact us directly to provide feedback. We use this information to help us improve the quality of the Site and the Functionality. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.

Who do we share your personal information with for these purposes?

1. We do not share your personal information for this purpose.

What is our legal basis?

1. It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

User and subscriber insight and analysis. For more information click here.

1. We analyse your contact details with other personal information that we observe about you from your interactions with our Sites, our email communications to you and/or with the Functionality.
2. Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:
3. an IP address to monitor Site traffic and volume;
4. a session ID to track usage statistics on our Site;
5. Our web pages and e-mails contain “cookies” "web beacons" or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.
6. In some of our e-mail messages, we use a “click-through URL”. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
7. Please see our Cookie Policy for further information.
8. This information is used to create profiles and insights about you and your business interests.
9. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and the Functionality. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting.

Who do we share your personal information with for these purposes?

1. We share your personal information with a limited number of third party service providers to assist us with user insight analytics. These providers include Google who provide us with Google Analytics. More details are provided in our Cookie Policy.

What is our legal basis?

1. Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
2. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other users.

Marketing communications.

1. We carry out the following marketing activities using your personal information:

Email marketing.

1. We use information that we observe about you from your interactions with our Site, our email communications to you (see the User and Subscriber Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

Who do we share your personal information with for these purposes?

1. We do not share your personal information for this purpose.

What is our legal basis?

1. Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
2. We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

Business administration and legal compliance.

1. We use your personal information for the following business administration and legal compliance purposes:
2. to comply with our legal obligations;
3. to enforce our legal rights;
4. protect rights of third parties; and
5. in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?

1. We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?

1. Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
2. Where we share your sensitive personal information, we shall obtain your consent to do so.

The Tradeteq networking platform and Tradeteq messenger functionality (the “Platform”)

1. If you communicate through the Platform we may learn about and process personal information that you or other users have posted or shared on the Platform. We collect information about you when you send, receive, or engage with the Tradeteq Messenger functionality. If you request to connect or accept a connection, we track whether you have acted on it.

What is our legal basis?

1. It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you in order to provide the functionality that you have subscribed to.
2. We will only also obtain your consent for the purposes of using the Platform functionality.

Who do we share your personal information with for this purpose?

1. We will share your personal information with the following categories of third parties:
2. To provide you with the Functionality – our website development, hosting and maintenance providers
3. Analysis and insights - We share your personal information with a variety of third party service providers to assist us with user insight analytics. These providers include Google who provide Google Analytics.
4. Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

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HOW DO WE OBTAIN YOUR CONSENT?

1. Where our use of your personal information requires your consent, you can provide such consent:
2. at the time we collect your personal information following the instructions provided;
3. by ticking the appropriate opt-in boxes when you are accessing some of the more advance functionality of the Site such as Tradeteq Messenger; or
4. by informing us by e-mail, post or phone using the contact details set out in this privacy policy.

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USE OF COOKIES

1. Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.‍

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THIRD PARTY LINKS AND SERVICES

1. It is likely that the Site will contain links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this privacy policy no longer applies.
2. Your browsing and interaction on any other website, or your dealings with any other third-party service provider, is subject to that website’s or third party service provider’s own rules and policies.
3. We do not monitor, control, or endorse the privacy practices of any third parties.
4. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
5. This privacy policy applies solely to personal information collected by us through our Site and Functionality and does not apply to these third party websites and third party service providers.

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TRANSFERS OUTSIDE THE EEA

1. Other than as set out above, we do not transfer your personal information outside of the EEA.

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‍HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

1. We do not keep your personal information for any specific period but we will not keep it for longer than is necessary for our purposes.
2. In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
3. If your information is only useful for a short period e.g. for specific campaigns we will delete it.

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SECURITY OF YOUR PERSONAL INFORMATION

1. We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
2. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
3. unauthorised access;
4. improper use or disclosure;
5. unauthorised modification; and
6. unlawful destruction or accidental loss.
7. All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Site.

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HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?

1. You have the following rights in relation to the personal information we hold about you:
2. Your right of access.
3. If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
4. Your right to rectification.
5. If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
6. Your right to erasure.
7. You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
8. Your right to restrict processing.
9. You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
10. Your right to data portability.
11. With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
12. Your right to object.
13. You can ask us to stop processing your personal information, and we will do so, if we’re:
14. relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
15. processing your personal information for direct marketing; or
16. processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.
17. Your rights in relation to automated decision-making and profiling.
18. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
19. Your right to withdraw consent.
20. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
21. Your right to lodge a complaint with the supervisory authority.
22. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

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CHANGE TO THIS PRIVACY POLICY

1. We may make changes to this privacy policy from time to time.
2. To ensure that you are always aware of how we use your personal information we will update this privacy policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy policy periodically to be informed of how we use your personal information.

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