Privacy Policy

Website Privacy Policy

Website Privacy Policy

Last updated: July 23, 2024

1. General
   1. We at Trade The Pool, a brand of Five Percent Online Ltd., (“We”, “Company”, “Five Percent Online”, “Us” or “Our”), are committed to securing your (“You”, “Your” or “User”) Personal Data (as defined below) and Your privacy. As part of this commitment, it is important for Us to be transparent about how We handle the information that We (or others on Our behalf) collect about Our users, when We collect information about them, and how We use such information.
   2. This privacy policy (the “Policy”) provides information regarding the use of data that We collect about the users of the 
      Tradethepool.com
       website (the “Website“) and the various services offered by the Company over any of its related products and services (collectively, the “Services”). By accessing and using the Website or the Services, You acknowledge that You have read, understood, and agree to be bound by the terms of this Policy.
   3. This Policy is part of and should be read in conjunction with Our Terms of Service available at: https://tradethepool.com/terms-and-conditions/.
   4. In this Policy, any reference to “Personal Data” is to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.
2. When do We collect Personal Data about You?
   1. We may collect Personal Data about You in the following circumstances:
      1. When You access or use the Website.
      2. When Users use the Services.
      3. When You interact with Us in any manner, including by sending Us messages through third party messaging applications or in any other manner; and When You submit Personal Data in the Contact us section.
3. No Obligation to Provide Personal Data to The Company And Its Implications

   You are not obligated to provide Us with any Personal Data about You. However, in some instances, not providing such Personal Data will prevent Us from providing You with the Services You requested Us to provide You and will prevent Your use of the Services or a part thereof.

4. What types of Personal Data do We collect?

   We (or others on Our behalf) may collect the following types of Personal Data about You:

   1. When you Register to the Hub and the Services. Upon creation of an account with Us, You provide Us with certain information that can be used to identify You including Your full name, Email address and country of residence, as well as any other information as the Company may deem necessary to collect at the point of registration. While some of the details mentioned above are required fields in the pages of registration, others are not required, but We recommend that You complete them so that We can provide You with the best services We can.
   2. When You Choose to Join the Evaluation Stage or Become a Funded User. Whenever You use Our services for simulated trading, We collect Your trading program, the amount You have invested, payment method for receiving funds and follow Your trading behavior and monitor it for Our analytical purposes, building trading strategies, evaluation Users as well as to fraud prevention.
   3. KYC AML information
      – We may require You to provide Us or any other third party on Our behalf additional information for the purpose of compliance with Know-Your-Customer (“KYC“) and Anti-Money Laundering applicable legal requirements and best practices.
   4. Communication information. When You contact Us, though any channel whatsoever, including the “Contact us” section, when You subscribe to Our Newsletter on the Website or social media networks, You may provide Us with Your full name, Email address, and the content of Your communication with Us.
   5. Website or Services usage information. This information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, crash reports and type of browser used, and information regarding the device You used. Some of this information may not identify You personally, and therefore does not constitute Personal Data.
   6. Website or Services activity information. Whenever You use the Website, We monitor Your use of the Website and record Your activity. The information that We gather about You in this context includes any activity that You perform in the Website or Services, please be advised that We may receive Your trading data from the Services, the length of time You will be watching content on the Website, Your interaction with content in the Website, etc.
   7. Aggregate Information. We will also create statistical, aggregated and anonymized data relating to Our Users and the Service for analytical purposes, including business development and Services improvements. We will share this aggregate information with Our third-party partners. Aggregated data is derived from personal information and user data but in its aggregated form it does not relate to or identify any client or individual or any specific user’s data. This data is used to understand Our customer base and to develop, improve and market Our Services.
5. The Purposes of The Processing of Personal Data 

   We process Your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

   We will not process Personal Data about You unless there is a legal basis for such processing.

   The legal bases according to which the Company may process Personal Data about You are as follows:

   1. Legitimate Interests. Processing is necessary for the purposes of provision of the Services, or any other legitimate interests pursued by the Company or by a third party. For example, to improve Our Services, We will use the data collected during Your use of the Services to enhance Our Website or Services, or for the exercise or defense of legal claims.
   2. Consent. Your consent that the Company will process Personal Data about You for one or more specific purposes. For example, for the purpose of sending marketing materials to You.
6. How Do We Use Personal Data?
   1. We may use Personal Data about You for the following purposes:
      1. To operate the Website and provide the Services;
      2. to contact You for the purpose of operational purposes.
      3. to personalize content and offers for You;
      4. to respond to Your queries, requests and/or complaints;
      5. to send You materials regarding the Services, events and other information We think will be of interest to You, subject to Your consent;
      6. to analyze and improve the Services, as well as to develop and offer new ones;
      7. to analyze and track usage to determine the usefulness or popularity of certain content and to better understand the online activity of the Website users;
      8. monitor and analyze trends, usage and activities in connection with the Services;
      9. to perform and maintain various activities supporting the offering and provision of the Services, including, but not limited to, the Services (such activities include back-office functions, business development activities, strategic decision making, financing management, third party services integration etc.);
      10. to protect Our and third parties’ interests, rights and assets, including detecting, investigating and preventing fraudulent transactions or unauthorized or illegal activities and initiation or exercise or defense of legal claims and preventing them;
      11. To perform KYC checks; and
      12. to fulfill Our legal or regulatory requirements.
7. Sharing of Personal Data with Third Parties
   1. Monitoring. We employ various monitoring tools and techniques to ensure the security, integrity, and compliance of the Services,
      inter alia, in order to ensure compliance with applicable laws, regulations, and internal policies, including Trading Rules. We may share relevant information with regulatory authorities or law enforcement agencies as required or permitted by law. In particular, the Company is aware of the regulatory requirements in the USA, and it operates in accordance therewith and aims to fully comply with US law and regulatory requirements. We will provide to any official enforcement organization of the US authorities relevant information by official and authorized request to Help@TradeThePool.com .
   2. We will not disclose Personal Data about You to third parties except as detailed in this Policy.
   3. We may transfer Personal Data according to the following:
      1. to entities that control Us, entities that are under Our control and/or to entities under common control or ownership with Us, as shall be from time to time (collectively, the “Group”). Such entities may use the Personal Data to support the needs of the Group;
      2. upon Your consent or instruction;
      3. in the event that We sell, assign or transfer some or all of Our business or assets to a successor or acquirer, or if We are acquired by or merge with a third party, or if We file for bankruptcy or become insolvent, or any other situation where Personal Data may be sold, assigned or transferred to a successor or acquirer;
      4. in the event that We will be subject to an audit or a due diligence process;
      5. to protect Our rights, property and interest or those of third parties;
      6. to fulfill Our legal or regulatory requirements or to comply with a national authority request or a court order; and
   4. We may also share Personal Data about You with third parties that provide Us with the following services:
      1. Storage and hosting providers, including cloud computing services and data security services;
      2. IP address information;
      3. analysis of user experience;
      4. support services;
      5. marketing services;
      6. CRM data management;
      7. KYC services providers;
      8. third -party services and integrations;
      9. accounting and legal services; and
      10. research, analytical, technical, and diagnostic services.
   5. We will share aggregate information with Our third-party partners, in its aggregated form, which does not relate to or identify any particular User.
8. Retention 

   We will retain Personal Data about You only for as long as necessary for the fulfillment of the purposes for which such Personal Data is collected. We may retain Personal Data about You for longer periods if We find it necessary to comply with legal requirements applicable to Us.

9. Cookies and Trackers 
   1. We may use certain third-party services, such as analytics companies or companies delivering advertisements, which may also use cookies or other technologies, and those practices and providers are subject to their own policies.
   2. For more information regarding the use of cookies in our website please see our cookie policy available at: https://tradethepool.com/cookie-policy/ .
10. Security 

    We have implemented suitable security policies, rules and technical measures to protect and safeguard the Personal Data under Our control from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction.

11. Links to Other Websites 
    1. The Website may contain links to third-party websites and applications. Likewise, other websites and applications may also reference or link to Our Website. We do not control these third-party websites and applications, nor the collection and processing of Personal Data by these entities. Therefore, We are not responsible for the privacy practices. This Policy does not apply to any actions taken via such websites and applications.
    2. Whenever You access such third-party websites and applications, We recommend that You carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data.
12. Your Rights in Respect of the Personal Data 
    1. You have the right to request that We provide You with confirmation as to whether Personal Data about You is being collected by Us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict Your consent to certain processing of Your Personal Data.
    2. Where the legal basis for the processing of the Personal Data about You is consent, You may at any time withdraw Your consent for the purposes for which You provided Your consent by sending a notice free of charge to the following email address: Help@TradeThePool.com.
    3. If You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that.
    4. At any time, You may approach Us by sending a notice to the email address Help@TradeThePool.com in order to receive information concerning the review performed by Us. This is so You can conclude that We may process the Personal Data about You on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
    5. We may provide You with offers that are tailored specifically for You, connecting You to brands, products and services in ways that are important to You. This may include ads, offers and other sponsored content related to Our products and services or of third parties. This is done following the processing of Personal Data about You to adjust the materials presented to You, on the basis of Your preferences, behavior, characteristics and interests.
    6. Similar analysis and conclusions are used to the extent that You agreed to receive marketing materials from Us, as such materials are tailored to offer You products and services which We think may be of more interest to You.
    7.  You may withdraw Your consent from receiving marketing materials via email at any time, by sending an email free of charge with the title “unsubscribe” to the following email address: Help@TradeThePool.com or by clicking the unsubscribe option in any marketing material sent to You. You can withdraw Your consent from receiving marketing materials via push notifications in Your mobile device’s settings page.
    8. Please note that if You opt out of receiving marketing communications from Us, We may still communicate with You from time to time if We need to provide You with non-marketing information about Our services or for other legitimate non-marketing reasons.
    9. You are entitled to the following rights in respect of the Personal Data about You. To exercise these rights, You may send a request to Help@TradeThePool.com:
       • We will grant Your right to receive information how Personal Data about You is processed by Us;
         • to rectify any inaccuracy in Your Personal Data;
         •  to erase Your Personal Data processed and stored by Us;
         •  to restrict the processing thereof or object thereto if applicable under the circumstances;
         •  the right to receive the Personal Data about You, which You have provided to the Company, in a structured machine-readable manner; and
         •  the right to withdraw Your consent when such is the legal basis of Our processing.
    10. We may reject Your requests where the request harms the rights and freedoms of others or comply with legal requirements applicable to Us. We may also charge a reasonable fee where applicable.
    11. You will also have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.
    12. Please note that We may need to receive Personal Data from You in order to verify Your identity prior to allowing You to exercise Your rights.
13. Transfer of Personal Data 
    1. Personal Data about You may be transferred to a third country (i.e. jurisdictions other than the one You reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about You and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.
    2. If You are an EEA resident, please note that these safeguards and protection will be available if any of the following are met:
       1. The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”);
       2. The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
       3. The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR.

          You may request that the Company provide You with details concerning the safeguards employed by it to protect the Personal Data about You that are transferred to a third country or an international organization, by sending an email to the following address: Help@TradeThePool.com.

14. Changes to the Policy 
    1. We may amend the terms of this Policy, from time to time. Whenever We amend this Policy, We will notify You of such amendments by publishing the updated Policy on the Website. In addition, when We make significant amendments to this Policy, We will strive to inform You about such amendments via means of communication We believe are reasonably appropriate to inform You of such amendments and by publishing a notice about such amendments on our Website. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on Our website or the designated page on the Website.
15. Contact Us
    1. For any queries relating to this Policy and data protection, please contact Us at Help@TradeThePool.com.