ProTradeLTDs Group Privacy Policy

At ProTradeLTDs, we understand that confidentiality and security of the personal information ("Personal Information") that you share with us is important. The ProTradeLTDs Group affiliates (collectively, "ProTradeLTD"), are committed to protecting the privacy of Personal Information, including Personal Information related to individuals who may be clients, employees, agents, job applicants or others inside or outside of ProTradeLTD. That is why we have developed specific policies and practices designed to protect the privacy of your Personal Information.

By opening an account at ProTradeLTD or by utilizing the products, services and applications available through ProTradeLTD, you have consented to the collection, use and disclosure of your Personal Information in accordance with this privacy policy ("Privacy Policy" or "Policy"). We encourage you to read this Privacy Policy carefully.

This Policy is based on the privacy and data protection principles common to the countries in which we operate. This Policy is intended to summarize ProTradeLTD's data protection practices generally and to advise our clients, prospective clients, job applicants, website visitors and other third parties about ProTradeLTD's privacy policies that may be applicable to them.

This Policy is specifically addressed to those who provide Personal Information to ProTradeLTD or who visit or use ProTradeLTD's websites, trading platforms, software application and social media sites.

Who is responsible for your Personal Information?

ProTradeLTD is responsible for the Personal Information that we may collect in the manner discussed below. ProTradeLTD includes:

  • ProTradeLTDs LLC, One Pickwick Plaza, Greenwich, CT 06830 United States;
  • ProTradeLTDs (U.K.) Limited, 20 Fenchurch Street, Floor 12, London, EC3M 3BY, United Kingdom;
  • ProTradeLTDs Ireland Limited, North Dock One, 91/92 North Wall Quay, Dublin 1 D01 H7V7, Ireland;
  • ProTradeLTDs Hong Kong Limited, Suite 1512, Two Pacific Place, 88 Queensway, Admiralty, Hong Kong SAR;
  • ProTradeLTDs Canada Inc., 1800 McGill College Avenue, Suite 2106, Montreal, Quebec, H3A 3J6, Canada;
  • ProTradeLTD Financial Services AG, Gubelstrasse 28/3rd Floor, Zug, 6300, Switzerland;
  • ProTradeLTDs (U.K.) Limited (DIFC Branch), Unit 507, Level 5, Index Tower, Dubai International Financial Centre, Dubai, United Arab Emirates; and their respective affiliates (the "ProTradeLTD Entities").

Specifically, your Personal Information will be controlled by the ProTradeLTD Entity that is providing services or a communication to you. In some instances your Personal Information will be controlled by more than one ProTradeLTD Entity.

How do we collect your Personal Information and what Personal Information do we collect?

ProTradeLTD collects Personal Information from you. This may include, among other things, information:

  • Provided during the ProTradeLTD account application process or during use of any of ProTradeLTD's website applications (for example, your name, email address, telephone number, birth date, tax ID number, investment objectives, biometric information, etc.);
  • Provided when you apply for an employment opportunity with us (for example, your name, contact information and any additional information provided by you in your resume);
  • Acquired as a result of the transactions you conduct through the ProTradeLTD systems ("Transaction Data") or in connection with services offered by ProTradeLTD (for example, if you participate in ProTradeLTD's debit card program);
  • Received from consumer-reporting agencies;
  • Collected through Internet cookies (for further information on our use of cookies, please see our Cookie Policy);
  • Collected from you when you use iBot, ProTradeLTD's natural language interface.

For what purposes will we use your Personal Information?

We may use your Personal Information for the following purposes ("Permitted Purposes"):

  • To provide services to you in accordance with any agreement(s) you or your organization may have with us, for our own administrative, record-keeping and compliance procedures;
  • To provide you or your organization with brokerage and other services available on our platforms, and/or to deal with any requests or inquiries you may have;
  • To pursue legitimate interests, including to carry out, monitor and analyze our business or operations including the activities set out in this Privacy Policy;
  • To enforce or apply any agreement and/or to protect our (or others') property or rights and to defend any potential claim;
  • To conduct our recruiting processes (applies only to information submitted for employment applications);
  • To respond to requests for information from you and to follow up with you afterwards to see if we can provide any further assistance;
  • To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;
  • To enter into or carry out contracts of various kinds;
  • To conduct monitoring by us or any other person on our behalf using various methods, including: (i) the use of "intelligent" automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation; or (iv) monitoring of business premises for security purposes, for example, using CCTV; or (v) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or (vi) using other similar monitoring technology that may become available from time to time;
  • For statistical purposes and for market research and product analysis and to develop and improve our products and services;
  • For the purposes of preventing and detecting money-laundering, terrorism, fraud or other crimes and/or abuses of our services;
  • To comply with any legal, regulatory or good practice requirement whether originating from Ireland or elsewhere (including but not limited to, the United States), and to fulfill our obligations under any reporting agreement entered into with any tax authority or revenue service(s) from time to time;
  • To comply with applicable laws in any country.

We may also process your Personal Information for the following purposes (after obtaining your express consent where such consent is legally required) in accordance with your preferences:

  • To communicate with you through the channels you have approved to keep you up to date on the latest developments, announcements and other information about ProTradeLTD services, products and technologies;
  • To conduct client surveys, marketing campaigns, market analysis, or promotional activities;
  • To collect information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

Where legally required, with regard to marketing-related communication, we will only provide you with such information after you have opted in or had an opportunity to object and we will also provide you with the opportunity to opt out at any time if you do not wish to receive further marketing-related communication from us.

Who we share your Personal Information with, and in what circumstances

We share your Personal Information in the following circumstances:

  • We may share your Personal Information between the ProTradeLTD Entities on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, billing and other business purposes. A list of the countries in which ProTradeLTD Entities are located can be found on our website;
  • We instruct service providers within and outside of ProTradeLTD (including cloud service providers such as AWS), domestically or abroad, to process Personal Information for the Permitted Purposes on our behalf and in accordance with our instructions and based on our legitimate interest to provide, maintain and improve our products and services;
  • We may share your Personal Information with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies;
  • We may disclose information about you to any depository, stock exchange, clearing or settlement system, account controller or other participant in the relevant system, to counterparties, dealers, custodians, intermediaries and others where disclosure is reasonably intended for the purpose of effecting, managing or reporting transactions in connection with the provision of our services or establishing a relationship with a view to such transactions;
  • We may share data provided to us for employment applications with third parties to assist us with the conduct of our recruitment processes;
  • Consistent with applicable law, we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defense of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;
  • We may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

Keeping Personal Information about you secure

To the extent required by law, we will take appropriate technical and organizational measures to keep your Personal Information confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Information. Personal Information may be kept on our Information Technology systems, those of our contractors or in paper files.

Transferring your Personal Information outside the European Economic Area ("EEA") or the United Kingdom (if GDPR or UK GDPR applies), outside of the Dubai International Financial Centre ("DIFC") (if the DIFC DPL applies) or outside of Quebec (if the Quebec Private Sector Act applies)

For Personal Information subject to the General Data Protection Regulation (EU) 2016/679 ("GDPR") or the UK General Data Protection Regulation ("UK GDPR"), we may transfer your Personal Information outside the EEA or the United Kingdom (the "UK") for the Permitted Purposes as described above. This may include countries that do not provide the same level of protection as the laws of your home country (for example, the laws within the EEA, the UK or the United States). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards if required by the GDPR, UK GDPR or other relevant laws.

If you have any questions about this section and/or appropriate data transfer mechanism used by ProTradeLTD, please contact the Data Protection Officer at [email protected].

Updating your Personal Information

If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know by contacting ProTradeLTD Client Service through the ProTradeLTD website at protradeltd.com/help. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

How long do we retain your Personal Information?

We retain your Personal Information in an identifiable form in accordance with our internal policies which establish general standards and procedures regarding the retention, handling and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations and proceedings.

Further rights for persons or information covered by GDPR, UK GDPR, PIPL, DIFC DPL, and the Quebec Private Sector Act

With respect to residents of the EEA, the UK, the People's Republic of China ("PRC"), DIFC, and Quebec, as well as in situations where your Personal Information is processed by an ProTradeLTD Entity established in the EEA, the UK, DIFC, Quebec or any other applicable jurisdictions ("Covered Individuals"), you have a number of legal rights under GDPR, UK GDPR, PIPL, DIFC DPL, and/or the Quebec Private Sector Act in relation to the Personal Information that we hold about you. These rights include:

  • Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you;
  • Requesting that we correct your personal information if it is inaccurate or incomplete;
  • Requesting that we erase your personal information in certain circumstances;
  • Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances;
  • Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so;
  • Obtaining computerized personal information collected from you in a structured, commonly used and technological format (right to data portability).

We have designated a Data Protection Officer ("DPO") to enhance and promote compliance with and understanding of privacy and data protection principles. If you wish to exercise any of the above rights, please send an email to [email protected].

Notice to California Residents

As a federally-regulated provider of financial services, ProTradeLTD is broadly exempt from the California Consumer Privacy Act ("CCPA"). Personal information we collect from clients and prospective clients is protected under separate federal legislation. Over the past 12 months, the only type of information we have collected potentially subject to the CCPA is web-browsing information regarding passive visitors to our website who are California residents, but are not our clients and do not provide us with any specific personal information (name, email address, street address, social security number, etc.) to request information about our services, start an account application or become a client. Information collected from these anonymous, passive visitors to our website may include IP address and browser-specific tags. We do not sell this information to third parties. We only use this information for internal purposes, such as to determine which advertisements are working and which content on our website is most interesting to visitors.

Updates to this Privacy Policy

This Privacy Policy was last updated on the date indicated at the top of this Policy. We reserve the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.

How to contact us

We welcome your views about our website and our Privacy Policy. If you have any questions about this Policy, please contact the Data Protection Officer at [email protected] or please contact ProTradeLTD Client Services through the ProTradeLTD website at protradeltd.com/help.