Privacy And Cookies Policy
This document is published to state the Privacy and Cookies Policy (defined as “P&C Policy”) for dt4xtrader.com (defined as the “Website”). All users (defined as “User” or “Users”) of the Website should carefully read this P&C Policy as it relates to their legal rights in respect of personal information and privacy. This P&C Policy forms an integral part of the Terms and Conditions of dt4xtrader.com and constitutes a legally binding agreement between the User and GreatGadgetz Ltd T/A DT4XTrader (defined as “DT4X Trader”) (defined as “DT4X Trader”), the Website owner. By using the Website, the User expressly agrees to be legally bound by this P&C Policy.
This P&C Policy is intended to give Users information on the obligations of DT4X Trader and on the rights of Users in relation to their personal information and privacy as regards:
- the collection of information on Users;
- use of the information collected;
- how information is processed and used;
- with whom the information is shared and on what basis;
- rights of Users in relation to information; and
- how the information collected is stored and secured.
BY USING THE WEBSITE, USERS EXPRESSLY AGREE TO THE P&C POLICY STATED HEREIN BY DT4X TRADER WITHOUT ANY RESERVATION. IF YOU DO NOT ACCEPT ANY PART OF THE P&C POLICY YOU MUST IMMEDIATELY CEASE TO USE THE WEBSITE.
DT4X TRADER RESERVES THE RIGHT TO MAKE CHANGES TO THIS P&C POLICY AT ITS DISCRETION WITHOUT REFERENCE TO USER. IF THE USER IS UNHAPPY WITH ANY FUTURE CHANGES, THE USER MUST IMMEDIATELY CEASE TO USE THE WEBSITE. ANY CONTINUED USAGE FO THE WEBSITE SHALL BE DEEMED ANY ACCETPTANCE ANY SUCH FUTURE CHANGES.
This P&C Policy is directed to all Users equally and the primary privacy requirements that DT4X Trader complies with the Data Protection Act 2018 of the United Kingdom. As DT4X Trader has client’s resident in the European Union (“EU”)/European Economic Area (“EEA”) and in the USA, this P&C Policy complies with GDPR and CCPA requirements in addition to United Kingdom requirements. As a whole. this P&C Policy applies to all Users.
In this P&C Policy, unless there is something in the subject matter or context inconsistent therewith, the following terms and expressions will have the following meanings:
- Definitions And Interpretations
|“AML”||Anti-Money Laundering obligations of DT4X Trader and the Website, including all relevant laws, statutory provisions, regulations, and policies.|
|“CCPA”||California Consumer Privacy Act of 2018|
|“Content”||Without exception, all images, text, information, data, audio, videos, graphics, articles, blogs, computer code, software, algorithms, business models, Withdrawal Growth feature, AutoScaling feature and any other material provided or posted by DT4X Trader on or through the Website, including the Products and Services.|
|“Cookies”||Cookies are tiny files which contain slivers of data and information, which may or may not include, an anonymous unique identifier in relation to whom the cookie is directed. It is a tiny file that a website transfers and stores on your device with the purpose of tracking your movements within the Website, remembering your preferences and your interaction with the various components and features of the Website.|
|“DPA”||Data Protection Act 2018|
|“Financial Instruments”||The financial instruments that Traders are authorised to trade on the Funded Trading Account and the current listing of which can be found at www/dt4xtrader.com/[ ].|
|“Funded Trading Accounts”||The account established by DT4X Trader in its own name and which Traders are authorised to trade on subject to the terms and conditions set out in this Terms and Conditions.|
|“GDPR”||Regulation (EU) 2016/679 General Data Protection Regulation.|
|“Member” or “Trader”||The person or legal entity who completes the registration and payment process and creates a user account on the Website for the purpose of gaining full access to the Website and Products and Services.|
|“Membership”||Membership of DT4X Trader which allows Members full access to the Content and entitles the Member to be an independent funded trader of DT4X Trader. All registrations on the Website are subject to confirmation by DT4X Trader.|
|“Membership Account”||The account created by a User on completion of the registration process on the Website.|
|“Products and Services”||Products and Services made available for subscription, sale or right to use on the Website by DT4X Trader, including but not limited to the Funded Trading Accounts.|
|“User” or “Users” or “You”||Any persons and/or entities that use the Website and shall for all purposes include Members and Traders.|
|“Website”||www.dt4xtrader.com, which is owned, developed and operated by DT4X Trader and includes all the Content and the domain name.|
- Our Basis For Collecting Your Information
DPA and GDPR regulations require that DT4X Trader must have a demonstratable legal basis for the collection and processing of personal information and data on Users.
2.1 User who do not intend to purchase any of the Products and Services offered by DT4X Trader and/or become Members are not required to register an account. Such Users are free to use the public sections of the Website within the terms of the License granted under Clause 13 of the Terms & Conditions of the Website. The only non-User initiated information collected on such Users is on their usage of the Website on a fully anonymous basis.
2.2 The only User initiated information that DT4X Trader collects on unregistered users is when such Users contact DT4X Trader through the Contact Form on the Website. In such cases only the Users’ name (if disclosed) and the e-mail address are collected and such information is only added to our database if the User has elected to receive communications from DT4X Trader, including marketing materials.
2.3 The information on unregistered Users is collected on the basis that it allows DT4X Trader to:
(a) record the number of visitors to the Website and how they interact with the Content and how they move around the Website and how long they spend on each part of the Website and the length of each visit. DT4X Trader also collects data on the User’s IP address, the site from which the User arrived from and the site to which the User departs. This information helps DT4X Trader monitor and improve Website performance and assist in developing strategies to monetise the Website.
(b) analysing the effectiveness and efficiency of DT4X Trader ’s marketing and promotion activities for the Website and its business.
(c) respond to emails from unregistered Users.
2.4 Users who intend to purchase the Products and Services and/or become Members are required to register an account on the Website. DT4X Trader collects the minimum amount of information possible to meets its requirements and to meet legal. accounting and tax obligations. As part of the registration process, DT4X Trader will collect the following information on each registrant:
– Full name
– Mobile Number
– ID Documents for AML policy
2.5 DT4X Trader does not collect any credit/debit card bank account or other financial information. All credit/debit card payments are channeled through Credit Card providers and Paypal a third party payment gateway. Members also have the option of making payments directly into out bank account.
2.6 As part of it AML Policy, DT4X Trader may request for documentary evidence relating to the registrant’s identity and/or address for verification purposes. The verification process may take place during the registration process or at some later times.
2.7 With the exception of the Contact Form and the registration process, DT4X Trader only collects information on an anonymous basis primarily relating to the way in which Users make use of the Website. As such, data is collected on Users primarily for the purpose of analysing the usage of the Website and the effectiveness and efficiency of DT4X Trader ’s activities for the marketing and promotion of the Website and also to identify ways in which the Website and the Products and Services can offer can be improved. Information on the registered Users is collected on the following basis:
- User’s consent to the collection of their personal information through an affirmative action (note that Users are entitled to withdraw their consent at any time by giving DT4X Trader a written notice);
- For the purpose of providing Users with information they have requested and/or purchased from DT4X Trader;
- To fulfil its contractual obligations to the Member once payment for Membership and the registration process has been completed – e.g. sending login information of the Funded Trading Account to the Member;
- It has a legitimate business interest for collection Users’ personal information – e.g improving the performance of the Website; and
- In providing the Products and Services, it is legally required to collect it.
2.8 Except insofar as working with third parties to analyse data and develop marketing and business strategies, DT4X Trader does not share, lease, sell or otherwise deal in Users’ personal data or information and DT4X Trader does not disclose the identity, address or financial details of Users to any third party. All information, if any, that may be shared in the future with third party vendors will be on an anonymous basis or pseudonymized basis.
2.9 DT4X Trader will use its best efforts to preserve and protect the privacy of Users. Its systems are designed to ensure the best possible protection against unauthorised use of the Website and all content and information and data that reside thereon, including that of all Users.
- Information Sources
DT4X Trader is able to collect personal data of Users in various ways, including the following methods:
3.1 Information Provided by Users to DT4X Trader
On the Website, this is only done through the Contact Form and the registration process.
3.2 Information We Collect
This type of information collection falls into the following categories:
(a) Information from browsers, devices and servers;
(b) Cookies and other tracking technologies;
(c) Application logs;
3.3 Information Secured From Third Parties
The only third party sources we use are referrals.
- Types Of Data Collected
Users’ personal information can be collected by us at various stages of their interaction with the Website. For examples cookies can start to track Users as soon as they land on the Website. The cookies will continue to track the User’s usage and how they interact with the Website.
To assist DT4X Trader in providing Users an efficient and high-quality service and user experience and to enable DT4X Trader to better develop its business and the services it offers, DT4X Trader collects the following types of data:
4.1 Personal And Financial Data
Through a combination of the Contact Form and the registration process, DT4X Trader collects only the information stated in Clause 2.2.
In the course of our interaction with customers, potential customers and other third parties, we may gain access to the following information from Users directly or from third party sources, such as credit agencies.
- Personal data for order completion purposes;
- Information required for compliance with Anti Money Laundering and Know Your Customer laws and regulations;
- Data required for product and warranty registration purposes;
4.2 Usage Data
- The User’s Internet Protocol address;
- Browser type and version;
- The page from which Users landed on the Website and the page of the Website on which Users landed;
- The pages of the Website Users visited and the services accessed;
- The times of entry into and exit out of the Website and the duration of the visit;
- The type of device used by Users to access the Website;
- Users’ unique mobile device ID, if any;
- Unique device identifiers and other diagnostic data;
- To ensure continuous availability of the Website, analysis of crash logs allow DT4X Trader to debug in its systems.
4.3 Mailing Lists
To assist us in our marketing and advertising campaigns, DT4X Trader maintains a mailing list. User email addresses are collected when they make use of the Contact Form. We only add email address of Users to our marketing database with their express consent. Users are free to withdraw their consent at any time.
4.4 Tracking And Cookies Data
To track and trace the use of the Website, we utilise cookies and similar tracking and tracing technologies and some of the information collected is stored in cookie files, which reside on their device(s). Cookies are sent by our server based Website software to their browser and the cookies will reside on their device(s) until they expire or are deleted.
There are two categories of cookies, session or persistent. Session cookies are deleted as soon as Users close their browser or turnoff their device. Persistent cookies will remain on their device until such time that they expire or are deleted. The principal types of cookies used by DT4X Trader are:
(i) Essential Cookies
(ii) Acceptance Cookies
(iii) Preference Cookies
(iv) Security Cookies
(v) Performance and Tracking Cookies
(vi) Advertising Cookies
Due to the level of expertise required, Performance and Tracking and Advertising cookies, if any, would be operated on our behalf by third party vendors. We do not use such cookies at this time.
- Use Of Users Personal Data
DT4X Trader uses data collected for various purposes that are justified by a legal basis and these include:
- Maintaining and providing the Website;
- To perform and/or enforce our Agreement with Users;
- Notifying users about changes and improvement(s);
- Enabling users to access interactive features;
- Providing access to customer and technical support;
- Compliance with legal obligations;
- Monitoring usage of the Website to maintain a stable and safe usage environment;
- marketing and promotional purposes;
- For analytical purposes to study and analyse how Users use the Website and to measure and analyse the effectiveness of our marketing and promotion efforts.
- Detecting preventing and solving technical issues; and
- To use as is otherwise required or permitted by law or consistent with the provisions of DPA and GDPR.
For purposes of DPA and GDPR, we may use of personal data for the following processing purposes:
(a) Preparation of Tenders;
(b) Proposals to potential customers relating to the Products and Services;
(c) Acceptance of offers from Customers to purchase the Products;
(d) Processing of orders from customers, including completion of the necessary forms by Customers;
(e) Recording all aspects relating to orders, including financial record keeping; and
(f) To arrange all aspects for the delivery of the Products and Services.
In order to protect our legitimate interests and those of relevant third parties, we may undertake additional processing of personal information for the following purposes:
(i) financial reporting for analysis of financial performance and preparation of forecasts and budgets;
(ii) marketing relating activities for the purpose of identifying potential customers and assessing performance of past marketing activities. This includes post Order fulfilment marketing communications. Users have the option of requiring their information to be removed from such activities;
(iii) to meet any legal obligations imposed by law and/or government regulation, such as any requirement to report purchaser details to relevant government agencies; and
(iv) to ensure internal corporate governance have been complied with.
- Sharing Users Personal Data
DT4X Trader does not sell, trade, lease, rent donate or otherwise deal in the personal data of Users. If required, DT4X Trader may engage third party data processors from time to time to assist in the analysis of data collected and to develop strategies to improve our Website and our marketing efforts. All data provided to third party data processors is on an anonymized basis and the third party vendors are always appointed under a duty of confidentiality.
- Data Retention Period
It is the policy of DT4X Trader to retain Users’ personal information for as short a period as possible. However, we will retain Users’ information on our servers for as long as required by the laws and regulations of the relevant jurisdictions and as is necessary by this P&C Policy and for the continued and efficient operation of the Website and also as required for accounting purposes and the taxation authorities. While Users’ personal information is stored on our servers, we will take all feasible measures to ensure that such personal information is safe, and we will apply a standard that is at least equivalent to that which we employ for the protection of our own confidential data.
- User Choices Regarding Interaction With Us
With certain exceptions, the level of interaction Users have with us is within Users’ control, particularly, but not limited to the following areas:
a) Users may opt out of non-essential communications with us by using the unsubscribe option included in such messages. However, Users will continue to receive essential messages from time to time.
b) Users may disable the acceptance of cookies on their browser at any time. However, Users should be aware that the Website may not function as intended and Users will probably experience a negative experience in using the Website;
c) Users may elect not to complete any non-mandatory information in any forms, surveys etc. on the Website; and
d) Users have the right to ask us to correct their personal information and also the right to remove their personal information (subject to Clause 8).
- Data Transfer
Data servers of DT4X Trader are located in the Netherlands and its operational offices are located in the United Kingdom. The personal and other data of all Users will be located and accessed from these and other locations where DT4X Trader ’s remote employees and contractors may be based. Users may be located in multiple other jurisdictions and the laws and regulations regarding personal and other data may be different in such jurisdictions. By accessing and continuing to use the Website, Users expressly consent to the transfer of Users’ personal and other data and information to the indicated jurisdictions and subjected to the laws and regulations of such jurisdictions.
Countries outside the UK, EEA and USA may not provide sufficient protection of Users’ personal information. To counter this, we will only send Users’ personal information to third parties outside UK, EEA and USA that agree to adhere to the terms of this P&C Policy and the GDPR standards and which are certified accordingly. Users have a right to obtain details of the mechanism under which Users’ personal information may be transferred outside of UK, EEA and USA by contacting email@example.com.
DT4X Trader has put in place measures that are necessary to ensure that the personal and other data of all Users is securely maintained, and no data will be transferred to any third party in any jurisdiction who does not maintain and operate security protocols equivalent to those maintained and operated by DT4X Trader.
- Information Users Share On Third Parties
In certain circumstances the Website may allow Users to submit information on third parties. For example, if Users use the Website to share Users’ personal information with their friends and family, Users will need to enter some personal details about themselves, including but not limited to their email address. In instances where Users provide information on third parties, the information submitted will be retained on our servers only in so far as it relates to Users’ account and such information will not, except as otherwise disclosed herein, be shared or otherwise dealt in.
- Information Received From Third Parties
In some instances, DT4X Trader may receive information about Users from third parties either through the Website or independently. For example, our payment gateways will submit information relating to Users’ transaction to us for the purpose of identifying their transactions and processing them to have their orders processed, prepared and delivered to Users and/or to maintain our accounting records for audit and taxation purposes. DT4X Trader may also in certain instances develop and maintain information about Users independently. All information will be maintained on our servers in the same manner and to the same standard as information provided by Users or gathered directly by us. In terms of sharing such information, we will apply the same rules and standards as any other information we may maintain on Users.
- How We Protect User Information
The security of Users’ data and information is of primary importance to DT4X Trader and we shall take all reasonable measures that comply to industry standards to keep their personal and other data safe and private. However, we cannot give Users a guarantee that Users’ personal and other data will be 100% safe and secure and we make no such guarantee and/or undertaking, express or implied.
The Website and our servers are routinely scanned by high grade anti-virus and malware scanning software. All operating software is kept up to date so that all known vulnerabilities are dealt with at the earliest possible opportunity. Users’ personal information/data is stored behind secure firewalls on secure networks and is accessible only by a limited group of people in a limited set of circumstances. All such personnel are required to sign non-disclosure agreements as part of their engagement terms. All passwords used are highly sophisticated and encrypted.
All sensitive personal and other information Users supply to us is encrypted via Secure Socket Layer (SSL) technology. All financial transactions are processed by independent payment gateways and Users’ financial information is never stored in our databases or on our servers nor do we make a request to Users for such information.
- Private Data Removal
Users have a right to request that their information be removed from the Website, our database and our servers. We will comply with such requests within thirty (30) days of receiving a written request from Users. However, please be aware that we will retain certain information relating to individual transactions Users may have conducted through the Website. We are required to retain such information for accounting, legal and taxation reasons.
- Link To Other Websites
From time to time, we may display advertisements by third parties on the Website. To assist the third parties in assessing the performance of their advertisements, they may set cookies that allow their servers to identify Users and their activity on the Website. These cookies allow the third parties to direct more relevant advertisements to Users taking into consideration their activities on the Website and preferences.
- Privacy Of Children And Minors
Our Service is restricted to persons over the age of 18. DT4X Trader does not knowingly collect data and information relating to persons under the age of 18. Any parent who is aware that their child has provided us with misleading and/or false information in order to access the Website should inform us immediately in writing by way of our contact form on the Website. Once we are aware the information on a person under the age of 18 has been collected without parental consent, we will take all appropriate actions necessary to remove such information from our records and our servers.
- Users’ Specific Data Protection Rights Under GDPR
For the purposes of GDPR, DT4X Trader is defined as a Data Controller of Users’ personal information. All residents of the EEA are bestowed certain rights by GDPR in relation to their personal information/data as regards:
- how it is collected;
- under what circumstances it can be collected;
- how it must be stored;
- how it can be used; and
- with whom and under what circumstances it can be shared.
Our legal basis of our collecting, storing, using and sharing Users’ personal information, is set out in Clause 2.
GDPR confers on EEA resident Users certain conditional rights for the protection of their personal information and/or data:
- to access, update or to delete certain personal information we have on Users;
- to rectify the correctness of any information we have on Users;
- right to object to our holding any information on Users;
- to request us to restrict the information collected on Users and how we make use of it;
- right to data portability for Users’ reuse elsewhere;
- Users have a right not to be the subject of decisions based on automatic procession or profiling; and
- right to withdraw the consent Users have previously given to use and request the erasure of any information we hold.
Before acting to any written request from Users in relation to the above, we may request for verification of their identity.
Please keep in mind that we may be under legal or contractual obligations which are in conflict with Users’ GDPR rights. These conflicts may prevent us from responding to some of User requests. Users are entitled to complain to a Data Protection Authority about our conduct in the collection and use of Users’ personal information. For more information, EU residents should contact their local data protection authority in the EEA
- CCPA Compliance
Since 1st January, 2020, the California Consumer Privacy Act (“CCPA”) afforded specific rights to consumers to ensure that their privacy and their personal data is protected. While DT4X Trader does not fall within the ambit of the CCPA, it will voluntarily comply with its requirements on a purely voluntary basis for the benefit of our Users in the US.
The rights conveyed by CCPA include the right to require businesses to disclose information about the collection and use of their personal information over the past 12 months. You may also ask us to delete any personal information that DT4X Trader will collect from you. In the event that DT4X Trader decides to sell the personal information of Users, something that will never happen, the User have the right to opt out of such sale. In the event that the User exercises any of his/her/its rights conferred by CCPA, DT4X Trader is not allowed to discriminate against the User for exercising his/her/its rights.
For the purposes of CCPA, DT4X Trader would be classified as a ‘Service Provider’.
Should the User wish to delete any of his/her/its information collected by DT4X Trader, the User should send a written request to firstname.lastname@example.org. DT4X Trader will assess the request and comply with it if the request does not wall within our exceptions to meet the User CCPA requests. These exceptions mainly relate to legal and statutory regulations which require DT4X Trader to maintain certain User information. These usually relate to accounting and tax matters.
- Google Analytics
19.2 Users also have the option of using an add-on provided by Google that allows Users to control what information is collected on them. This addon only functions to restrict data sent to Google and does not restrict any data sent to DT4X Trader or any of its third party contractors. Users also have the option of opting out of Google Analytics through this URL – https://tools.google.com/dlpage/gaoptout.
19.3 In relation to any data moved out of the EEA, Google is part of the Privacy Shield programme on a self-certified basis. Further information on how Google uses the personal information of users can be found at https://www.google.com/intl/en/policies/privacy/.
- Changes To P&C Policy
DT4X Trader at all times reserves the right to change any and all aspects of this P&C Policy at any time without giving advance notice of such changes to Users and without giving reasons for such changes. If DT4X Trader does give any explanation for changes in the P&C Policy, it is done so only as a courtesy and not as a requirement. Any changes to the P&C Policy shall become effective immediately the new P&C Policy is posted on the Website and a notice of such changes is posted on the Website. All Users are advised to review our P&C Policy from time to time to keep themselves updated on any changes.
- Data Protection Personnel
If Users have any queries regarding this P&C Policy or their personal data and information, Users may contact our Data Protection personnel via email to email@example.com.
- Contact Us
Any person or legal entity requiring information in respect of our P&C Policy should contact us by way of email firstname.lastname@example.org. Our business address is as follows:
GreatGadgetz Ltd T/A DT4X Trader
272 Bath Street
Scotland, G2 4JR
- Effective Date
This Privacy and Cookies Policy is effective from the 12th of June, 2021 and shall remain in effect until such time it is superseded by an update or terminated by DT4X Trader.