PRIVACY POLICY

1. INFORMATION WE COLLECT

Personal information you provide

Note: We collect personal information that you choose to provide to us.

We collect personal information that you voluntarily provide when you register for an account, complete onboarding steps, request information about Tradence or our products and Services, subscribe to updates, participate in features or activities offered through the Services, submit forms, respond to surveys, take part in promotions (where offered), or otherwise contact or communicate with us. The categories of personal information we collect may vary depending on how you interact with the Services and may include, for example, your name, username, email address, phone number, date of birth, address, nationality, account preferences, and any other information you choose to provide through the Services or in your communications with us.

If you use features that involve transactions, deposits, withdrawals, or payments, we may receive limited transaction-related details from our payment processors (for example, confirmation of payment status, partial card details such as last four digits, billing country, and transaction reference identifiers). TRADENCE does not directly store full credit card or payment card numbers. Payment transactions are processed by third-party payment providers in accordance with their own privacy and security standards, and your use of those services may be governed by their terms and privacy notices.

Sensitive information. Where required, permitted, or appropriate under applicable law, we may process certain sensitive information for purposes such as identity verification, fraud prevention, account security, and compliance. This may include government-issued identification information and, where available, enabled, and permitted by applicable law, biometric identifiers or biometric templates (for example, for liveness checks or identity matching). We only process sensitive information when we have a lawful basis to do so and when appropriate safeguards are in place.

All personal information that you provide to us must be true, complete, and accurate. You agree to keep your information current and to notify us promptly if any of your personal information changes.

Information collected automatically

Note: Some information — such as your Internet Protocol (IP) address and device/browser characteristics — is collected automatically when you visit or use our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information may not identify you by name, but it may include device and usage information such as your IP address, approximate location (for example, country or region), browser type and settings, device type and identifiers, operating system, language preferences, access times, pages viewed, clicks, and referring and exit pages. We may also collect information about how you interact with the Services, including the features you use, the actions you take, and performance and diagnostic information (such as crash logs, latency, and error reports).

We use this information primarily to maintain the security and operation of the Services, to help detect and prevent fraud or unauthorized activity, to debug and improve functionality, and for internal analytics and reporting. In some cases, this information may be used to personalize your experience, enforce our Terms, and comply with applicable legal obligations.

Like many online services, we also collect information through cookies and similar technologies. For more information about how we use cookies and related tools (including analytics and preference technologies), please see the section titled "COOKIES AND SIMILAR TECHNOLOGIES" below.

2. HOW WE USE YOUR INFORMATION

Note: We process your information to operate, deliver, improve, and administer our Services, to communicate with you, to help maintain safety and prevent fraud, and to meet legal and regulatory obligations. Where required by applicable law, we also process information based on your consent or at your direction.

We process personal information for purposes that depend on how you interact with the Services, the features you use, the choices you make, and any applicable terms you accept under our Terms and Conditions. We also process information as required, permitted, or restricted by applicable law. The purposes below are provided to explain how we use information in practice:

• Providing our Sites, Services, and features. We may use information to provide, personalize, maintain, and improve the Services, including as described in our Terms and Conditions. This may include using information to:
  • operate, maintain, customize, measure, and improve our Sites and Services and manage our business operations;
  • create, authenticate, and update user accounts and profiles;
  • process transactions and related requests, including payments (through third-party providers where applicable);
  • send service-related communications, such as confirmations, notices, receipts, invoices, technical notices, updates, security alerts, and administrative messages; and
  • create aggregated or de-identified information where permitted by applicable law and used in a way that is not intended to identify you.
• Safety, security, and platform integrity. We may use information to help maintain the safety, security, and integrity of our Sites and Services, including to:
  • detect, prevent, investigate, respond to, and deter fraudulent, unauthorized, suspicious, or illegal activity;
  • verify identity (where applicable), validate access, and support authentication and account security measures;
  • protect against spam, malware, abuse, and other security risks;
  • perform internal operations necessary to provide the Services, including troubleshooting bugs, resolving operational issues, and maintaining service performance; and
  • enforce our agreements, including these Terms and Conditions, and comply with applicable laws and regulations.
• Customer support and communications. We may use information to provide customer support, including to:
  • route requests to the appropriate support team or specialist;
  • communicate with you about your account, inquiries, or requests (including, where you choose, through social media or other channels you use to contact us);
  • investigate and address user concerns, disputes, or suspected issues; and
  • monitor, evaluate, and improve the quality and effectiveness of our support responses and processes.
• Research, testing, and development. We may use information for testing, research, analytics, and product development to improve the Services, enhance performance, strengthen safety and security controls, improve our ability to prevent misuse or illegal activity, develop new features and products, and support payment and operational solutions connected with the Services.
• Legal and regulatory compliance. Certain laws and regulations may require us to collect, use, verify, and retain personal information in specific ways. For example, we may need to identify and verify users, screen for fraud or prohibited activity, and keep records for compliance and risk management purposes. This may include collecting and storing identity information such as name, date of birth, address details, and photo identification where required or permitted by applicable law. We may use service providers to help verify information you provide by comparing it against reputable sources and databases (which may include public records where legally available). If you attempt to link a bank account or use certain features, we may request additional information needed to verify identity, confirm address details, manage risk, or comply with legal requirements. IF YOU DO NOT PROVIDE INFORMATION THAT IS REQUIRED UNDER APPLICABLE LAW OR REASONABLY REQUESTED FOR COMPLIANCE PURPOSES, WE MAY BE UNABLE TO PROVIDE CERTAIN SERVICES AND MAY NEED TO RESTRICT OR CLOSE YOUR ACCOUNT. We may also use information to respond to lawful requests, regulatory inquiries, official investigations, and to address claims or disputes relating to the Services, as permitted by applicable law.
• Direct marketing and updates. Where permitted by applicable law and consistent with your preferences, we may use information to send you communications about the Services, including newsletters, product updates, new features, promotions, surveys, announcements, and events through email, in-app notifications, or other channels. We may also use information to manage your participation in promotions and events and to tailor communications based on your settings and preferences. You may be able to opt out of certain promotional communications as described in this Privacy Policy and in the messages you receive.

3. WHEN WE SHARE PERSONAL INFORMATION

We may share, disclose, or otherwise make available information we collect (including personal information) in the situations described below. When we share personal information, we do so for the purposes outlined in this Privacy Policy, and where appropriate, we take steps designed to require recipients to handle the information in a manner consistent with this Policy.

• With your consent or at your direction. We may share personal information when you ask us to do so, authorize a disclosure, or otherwise choose to share information through the Services. Where required by applicable law, we will obtain your consent before sharing information for a specific purpose.
• Affiliates and related entities. We may share information with our affiliates and related companies for operational purposes (such as account administration, security, internal reporting, and providing the Services). Where we do so, we require affiliates to follow privacy protections consistent with this Privacy Policy.
• Service providers. We may share information with third-party vendors that perform services on our behalf, such as hosting and infrastructure, customer support tools, analytics, security monitoring, communication providers, marketing support, and information technology services. Our agreements are intended to require service providers to process personal information only on our instructions and to use appropriate safeguards.
• Payment processing and financial partners. Where you choose to make deposits, withdrawals, purchases, or other transactions through the Services, we may share relevant information with payment processors and financial service providers to process transactions, reduce fraud, and manage risk. Tradence does not store full payment card numbers, and payment processing is handled by third parties under their own terms and privacy practices.
  • For example, a third-party provider may help connect your Tradence account to a bank account, confirm account ownership, or validate transaction details. Information shared with such providers will be handled according to their applicable privacy notices and agreements with you and/or with us.
• Identity verification, compliance, and risk screening. We may share personal information with third-party identity verification, screening, and fraud-prevention providers to verify identity, detect and prevent fraud, enforce our policies, and manage compliance and risk. These providers may compare information you provide against trusted databases or authoritative sources and may generate verification results or risk signals that help us decide whether and how we can provide the Services.
  • For example, where supported and permitted by law, an identity verification provider may verify that a selfie you submit matches the photo on your government-issued identification. Depending on the method used, this process may involve biometric identifiers or templates. Where required, we will provide additional notices and obtain any necessary permissions.
• Legal and regulatory disclosures. We may share information with courts, law enforcement, regulators, supervisory authorities, government agencies, legal counsel, or other parties where we believe disclosure is necessary or appropriate to: (A) comply with applicable law or a lawful request; (B) respond to legal process such as subpoenas, court orders, or warrants; (C) investigate, prevent, or address fraud, security issues, prohibited activity, or violations of our Terms or policies; (D) establish, exercise, or defend legal claims; (E) protect the rights, property, and safety of Tradence, our users, or others, including to help prevent imminent harm or material financial loss; and (F) cooperate with competent authorities as required or permitted by applicable law.
• Business partners and integrations you choose. We may share information with business partners or integration providers where this is necessary to deliver a feature you request, support a joint offering, or provide promotions or services you opt into. Where required, we will seek your consent.
• Other users (where you enable user-to-user features). If you use features that involve interacting with other Tradence users (such as peer-to-peer features or sending/receiving transfers where supported), we may display or share certain information so the feature can work as intended. The information shown depends on the feature and your settings and may include your display name/username, limited profile details, and transaction information needed to complete the interaction.
• Professional advisors. We may share information with our professional advisors (such as lawyers, accountants, auditors, insurers, and banking partners) and specialist providers (including security or blockchain analytics providers where relevant) for purposes such as obtaining advice, completing audits, managing risk, resolving disputes, and meeting legal obligations.
• Business changes. We may share or transfer information in connection with a corporate transaction or proposed transaction, such as a merger, acquisition, reorganization, financing, or sale of assets. If such an event occurs, we will take steps designed to ensure personal information remains subject to appropriate protections.
• Aggregated or de-identified information. We may create and share aggregated or de-identified information that is not intended to identify you (for example, statistics about usage or performance). We may share such information for analytics, research, and business intelligence.
• Advertising and marketing partners (where applicable). Where permitted by applicable law and consistent with your preferences, we may share limited information with marketing or advertising partners to help deliver and measure campaigns. Tradence does not sell personal information for money; however, some privacy laws may treat certain disclosures for advertising as a “sale” or “sharing.” Where required, we provide choices and controls as described in this Privacy Policy.

4. COOKIES AND SIMILAR TECHNOLOGIES

Note: We (and certain service providers we use) may use cookies and similar technologies to collect and store information when you interact with the Services.

We use cookies and related technologies (such as pixels, tags, and web beacons) to help the Services function properly, remember your preferences, keep accounts and sessions secure, understand how the Services are used, and improve performance. Some of these technologies are essential for security and basic operation, while others help us measure and enhance user experience.

Cookies: Cookies are small text files or identifiers placed on your device by your browser when you visit a website. Certain cookies help you navigate the Services, remember settings, and maintain your session, while others help us understand usage patterns and improve features. Cookies generally fall into two categories: session cookies and persistent cookies.

• Session Cookies: These are temporary cookies that exist only while your browser session is active. They typically expire when you close your browser. We use session cookies to recognize you during a session, enable login functionality, support security checks, and help process requests as you move through the Services.
• Persistent Cookies: These remain on your device after you close your browser (for a period defined by the cookie) or until you delete them. We use persistent cookies to remember preferences and to collect aggregate and statistical information about how users interact with the Services over time.

Managing Cookies: Most browsers accept cookies by default, but you can usually change your settings to remove or reject cookies. If you disable cookies, parts of the Services may not function correctly, and certain features (such as keeping you signed in or saving preferences) may be limited. Your browser’s help menu typically explains how to manage or delete cookies.

Do Not Track: Some browsers include a “Do Not Track” (DNT) setting. Because there is no consistent industry standard for interpreting DNT signals, our Services may not respond to DNT signals in a uniform way. We address related choices and controls in the sections of this Policy that discuss cookies and tracking controls.

Analytics and measurement: We may use analytics tools and providers (such as Google Analytics and similar services) to help us understand how the Services are used, diagnose technical issues, and improve performance and user experience. These providers may use cookies or similar technologies to collect information about your use of the Services. We do not provide these providers with your payment card details, and we do not share Personal Information with analytics providers for their independent marketing purposes.

5. SOCIAL LOGIN INFORMATION

If you choose to create an account or sign in to the Services using a third-party social login (for example, Google, Facebook, or X), we may receive certain information about you from that provider.

When you use a social login, the third-party provider may share profile details associated with your account. The information we receive depends on the provider, your account settings, and the permissions you grant at the time of connection. It may include details such as your name, username, email address, profile photo, and any other information the provider makes available to us.

We use social login information only to (i) create or authenticate your account, (ii) provide the requested functionality, and (iii) operate, secure, and improve the Services as described in this Privacy Policy. We do not control how third-party providers use your information, and their processing is governed by their own terms and privacy policies.

We recommend that you review the privacy settings and notices of the relevant third-party provider to understand what information may be shared and how you can manage or revoke permissions. In many cases, you can disconnect a social login through your Tradence account settings (where available) or through the third-party provider’s settings.

6. INTERNATIONAL DATA TRANSFERS

We may transfer, store, and process your information in countries other than the country where you live.

The Services may be supported by infrastructure and service providers operating in multiple locations. As a result, your information may be transferred to, stored in, or accessed from jurisdictions where we or our service providers maintain facilities, including for purposes described in this Privacy Policy (such as delivering the Services, security, customer support, analytics, and legal compliance).

If you access the Services from a location with data protection laws that differ from those of the countries where your information is processed, please note that your information may be handled under those other laws. We take steps designed to protect your information consistent with this Privacy Policy and applicable legal requirements, including implementing safeguards where required for cross-border transfers.

Where applicable, we may rely on appropriate transfer mechanisms and safeguards recognized under relevant data protection frameworks (such as contractual protections or other approved measures). If you would like more information about the safeguards we use for international transfers, you can contact us using the details in the CONTACT US section.

7. HOW WE PROTECT INFORMATION

We use administrative, technical, and physical safeguards designed to help protect personal information from unauthorized access, loss, misuse, alteration, or disclosure. The measures we use may include:

• Encryption of data in transit and, where appropriate, at rest
• Access controls, authentication measures, and least-privilege practices
• Security monitoring, vulnerability management, and periodic reviews
• Internal policies and staff training relating to data protection
• Incident response and escalation procedures

Even with these safeguards, no internet-based service can be guaranteed to be completely secure. Cyber threats evolve, and unauthorized third parties may attempt to bypass security controls. As a result, while we take reasonable steps to protect your information, we cannot guarantee absolute security.

You also play an important role in keeping your account secure. When registering, choose a strong password and enable available security tools (such as two-factor authentication). Do not share your login credentials with anyone. If you believe your account has been accessed without authorization, please submit a support ticket via the Tradence Support Center.

YOU ARE RESPONSIBLE FOR ALL ACTIVITY ON THE ACCOUNT ASSOCIATED WITH YOUR LOGIN CREDENTIALS.

8. HOW LONG WE KEEP INFORMATION

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to operate the Services, meet contractual commitments, support security and fraud prevention, and to comply with legal and regulatory requirements. Where applicable, this may include keeping certain records for a minimum period (for example, up to five (5) years) to satisfy obligations under anti-money laundering, counter-terrorism financing, and other applicable laws and regulations.

When deciding how long to retain information, we may consider factors such as: the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it; and whether we can achieve those purposes through other means. We may also retain information for longer where required or permitted by law (including legal, regulatory, tax, accounting, or reporting requirements) or where needed to establish, exercise, or defend legal claims, resolve disputes, or enforce our agreements and policies.

If we no longer have an ongoing legitimate need to process your personal information, we will take steps to delete it or de-identify it. If deletion is not immediately possible (for example, because the information is stored in backups), we will securely store it and restrict further processing until deletion is feasible.

Where biometric information is collected for identity verification (if applicable and permitted by law), we retain it only for as long as necessary for the purposes described above and for any period required by applicable laws and regulations. Additional details may be provided in any separate biometric notice or policy we make available.

9. MINORS PRIVACY

Note: We do not knowingly collect or solicit personal information from, or direct marketing to, anyone under 18.

The Services are intended for individuals who are 18 years of age or older. By using the Services, you confirm that you are at least 18 and that you are permitted to use the Services under the laws that apply to you. We do not knowingly permit minors to create accounts or use the Services.

If we become aware that we have collected personal information from someone under 18, we will take reasonable steps to disable the relevant account (if applicable) and delete the information from our active systems, unless we are required to keep it to comply with legal obligations.

If you believe a minor may have provided us personal information, please contact us at privacy@tradence.com.

10. YOUR PRIVACY RIGHTS

Tradence aims to provide meaningful privacy choices to all individuals, even where a specific statutory right may not apply. Depending on your location and applicable law, you may have additional rights beyond those described below.

• Right to Know. You may request information about the categories of personal information we collect about you, how we use it, and the categories of parties with whom we may disclose it, as applicable.
• Right to Access/Portability. You may request access to, and/or a copy of, certain personal information we maintain about you, in a portable format where feasible.
• Right to Delete. You may request deletion of certain personal information we have collected or maintain about you, subject to exceptions. Please note that we may need to retain certain information to comply with legal and regulatory obligations (including recordkeeping requirements under anti-money laundering, counter-terrorism financing, fraud prevention, tax, accounting, or other applicable laws).
• Right to Correct. You may request that we correct inaccurate personal information we maintain about you.
  • To request updates or corrections, please contact Customer Support at Tradence Support Center. You may also be able to update certain account profile information by logging into your account.
• Right to Opt Out. You may opt out of certain uses of your personal information, including:
  • Marketing and Promotional Communications. You can stop receiving marketing emails by following the unsubscribe instructions included in those messages, or by contacting us at privacy@tradence.com. Please note that you may still receive service-related or transactional messages (including legal notices) that are necessary to provide the Services.
  • Targeted Advertising. You may be able to limit certain targeted advertising through controls described in the COOKIES AND SIMILAR TECHNOLOGIES and (see the DO-NOT-TRACK CONTROLS section below).

How to exercise your rights. You can submit a request by contacting us at privacy@tradence.com. To protect your privacy and security, we may request additional information to verify your identity before processing your request. If we cannot reasonably verify your identity, we may be unable to fulfill your request.

We may lawfully decline a request, or charge a reasonable administrative fee, where permitted by applicable law (for example, if a request is manifestly unfounded, excessive, or repetitive).

11. ADDITIONAL NOTICES

If you act as an authorized individual on behalf of another user and provide that user’s personal information to us, you are responsible for ensuring you have all necessary permissions and consents to do so. You also confirm that providing (and our use of) that information in connection with the Services does not violate any applicable law, rule, regulation, or order.

Please be aware that the information you submit may be screened against internal risk indicators and external data sources where appropriate to help comply with applicable anti-money laundering and counter-terrorism financing requirements, and our internal “Know Your Client” policies.

• Information. For information about the categories of personal information we have collected (including sources), please review the INFORMATION WE COLLECT section above. We collect and use information for the purposes described in HOW WE USE YOUR INFORMATION above, and we may disclose it to the types of third parties described in WHEN WE SHARE PERSONAL INFORMATION above.
• Opt out of “sale” or “share” (where defined by law). Tradence Technologies Ltd does not sell personal information for money. However, certain third-party cookies and similar technologies used for advertising or analytics may be considered a “sale” or “share” under some privacy laws. Advertising partners are contractually restricted from using personal information collected through our Services for their own independent marketing purposes. You can manage or opt out of these technologies as described in the COOKIES AND SIMILAR TECHNOLOGIES and DO NOT TRACK CONTROLS section below.
• Limit the use and disclosure of sensitive personal information. We only collect and use sensitive personal information where necessary to provide the Services, meet security and fraud-prevention requirements, and comply with legal and regulatory obligations. If you limit our use of certain sensitive personal information, some Services (including account access, verification, and transaction-related features) may not be available to you.

In addition to the mechanisms described above, you can submit privacy requests by emailing us at privacy@tradence.com, or by contacting customer support via live chat.

Some individuals may have the right to appoint an “authorized agent” to submit requests on their behalf. If an authorized agent submits a request, we may require proof of authorization (for example, a signed written permission) and may also request that you verify your identity directly with us.

Appeals

If we decline a privacy request, you may appeal our decision by emailing us at privacy@tradence.com. If you remain dissatisfied with the outcome, you may have the right to submit a complaint to the relevant data protection authority in your jurisdiction.

Controller/Business Designation

Tradence Technologies Ltd generally acts as a data controller (or similar role under applicable law) for personal information processed through the Services, meaning we determine the purposes and means of processing in accordance with applicable data protection laws.

12. DO-NOT-TRACK CONTROLS

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can enable to signal your preference not to have information about your online browsing activities monitored or collected. At this time, there is no consistent industry standard for recognizing and implementing DNT signals. For that reason, we do not currently respond to DNT browser signals or to other automated mechanisms that communicate a “do not track” preference. If a standard is adopted in the future that we are required to follow, we will describe our updated practices in a revised version of this Privacy Policy.

13. MOBILE PRIVACY

The TRADENCE mobile application may use third-party software development kits (“SDKs”) and application programming interfaces (“APIs”) provided by trusted service partners to support core functionality, security features, analytics, and performance monitoring.

These integrations may collect limited technical information from your device, such as device identifiers, operating system version, app version, crash diagnostics, and usage data. We use this information to help improve platform reliability, strengthen security, troubleshoot issues, and enhance user experience.

We require third-party service providers to process this information only under our instructions, in line with applicable data protection laws and appropriate contractual safeguards.

For more information about cookies and similar technologies, please refer to our COOKIES AND SIMILAR TECHNOLOGIES section above or contact us at privacy@tradence.com.

14. BLOCKCHAIN INFORMATION

Please be aware that blockchain networks are generally transparent. Transactions you initiate or approve through the Platform may be publicly visible on the relevant blockchain, including (without limitation) your public wallet address, the recipient’s public wallet address, transaction amounts, timestamps, and any additional data included with a transaction.

Public blockchain activity may, now or in the future, be analyzed and linked to individuals by third parties (including analytics providers and law enforcement). As a result, blockchain data may be used to infer or correlate information about a user’s identity or activity. We encourage you to understand how privacy and transparency work on blockchain networks before using blockchain-based features.

15. THIRD-PARTY LINKS

Our Sites or Services may include links to third-party websites, apps, or services that are not operated or controlled by Tradence. If you follow a third-party link, any information you provide (or that is collected) will be governed by that third party’s own privacy practices and terms.

We are not responsible for the content, security, or privacy practices of third-party sites or services. We encourage you to review the applicable privacy policies and notices of any third-party website or service you choose to visit.

16. CHANGES TO THIS PRIVACY POLICY

Note: We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.

When we update this Privacy Policy, we will revise the “Last updated” date at the top of this page. If we make material changes, we may also provide additional notice where appropriate, such as by posting a prominent notice within the Services or sending you a notification. We encourage you to review this Privacy Policy regularly so you understand how we collect, use, and protect your information.

17. ACCESS, UPDATE, OR DELETE YOUR INFORMATION

Depending on where you live and the laws that apply, you may have the right to request access to the personal information we collect about you, receive details about how we have processed it, correct inaccurate or incomplete information, or request deletion of your personal information. You may also have the right to withdraw consent where we rely on consent to process your personal information. These rights may be limited in certain circumstances (for example, where we must retain information to comply with legal or regulatory obligations or to establish, exercise, or defend legal claims). To submit a request, please complete and send a data subject access request.

18. CONTACT US

If you have any questions about this Privacy Policy or our privacy practices, please contact us: