TradeSmartFXTools

Effective Date: 25 March 2026

Version: 1.0

CHAPTER 1 – INTRODUCTION

1.1 Purpose of this Privacy Policy

This Privacy Policy explains how TradeSmartFXTools (“Company”, “we”, “our” or “us”) collects, uses, stores, shares, protects and otherwise processes personal information relating to visitors to our website, prospective customers, customers, account holders and other individuals who interact with our products or services.

This Privacy Policy applies to all products and services offered by the Company, including but not limited to free and paid Expert Advisors (“EAs”), software licences, customer accounts, licence activation systems, dashboards, technical support services, software updates, educational materials, digital downloads, refund administration, marketing activities and all other services provided by the Company.

By accessing our website, downloading free software, purchasing any paid product, creating an account, contacting us or otherwise interacting with the Company, you acknowledge that your personal information may be processed in accordance with this Privacy Policy.

1.2 Who We Are

TradeSmartFXTools is a software development company that develops, licenses and distributes automated trading software, including MetaTrader Expert Advisors, together with related software, dashboards, activation systems, documentation, settings files, educational resources, technical support services and other digital products and services.

For the purposes of applicable data protection laws, including the UK General Data Protection Regulation (“UK GDPR”), TradeSmartFXTools acts as the controller of the personal information described in this Privacy Policy.

1.3 Scope of this Privacy Policy

This Privacy Policy applies to personal information collected through:

• the official TradeSmartFXTools website;
• customer accounts and dashboards;
• software downloads;
• free and paid software licences;
• licence activation and management systems;
• online purchases and payment processes;
• customer support communications;
• refund requests and verification procedures;
• software updates and maintenance services;
• newsletters and email communications;
• promotional campaigns and marketing activities;
• social media pages and advertisements;
• cookies and similar tracking technologies; and
• any other interaction between you and the Company relating to our products or services.

This Privacy Policy does not apply to third-party websites, software, applications or services that are not owned or controlled by the Company, even where those services may be linked from our website.

1.4 Acceptance of this Privacy Policy

By accessing or using our website, downloading free software, purchasing any product or service, creating a customer account or otherwise interacting with the Company, you acknowledge that you have read and understood this Privacy Policy.

Where your consent is required by applicable law for specific processing activities, we shall request your consent before carrying out those activities. Where processing is necessary for the performance of a contract, compliance with a legal obligation, the protection of legitimate interests or any other lawful basis recognised under applicable law, your personal information may be processed without separate consent to the extent permitted by applicable law.

1.5 Changes to this Privacy Policy

The Company may amend or update this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements, business operations, technologies, products or services.

Where we make material changes to this Privacy Policy, we may notify users through our website, customer dashboard, email or other official communication channels where appropriate.

The version published on the official TradeSmartFXTools website shall always be the current and authoritative version.

Your continued use of our website, products or services following the publication of an updated Privacy Policy constitutes your acknowledgement of the revised Privacy Policy to the extent permitted by applicable law.

1.6 Contact Information

If you have any questions regarding this Privacy Policy or our processing of your personal information, you may contact us using the official contact details published on the Contact page of the official TradeSmartFXTools website.

For security and verification purposes, we may request reasonable information to verify your identity before responding to or processing any privacy-related enquiry or request.

CHAPTER 2 – INFORMATION WE COLLECT

2.1 Information You Provide to Us

We may collect personal information that you voluntarily provide when you interact with our website, create an account, download free software, purchase products or services, request technical support, submit refund requests, subscribe to our newsletters or otherwise communicate with us.

Depending upon your interaction with the Company, this information may include:

• Full name;
• Email address;
• Country of residence;
• Billing information;
• Payment confirmation details;
• Customer account information;
• Login credentials;
• MetaTrader account numbers used for software licensing;
• Licence activation information;
• Dashboard account information;
• Technical support enquiries;
• Software configuration details;
• Refund requests and supporting documentation;
• Verification information;
• Communications sent to us by email or other official communication channels; and
• Any other information you voluntarily choose to provide.

The Company does not intentionally collect special category personal data (such as information relating to health, race, religion, political opinions or biometric data) unless required by law or voluntarily provided by you.

2.2 Information Collected Automatically

When you visit our website or use our products or services, certain technical information may be collected automatically through cookies, analytics services and similar technologies.

This information may include:

• IP address;
• Browser type and version;
• Device type;
• Operating system;
• Screen resolution;
• Language preferences;
• Internet service provider;
• Website pages visited;
• Date and time of access;
• Referring website addresses;
• Session duration;
• Click behaviour;
• Navigation patterns;
• Error reports;
• Diagnostic information;
• Approximate geographic location derived from your IP address; and
• Other technical information necessary for website functionality, security and analytics.

This information generally does not directly identify you but may become personal information where required by applicable law.

2.3 Software and Licence Information

Where you use any of our software products, including free or paid Expert Advisors, we may collect information necessary to provide, activate, manage, secure and support your software licence.

This may include:

• Licence identification numbers;
• Activation status;
• Registered MetaTrader account numbers;
• Authorised trading accounts;
• Software version;
• Installation status;
• Activation history;
• Dashboard activity;
• Technical error logs;
• Update history;
• Device identifiers where reasonably necessary for licence administration; and
• Other technical information required to provide our software and related services.

2.4 Payment Information

Payments for our products and services may be processed through independent third-party payment providers.

The Company does not intentionally collect or store complete payment card numbers, CVV security codes or other sensitive payment credentials unless required for lawful business purposes.

We may receive limited transaction information from payment providers, including:

• Payment confirmation;
• Transaction reference numbers;
• Payment status;
• Purchase history;
• Currency;
• Amount paid; and
• Billing information reasonably necessary for accounting, fraud prevention, customer support and legal compliance.

The collection and processing of payment information by third-party payment providers is governed by their respective privacy policies.

2.5 Technical Support and Verification Information

Where you request technical support, software troubleshooting or a refund under the Company’s applicable refund policy, we may request additional information reasonably necessary to investigate and resolve your request.

Depending upon the circumstances, this may include:

• Screenshots;
• Screen recordings;
• Trading logs;
• Expert Advisor logs;
• MetaTrader journal logs;
• Configuration files;
• Account history;
• Software settings;
• Error messages;
• Diagnostic information;
• Communications relating to your request; and
• Other information reasonably necessary to verify eligibility, diagnose technical issues or administer our products and services.

Where reasonably necessary, and only with your prior consent, we may conduct a remote support session solely for the purpose of diagnosing technical issues or verifying information relevant to your request.

2.6 Information from Third Parties

We may receive personal information from trusted third parties where permitted by applicable law.

Such information may include:

• Payment confirmation from payment providers;
• Advertising and marketing information;
• Website analytics data;
• Fraud prevention information;
• Security-related information;
• Customer referrals;
• Social media interactions; and
• Other information lawfully provided by third-party service providers engaged by the Company.

The Company does not knowingly purchase personal information from data brokers for marketing purposes.

CHAPTER 3 – HOW WE USE YOUR PERSONAL INFORMATION

3.1 Purpose of Processing

The Company processes personal information only where it has a lawful basis to do so and only for purposes that are legitimate, necessary and proportionate to the operation of its business.

Depending on your interaction with the Company, your personal information may be used for one or more of the following purposes.

3.2 Providing Products and Services

We use personal information to provide, administer and manage our products and services, including:

• creating and managing customer accounts;
• processing software purchases;
• providing access to free and paid software products;
• activating and managing software licences;
• managing customer dashboards;
• delivering software updates;
• providing digital downloads;
• administering subscriptions where applicable; and
• providing related products and services requested by you.

3.3 Customer Support

We process personal information to provide customer support and technical assistance, including:

• responding to enquiries;
• diagnosing technical issues;
• troubleshooting software problems;
• verifying licence information;
• resolving activation issues;
• providing software updates;
• administering refund requests;
• conducting verification procedures; and
• improving the quality of our customer support services.

Where reasonably necessary, and with your prior consent where required, we may conduct remote support sessions solely for diagnostic or verification purposes.

3.4 Processing Payments

Personal information may be processed to:

• process payments;
• verify completed transactions;
• issue invoices where applicable;
• prevent fraudulent transactions;
• maintain financial records;
• comply with taxation obligations;
• administer refunds; and
• resolve payment-related enquiries.

Payment card information is processed by independent third-party payment providers in accordance with their own privacy policies.

3.5 Improving Our Products and Services

We continually improve our software and services.

Accordingly, personal information may be processed to:

• analyse software performance;
• identify technical issues;
• improve software stability;
• develop new features;
• improve user experience;
• enhance website functionality;
• improve customer support;
• conduct internal testing; and
• maintain the security and reliability of our products and services.

Where reasonably practicable, aggregated or anonymised information may be used for analytical purposes.

3.6 Website Analytics and Performance

We use website analytics and similar technologies to better understand how visitors interact with our website.

This information helps us to:

• measure website traffic;
• analyse visitor behaviour;
• identify technical issues;
• improve website performance;
• optimise page layouts;
• evaluate marketing campaigns;
• improve user experience; and
• maintain website security.

Analytics information may be collected through services such as Google Analytics, Microsoft Clarity and other similar analytics providers.

3.7 Marketing Communications

Where permitted by applicable law, we may use your personal information to send information relating to:

• software updates;
• new product releases;
• educational content;
• promotional offers;
• newsletters;
• product announcements;
• service notifications; and
• other marketing communications that may be relevant to you.

Where required by law, such communications will only be sent with your consent. You may unsubscribe from marketing communications at any time by following the unsubscribe instructions contained within the communication or by contacting the Company.

Service-related communications that are necessary for the administration of your account, software licence or purchases may continue to be sent even if you opt out of marketing communications.

3.8 Security and Fraud Prevention

Personal information may be processed to:

• protect our website and systems;
• prevent unauthorised access;
• detect fraudulent activity;
• investigate suspected abuse;
• enforce our agreements;
• protect intellectual property;
• monitor licence compliance;
• maintain network security; and
• protect the rights, property and legitimate interests of the Company, our customers and other users.

3.9 Legal and Regulatory Compliance

We may process personal information where necessary to:

• comply with applicable laws and regulations;
• respond to lawful requests from public authorities;
• comply with court orders or legal processes;
• establish, exercise or defend legal claims;
• enforce our contractual rights;
• resolve disputes; and
• comply with accounting, taxation and regulatory obligations.

3.10 Lawful Bases for Processing

Where the UK General Data Protection Regulation (“UK GDPR”) or other applicable data protection laws apply, we process personal information on one or more of the following lawful bases:

• performance of a contract;
• compliance with a legal obligation;
• protection of legitimate interests pursued by the Company or a third party, provided such interests do not override your rights and freedoms;
• your consent, where required by law; and
• any other lawful basis recognised under applicable data protection legislation.

Where processing is based upon your consent, you may withdraw that consent at any time. Withdrawal of consent shall not affect the lawfulness of any processing carried out before such withdrawal.

CHAPTER 4 – COOKIES, ANALYTICS AND TRACKING TECHNOLOGIES

4.1 Use of Cookies

The Company uses cookies and similar technologies to improve the functionality, security and performance of its website and services.

Cookies are small text files that are placed on your device when you visit our website. They enable certain website features, remember your preferences and help us better understand how visitors use our website.

Cookies may remain on your device for different periods depending on their purpose and settings.

4.2 Types of Cookies We Use

We may use the following categories of cookies:

(a) Essential Cookies

These cookies are necessary for the operation of our website and cannot generally be disabled.

They may be used to:

• maintain website security;
• enable customer logins;
• remember session information;
• provide shopping cart functionality;
• process purchases; and
• ensure the proper operation of our website and customer dashboard.

(b) Functional Cookies

These cookies improve your browsing experience by remembering preferences such as:

• language preferences;
• login preferences;
• display settings;
• previously entered information; and
• other website customisation settings.

(c) Analytics Cookies

Analytics cookies help us understand how visitors interact with our website.

These cookies may collect information such as:

• pages visited;
• time spent on pages;
• navigation paths;
• referral sources;
• website performance;
• visitor engagement;
• approximate geographic location;
• browser information; and
• device information.

This information helps us improve the functionality, usability and performance of our website and services.

(d) Advertising and Marketing Cookies

Where applicable, advertising cookies may be used to:

• measure the effectiveness of advertising campaigns;
• understand customer interests;
• improve marketing performance;
• limit repetitive advertisements; and
• deliver advertisements that may be more relevant to your interests.

4.3 Google Analytics

The Company uses Google Analytics to collect information regarding the use and performance of our website.

Google Analytics may collect information including:

• pages visited;
• session duration;
• browser information;
• device information;
• approximate geographic location;
• referral sources;
• website interactions; and
• other anonymous or pseudonymous statistical information.

This information is used solely to improve our website, products, services and customer experience.

Google Analytics operates in accordance with Google’s own Privacy Policy and data processing practices.

4.4 Microsoft Clarity

The Company may use Microsoft Clarity to better understand how visitors interact with our website.

Microsoft Clarity may collect information relating to:

• mouse movements;
• scrolling behaviour;
• clicks;
• page navigation;
• device information;
• browser information;
• session recordings; and
• website performance.

This information helps us identify usability issues, improve website performance and enhance the overall user experience.

4.5 Meta Pixel and Advertising Technologies

The Company may use Meta Pixel and similar advertising technologies to measure the effectiveness of advertising campaigns and better understand customer interactions with our website.

These technologies may collect information relating to:

• website visits;
• page views;
• conversions;
• purchases;
• button clicks;
• browsing behaviour; and
• interactions with our advertisements.

This information assists us in improving our marketing campaigns and delivering more relevant advertisements to users who may be interested in our products or services.

4.6 Managing Cookies

Most web browsers allow you to:

• accept cookies;
• reject cookies;
• delete existing cookies;
• restrict certain cookies; or
• receive notifications before cookies are stored.

You can usually manage your cookie preferences through your browser settings.

Please note that disabling certain cookies may affect the functionality, security or performance of our website and certain features may no longer operate correctly.

4.7 Do Not Track Signals

Some web browsers provide a “Do Not Track” (“DNT”) feature.

Because there is currently no universally accepted standard governing DNT signals, the Company does not currently respond to or alter its practices based solely upon such signals unless required by applicable law.

4.8 Future Technologies

The Company may introduce additional cookies, analytics tools or similar technologies from time to time in order to improve the security, functionality, performance and operation of its website and services.

Where required by applicable law, we will provide appropriate notice and obtain consent before deploying non-essential cookies or similar tracking technologies.

CHAPTER 5 – SHARING AND DISCLOSURE OF PERSONAL INFORMATION

5.1 General Principle

The Company does not sell, rent or otherwise trade your personal information to third parties for their own independent marketing purposes.

Personal information is disclosed only where reasonably necessary for the operation of our business, the provision of our products and services, compliance with legal obligations or as otherwise described in this Privacy Policy.

5.2 Service Providers

The Company may share personal information with carefully selected third-party service providers that assist us in operating our business.

These service providers may include:

• payment processing providers;
• website hosting providers;
• cloud storage providers;
• email service providers;
• customer support platforms;
• analytics providers;
• marketing service providers;
• software infrastructure providers;
• security and fraud prevention providers;
• domain and DNS service providers; and
• other technology providers reasonably necessary for the operation of our business.

Such providers are permitted to process personal information only to the extent reasonably necessary to perform services on our behalf and in accordance with applicable contractual and legal obligations.

5.3 Payment Providers

Payments for our products and services are processed through independent third-party payment providers.

Where necessary to process your purchase, we may share limited information required to complete the transaction, including your name, contact details, billing information, transaction amount and other information reasonably necessary for payment processing.

The handling of payment information by payment providers is governed by their respective privacy policies and security practices.

5.4 Analytics and Advertising Providers

The Company may share certain technical and usage information with analytics and advertising providers to help us:

• understand website performance;
• analyse visitor behaviour;
• measure advertising effectiveness;
• improve our products and services;
• detect technical issues; and
• optimise customer experience.

Such providers may include Google Analytics, Microsoft Clarity, Meta Platforms and other similar analytics or advertising providers engaged by the Company from time to time.

Where required by applicable law, such processing shall be subject to your consent.

5.5 Legal Compliance

The Company may disclose personal information where we reasonably believe such disclosure is necessary to:

• comply with applicable laws or regulations;
• comply with court orders or other lawful legal processes;
• respond to requests from competent governmental or regulatory authorities;
• establish, exercise or defend legal claims;
• investigate suspected fraud or unlawful activity;
• enforce our agreements; or
• protect the rights, property, safety or legitimate interests of the Company, our customers or other persons.

5.6 Business Transfers

If the Company undergoes a merger, acquisition, investment, corporate restructuring, sale of assets or other business transaction, personal information may be transferred to the relevant successor entity or prospective purchaser, subject to appropriate confidentiality obligations and applicable legal requirements.

Any successor entity receiving such information shall continue to process personal information in accordance with this Privacy Policy or provide notice of any material changes where required by applicable law.

5.7 Professional Advisers

The Company may disclose personal information where reasonably necessary to its professional advisers, including legal advisers, accountants, auditors, insurers and other professional consultants, provided such persons are subject to appropriate duties of confidentiality or professional obligations.

5.8 International Service Providers

Some of our service providers may process personal information in countries outside your country of residence.

Where personal information is transferred internationally, the Company will take reasonable steps to ensure that appropriate safeguards are implemented where required by applicable data protection laws.

Further information regarding international data transfers is provided in Chapter 6 of this Privacy Policy.

5.9 No Sale of Personal Information

The Company does not sell personal information to third parties.

Any sharing of personal information is carried out solely for legitimate business purposes, contractual performance, legal compliance, fraud prevention, security, analytics, customer support or other purposes described in this Privacy Policy.

5.10 Third-Party Responsibility

While the Company carefully selects reputable service providers, each independent third-party provider remains responsible for its own processing of personal information in accordance with its applicable privacy policy and legal obligations.

The Company is not responsible for the independent privacy practices of third-party websites, platforms or services that are not owned or controlled by the Company.

CHAPTER 6 – INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

6.1 International Nature of Our Business

TradeSmartFXTools operates internationally and provides products and services to customers located in various countries.

As a result, your personal information may be collected, accessed, stored, processed or transferred across international borders where reasonably necessary for the operation of our business and the provision of our products and services.

6.2 International Transfers

Personal information may be transferred to or processed in countries outside your country of residence, including countries where the Company, its service providers or technology providers operate.

Such transfers may occur for purposes including:

• software licence administration;
• customer account management;
• payment processing;
• website hosting;
• cloud storage;
• technical support;
• analytics;
• fraud prevention;
• security monitoring;
• legal compliance; and
• business continuity.

6.3 Appropriate Safeguards

Where personal information is transferred internationally, the Company will take reasonable steps to ensure that appropriate safeguards are implemented where required by applicable data protection laws.

Such safeguards may include:

• contractual data protection obligations;
• appropriate technical and organisational security measures;
• confidentiality obligations imposed upon service providers;
• recognised international data transfer mechanisms where applicable; and
• other safeguards required or permitted under applicable law.

6.4 Service Providers

Some third-party service providers engaged by the Company may store or process personal information in multiple countries.

While the Company seeks to engage reputable service providers that maintain appropriate security standards, the processing of personal information by such providers may occur in jurisdictions that have data protection laws different from those of your country of residence.

6.5 Customer Acknowledgement

By using our website or purchasing, downloading or using any of our products or services, you acknowledge that your personal information may be transferred internationally and processed in accordance with this Privacy Policy where such transfers are reasonably necessary for the operation of our business or the provision of our products and services.

6.6 Protection of Transferred Information

Regardless of where personal information is processed, the Company will implement reasonable administrative, technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss or destruction.

However, no method of electronic transmission, cloud storage or internet communication can be guaranteed to be completely secure, and the Company cannot guarantee absolute security of information transmitted electronically.

6.7 Compliance with Applicable Laws

The Company will take reasonable steps to ensure that international transfers of personal information are carried out in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), where applicable, and any other mandatory legal requirements governing international data transfers.

CHAPTER 7 – DATA SECURITY AND PROTECTION

7.1 Our Commitment to Security

The Company is committed to protecting the confidentiality, integrity and availability of personal information entrusted to us.

We implement reasonable administrative, technical and organisational security measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access or other unlawful processing.

While we continually review and improve our security measures, no system of electronic storage, transmission or processing can be guaranteed to be completely secure.

7.2 Security Measures

Depending upon the nature of the information being processed, the Company may implement security measures including:

• secure website connections using encryption technologies;
• password-protected customer accounts;
• access controls limiting access to authorised personnel;
• authentication procedures for customer verification;
• firewall and network security measures;
• malware detection and prevention systems;
• secure cloud hosting services;
• regular software updates and security maintenance;
• monitoring for suspicious or unauthorised activity; and
• other reasonable technical and organisational safeguards appropriate to the risks involved.

The specific security measures implemented may change from time to time as technologies and security standards evolve.

7.3 Customer Responsibility

Customers also play an important role in protecting their personal information.

You are responsible for maintaining the confidentiality of your account credentials, passwords and login information and for taking reasonable precautions to prevent unauthorised access to your devices and accounts.

You should immediately notify the Company if you become aware of any suspected unauthorised access to your account or any security incident relating to our products or services.

7.4 Data Retention and Access Controls

The Company limits access to personal information to those employees, contractors and authorised service providers who reasonably require such access for the performance of their duties.

Persons authorised to access personal information are required to maintain appropriate confidentiality and comply with applicable security procedures.

7.5 Security Incidents

If the Company becomes aware of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, the Company will take appropriate steps to investigate the incident, mitigate its effects and, where required by applicable law, notify the relevant supervisory authority and affected individuals within the applicable legal timeframes.

Not every security incident or technical event constitutes a reportable personal data breach.

7.6 Third-Party Service Providers

The Company engages reputable third-party service providers that may process personal information on our behalf.

While we seek to engage providers that maintain appropriate security standards, each independent service provider remains responsible for maintaining the security of the systems under its control.

The Company is not responsible for security failures arising solely from the systems, infrastructure or security practices of independent third-party providers beyond the Company’s reasonable control.

7.7 No Absolute Guarantee

Although the Company implements reasonable safeguards designed to protect personal information, no method of transmitting information over the Internet or storing electronic information is completely secure.

Accordingly, the Company cannot guarantee or warrant that personal information will always remain completely secure against every possible security threat, cyberattack, technical failure or other unforeseen event.

Nothing in this Privacy Policy shall be interpreted as guaranteeing absolute security of personal information.

CHAPTER 8 – DATA RETENTION

8.1 Retention of Personal Information

The Company retains personal information only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, comply with applicable legal obligations, resolve disputes, enforce our agreements and operate our business.

The retention period applicable to any particular category of personal information may vary depending upon the nature of the information, the purpose for which it was collected and any applicable legal or regulatory requirements.

8.2 Customer Account Information

Customer account information, including account registration details, licence information and purchase history, may be retained for as long as the customer maintains an account with the Company and for a reasonable period thereafter where necessary for legal, security, fraud prevention, technical support, accounting or business administration purposes.

8.3 Purchase and Payment Records

The Company may retain purchase records, invoices, payment confirmations and related financial information for as long as reasonably necessary to:

• comply with accounting and taxation obligations;
• maintain financial records;
• investigate fraudulent transactions;
• administer refunds;
• resolve disputes;
• enforce contractual rights; and
• comply with applicable legal requirements.

Sensitive payment credentials, such as complete payment card numbers and CVV security codes, are not intentionally stored by the Company.

8.4 Technical Support and Verification Records

Information relating to technical support, software troubleshooting, licence verification, refund requests, support tickets, diagnostic information, screenshots, logs, screen recordings and other verification materials may be retained for as long as reasonably necessary to investigate issues, administer our products and services, resolve disputes, improve customer support and comply with legal obligations.

Where remote support sessions are conducted with your consent, any recordings or related materials will only be retained where reasonably necessary for the purposes for which they were collected.

8.5 Website Analytics

Information collected through cookies, analytics platforms and similar technologies may be retained for varying periods depending upon the settings of the relevant analytics provider and the operational requirements of the Company.

Where reasonably practicable, analytics information may be aggregated or anonymised so that it no longer identifies any individual.

8.6 Marketing Information

Where you have subscribed to receive marketing communications, the Company may retain your contact information until you unsubscribe or otherwise withdraw your consent, unless a longer retention period is required by law or is otherwise necessary to establish, exercise or defend legal claims.

Even where you unsubscribe from marketing communications, the Company may continue to retain limited information necessary to ensure that your marketing preferences are respected.

8.7 Legal and Regulatory Requirements

The Company may retain personal information for longer periods where reasonably necessary to:

• comply with applicable laws or regulations;
• satisfy legal, accounting or taxation obligations;
• establish, exercise or defend legal claims;
• investigate suspected fraud or unlawful activity;
• enforce contractual rights;
• protect the rights, property or safety of the Company, its customers or other persons; or
• comply with lawful requests from competent authorities.

8.8 Secure Deletion

Where personal information is no longer reasonably required for the purposes for which it was collected and there is no legal obligation requiring its continued retention, the Company will take reasonable steps to securely delete, anonymise or otherwise dispose of such information in accordance with its internal data management practices.

Please note that residual copies of information may continue to exist within backup systems for a limited period before being securely overwritten or deleted in the ordinary course of system maintenance.

8.9 Retention Policy Updates

The Company may amend its data retention practices from time to time to reflect changes in applicable laws, business operations, technology or regulatory requirements.

Any such changes shall be implemented in accordance with applicable data protection laws and this Privacy Policy.

CHAPTER 9 – YOUR PRIVACY RIGHTS

9.1 Your Rights

Subject to applicable data protection laws, you may have certain rights regarding the personal information that the Company holds about you.

These rights may vary depending upon your country of residence and the applicable legal requirements.

9.2 Right of Access

You may request confirmation as to whether the Company processes your personal information and, where applicable, request access to the personal information held about you together with certain information regarding how it is processed.

The Company may require reasonable verification of your identity before responding to such a request.

9.3 Right to Rectification

If you believe that any personal information held by the Company is inaccurate, incomplete or out of date, you may request that it be corrected or updated.

The Company may request reasonable evidence to verify the accuracy of the requested correction.

9.4 Right to Erasure

Where permitted by applicable law, you may request the deletion of your personal information.

The Company may decline such requests where continued retention of the information is reasonably necessary to:

• comply with legal obligations;
• maintain accounting or taxation records;
• establish, exercise or defend legal claims;
• investigate fraud or security incidents;
• enforce contractual rights;
• protect the legitimate interests of the Company; or
• comply with other lawful requirements.

Deletion of personal information may affect your ability to continue using certain products or services provided by the Company.

9.5 Right to Restrict Processing

Where permitted by applicable law, you may request that the Company temporarily restrict the processing of your personal information in circumstances recognised by applicable data protection laws.

During any period of restriction, the Company may continue to store the relevant information where permitted by law but may limit further processing until the restriction is lifted.

9.6 Right to Object

Where the Company processes personal information based upon its legitimate interests or for direct marketing purposes, you may have the right to object to such processing in accordance with applicable law.

Where a valid objection is received, the Company will cease the relevant processing unless it has compelling legitimate grounds or another lawful basis permitting continued processing.

9.7 Right to Data Portability

Where applicable data protection laws provide such a right, you may request that certain personal information you have provided to the Company be supplied in a structured, commonly used and machine-readable format, or transferred directly to another organisation where technically feasible.

This right applies only in circumstances recognised under applicable law.

9.8 Right to Withdraw Consent

Where the Company relies upon your consent as the lawful basis for processing your personal information, you may withdraw that consent at any time.

Withdrawal of consent shall not affect the lawfulness of any processing carried out before such withdrawal.

Where consent is withdrawn, certain products, services or website functionality may no longer be available where such processing is necessary for their operation.

9.9 Exercising Your Rights

Requests relating to your privacy rights should be submitted using the Company’s official contact details published on the Contact page of the official TradeSmartFXTools website.

To protect the privacy and security of personal information, the Company may request reasonable information to verify your identity before processing any request.

The Company will respond to verified requests within the time period required by applicable law.

9.10 Complaints

If you believe that the Company has processed your personal information in a manner that does not comply with applicable data protection laws, you may contact the Company using the official contact details published on the Contact page of the official TradeSmartFXTools website so that we may investigate and attempt to resolve your concerns.

If you remain dissatisfied, and where applicable law provides such a right, you may lodge a complaint with the competent data protection supervisory authority in your jurisdiction.

9.11 Limitations

The rights described in this Chapter are subject to applicable laws and may be limited where an exemption or lawful restriction applies.

Nothing in this Privacy Policy shall require the Company to take any action that would be unlawful, technically impossible, disproportionate or that would adversely affect the rights and freedoms of other individuals.

CHAPTER 10 – MARKETING COMMUNICATIONS

10.1 Marketing Communications

The Company may send marketing communications relating to its products, services, software updates, educational content, newsletters, promotional offers, special announcements and other information that may be of interest to you.

Where required by applicable law, such communications will only be sent with your prior consent.

10.2 Methods of Communication

Marketing communications may be sent through one or more of the following channels:

• email;
• customer dashboard notifications;
• website announcements;
• social media platforms;
• messaging platforms where you have voluntarily subscribed or requested communications; and
• other communication methods permitted by applicable law.

10.3 Opting Out

You may opt out of receiving marketing communications at any time by:

• clicking the unsubscribe link contained within a marketing email;
• adjusting your communication preferences where available;
• contacting the Company using the official contact details published on the Contact page of the official TradeSmartFXTools website; or
• following any other unsubscribe instructions provided by the Company.

The Company will process unsubscribe requests within a reasonable period and in accordance with applicable law.

10.4 Service Communications

Even if you choose not to receive marketing communications, the Company may continue to send communications that are necessary for the administration of your account, purchases or use of our products and services.

Such communications may include:

• purchase confirmations;
• payment confirmations;
• licence activation information;
• software update notifications;
• security notices;
• technical support communications;
• refund administration;
• legal notices;
• changes to our agreements or policies; and
• other communications necessary for the operation of your account or our contractual relationship.

These communications are not considered marketing communications and cannot always be opted out of while you continue to use our products or services.

10.5 Third-Party Marketing

The Company does not sell your personal information to third parties for their own direct marketing purposes.

Where third-party service providers assist us in delivering marketing communications, they may process personal information solely on our behalf and only in accordance with applicable contractual obligations and data protection laws.

10.6 Withdrawal of Consent

Where marketing communications are based upon your consent, you may withdraw that consent at any time.

Withdrawal of consent shall not affect the lawfulness of any marketing communications sent before your withdrawal was received and processed.

The withdrawal of consent shall not affect the Company’s ability to send service-related communications that are necessary for the performance of a contract, compliance with legal obligations or the protection of the Company’s legitimate interests where permitted by applicable law.

CHAPTER 11 – CHILDREN’S PRIVACY

11.1 No Services for Children

The Company’s website, software, products and services are intended solely for individuals who are at least eighteen (18) years of age or who have otherwise reached the age of legal majority in their jurisdiction of residence.

The Company does not knowingly market to, solicit information from or provide products or services directly to children.

11.2 No Knowing Collection of Children’s Personal Information

The Company does not knowingly collect, process or store personal information relating to any individual under the age of eighteen (18).

If the Company becomes aware that personal information relating to a child has been collected without appropriate legal authority or parental consent where required by applicable law, the Company will take reasonable steps to delete such information as soon as reasonably practicable, unless retention is required or permitted by applicable law.

11.3 Responsibility of Parents and Guardians

Parents, legal guardians and other responsible adults are encouraged to supervise the online activities of children and to help ensure that children do not submit personal information through the Company’s website or services without appropriate authorisation.

If you believe that a child has provided personal information to the Company without appropriate authorisation, please contact the Company using the official contact details published on the Contact page of the official TradeSmartFXTools website.

11.4 Misrepresentation of Age

The Company reserves the right to suspend or terminate access to its products, services or customer accounts where it reasonably believes that a user has misrepresented their age or is otherwise ineligible to use the Company’s products or services.

Nothing in this Chapter shall affect any rights or obligations that cannot lawfully be excluded or restricted under applicable law.

CHAPTER 12 – CHANGES TO THIS PRIVACY POLICY

12.1 Right to Amend

The Company reserves the right to amend, modify or update this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements, business operations, technologies, products, services, security practices or other legitimate business needs.

12.2 Publication of Updates

The most current version of this Privacy Policy will be published on the official TradeSmartFXTools website and shall supersede all previous versions from its stated Effective Date.

Where required by applicable law, or where the Company considers it appropriate, notice of material changes may also be provided through one or more of the following methods:

• email;
• customer dashboard notifications;
• website announcements;
• other Official Communication Channels; or
• any other reasonable method of communication.

The Company is not obliged to provide individual notice of every amendment unless required by applicable law.

12.3 Customer Responsibility

It is your responsibility to review this Privacy Policy periodically to remain informed about how the Company collects, uses, stores, shares and protects your personal information.

Continued access to or use of the Company’s website, products or services following the publication of an updated Privacy Policy constitutes your acknowledgement of the revised Privacy Policy to the extent permitted by applicable law.

12.4 Previous Versions

The Company may retain previous versions of this Privacy Policy for internal record-keeping, legal, regulatory or compliance purposes.

Only the version of this Privacy Policy published on the official TradeSmartFXTools website and identified by its Effective Date shall govern the Company’s processing of personal information from that Effective Date onward.

12.5 Compliance with Applicable Law

Nothing in this Chapter shall permit the Company to amend this Privacy Policy in a manner that would reduce or remove any rights that cannot lawfully be excluded or restricted under applicable data protection laws.

Where any provision of an updated Privacy Policy is found to be inconsistent with mandatory legal requirements, the applicable law shall prevail to the extent of that inconsistency.

CHAPTER 13 – CONTACT INFORMATION

13.1 Contacting the Company

If you have any questions, concerns or requests relating to this Privacy Policy or the Company’s processing of your personal information, you may contact TradeSmartFXTools using the official contact details published on the Contact page of the official TradeSmartFXTools website.

The Company’s official email address published on the Contact page of the official TradeSmartFXTools website shall constitute the sole official email address for all privacy-related communications under this Privacy Policy.

13.2 Privacy Requests

You may contact the Company to:

• request access to your personal information;
• request correction of inaccurate personal information;
• request deletion of personal information where permitted by applicable law;
• request restriction of processing;
• object to certain processing activities;
• withdraw consent where processing is based upon consent;
• exercise any other applicable privacy rights; or
• submit any enquiry relating to this Privacy Policy.

Requests should include sufficient information to enable the Company to identify the requester and locate the relevant records.

13.3 Identity Verification

To protect the privacy and security of personal information, the Company may request reasonable information or documentation to verify the identity and authority of any individual submitting a privacy-related request before responding to or processing that request.

Where the Company is unable to verify the identity of the requester, it may refuse or delay the request until satisfactory verification has been obtained.

13.4 Response Time

The Company will acknowledge and respond to verified privacy-related requests within the time period required by applicable law.

Where permitted by applicable law, the Company may extend the response period where a request is particularly complex, repetitive or involves a large volume of information. If an extension is required, the Company will notify the requester within the applicable legal timeframe.

13.5 Official Communications

All notices and communications relating to this Privacy Policy shall be made through the Company’s Official Communication Channels.

The Company shall not be responsible for communications sent to unofficial email addresses or other unofficial communication channels unless expressly acknowledged in writing by the Company through its official email address.

13.6 Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws specified in the Company’s applicable Terms and Conditions, except where mandatory data protection laws require otherwise.

Nothing in this Privacy Policy shall exclude, restrict or limit any rights or remedies that cannot lawfully be excluded or restricted under applicable law.

13.7 Entire Privacy Policy

This Privacy Policy constitutes the complete and exclusive statement of the Company’s practices relating to the collection, use, storage, disclosure and protection of personal information in connection with the Company’s website, software, products and services.

If any provision of this Privacy Policy is held to be invalid, unlawful or unenforceable by a court or other competent authority, the remaining provisions shall remain in full force and effect to the fullest extent permitted by applicable law.

This Privacy Policy should be read together with the Company’s Terms and Conditions, Cookie Policy and any other legal policies published on the official TradeSmartFXTools website.