TraderWagon Privacy Statement

TraderWagon Privacy Statement
Last updated: 4 January 2022.
Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.
This Privacy Statement describes how TraderWagon collects and processes your personal information through the TraderWagon websites and mobile applications or other related services or applications hereto that reference this Privacy Statement and which rights you have in relation to the processing of your personal data. By using the services provided by TraderWagon (“TraderWagon Services”), you are consenting to the collection, storage, processing and transfer of your personal information as described in this Privacy statement.
TraderWagon Ltd., whose address is at Victoria Corporate Agents (Proprietary) Limited, Suite 108, Premier Building, Victoria, Mahe, Seychelles is the Data Controller for personal information collected and processed in connection with the provision of TraderWagon Services.
1.
What Personal Information About Users Does TraderWagon Collect? For what Purposes does TraderWagon process Users Personal Information?  For which purposes and on which legal basis do we use your personal data?
TraderWagon collects personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders, and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.
Below is also a chart describing the categories of personal data we collect.
What information and personal data does TraderWagon process?
Why does TraderWagon process my personal information?
Legal Basis for our use of personal information.

- email address;

- name;

- gender;

- date of birth;

- home address;

- phone number;

- nationality;

- device ID;

- Transaction services. We use your personal information to process order transactions, and to communicate with you about orders and services;

- Communicate with you. We use your personal information to communicate with you in relation to TraderWagon Services;

Performance of a contract when we provide you with products or services or communicate with you about them. This includes when we use your personal information to take and handle orders and process transactions.

- The Internet protocol (IP) address used to connect your computer to the Internet;

- Login, e-mail address, password and location of your device or computer;

- TraderWagon Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences);

- Version and time zone settings;

Provide, troubleshoot, and improve TraderWagon Services. We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of TraderWagon Services.
Our legitimate interests and the interests of our users when, for example, we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or other;

- Transaction history;

- Information from other sources: we may receive information about you from other sources such as credit history information from credit bureaus;

Fraud prevention and credit risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our users, TraderWagon Services and others. We may also use scoring methods to assess and manage credit risks.
Our legitimate interests and the interests of our users when, for example, we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others.
Information about your behavior: we may process information about you on your behavior and your activity for marketing and advertising purposes.

- Improve our services. We process personal information to improve our services and for you to have a better user experience;

- Recommendations and personalisation. We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with TraderWagon Services;

Our legitimate interest to improve our services;
Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your data for that purpose.

- The Internet protocol (IP) address used to connect your computer and app to the Internet.

- Login, e-mail address, password and location of your device or computer.

- TraderWagon Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences);

- Version and time zone settings.

- Transaction history.

Automatically Collected information. We automatically collect and store certain types of information about your use of TraderWagon Services including your interaction with content and services available through TraderWagon. Like many websites, we use cookies and other unique identifiers, and we obtain certain types of information when your web browser or device accesses TraderWagon Services
Your consent when we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your data for that purpose.
Except for certain information that is required by law or by policies, your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.
The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to the website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors.
Where the above table states that we will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.
To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal information, only in countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal data will not be your consent but any other applicable legal basis.
We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest to do so.
2. Can Children Use Trader Wagon Services?
TraderWagon does not allow anyone under the age of eighteen (18) years to use TraderWagon Services.
3. What About Cookies and Other Identifiers?
We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements. To enable our systems to recognise your browser or device and to provide TraderWagon Services to you, we use cookies.
We use operational cookies and similar tools (collectively, "cookies") to provide our services, for example:
  • Recognising you when you sign-in to use our services.
  • Providing customised features and services.
  • Displaying features and services which might be of interest to you, including ads on our services.
  • Preventing fraudulent activity.
  • Improving security.
  • Keeping track of your preferences such as currency and language.
  • We also use cookies to understand how users use our services so we can make improvements.
The settings on your browser will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable and remove cookies, and when cookies will expire.
Operational cookies allow you to take advantage of some of TraderWagon’s essential features. If you block or otherwise reject operational cookies through your browser settings some features, and services may not work.
4. Does TraderWagon Share My Personal Information with third parties?
Information about our users is an important part of our business and we are not in the business of selling our users' personal information to others. TraderWagon shares users' personal information only as described below and with the subsidiaries or affiliates of TraderWagon that are either subject to this Privacy Statement or follow practices at least as protective as those described in this Privacy Statement. Before TraderWagon shares this information, we shall take the necessary steps to ensure that our Users personal information will be given adequate protection as required by relevant data privacy laws and TraderWagon internal policies.
  • Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, assessing and managing credit risk, and performing identity recognition and other KYC functions. These third-party service providers have access to personal information and Sensitive Personal Data needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as only permitted by applicable data protection laws.
  • Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy notice. Also, in the unlikely event that TraderWagon or substantially all of its assets are acquired, user information will be one of the transferred assets.
  • Protection of TraderWagon and others: We release accounts and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of TraderWagon, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction, and with regulatory agencies and law enforcement to comply with lawful requests.
5. What about sensitive data?
We do not collect sensitive data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.
The term “sensitive data'' refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biomentric or generic data, sexual life or orientation or criminal convictions and offences (including information about suspected criminal activities).
6. How Secure is My Information?
We design our systems with your security and privacy in mind. We protect your personal data in accordance with applicable laws and our data privacy policies. We work to protect the security of your personal information -such as encryption protocols and software whilst transmitting data- and maintain the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, altercation, disclosure, or access, or accidental or unlawful destruction of damage thereto.
We maintain physical, technical, and organizational security safeguards in connection with the collection, storage, and disclosure of your personal information. We have protocols, controls and relevant policies, procedures, and guidance to maintain these arrangements considering the risks associated with the categories of personal data and the processing we undertake. We adopt market leading security measures to protect your personal data.
Our security procedures mean that we may ask you to verify your identity before we disclose personal information to you.
7. How Does TraderWagon Use Personal Data for Marketing Purposes?
We may share your personal information with our marketing partners for the purposes of targeting, modelling, and/or analytics as well as marketing and advertising in accordance with applicable marketing laws and regulations. You can exercise your right to prevent marketing communications to you by checking the above forms described we use to collect your personal data, or by utilizing may opt-out mechanisms in e-mails we send to you. You can also opt-out of receiving such marketing by contacting marketing_tw@traderwagon.com. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.
8. What Rights Do I Have With Respect To The Processing Of My Personal Data (“Data”) ?
You are entitled (in the circumstances and under the conditions, and subject to the exceptions specified in applicable law) to:
  • Right to access  you have the right to obtain confirmation that your Data are processed and to obtain a copy of it as well as certain information related to its processing.
  • Right to rectify  you can request the rectification of your Data which is inaccurate, and also add to it. You can also change your personal information in your account at any time.
  • Right to delete  you can, in some cases, have your Data deleted.
  • Right to object:  you can object, for reasons relating to your situation, to the processing of your Data. For instance, you have the right to object to commercial prospection.
  • Right to limit the processing:  in certain circumstances, you have the right to limit the processing of your Data.
  • Right to portability:  in some cases, you can ask to receive your Data which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, that we communicate your Data on your behalf directly to another data controller.
  • Right to withdraw your consent:  for processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter.
  • Right to define the instructions relating to the use of your personal data postmortem:  you have the right to define instructions relating to the retention, deletion and communication of your Data after your death.
  • Right to lodge complaints to the relevant data protection authority. 
If you’d like to exercise any of your rights please do contact us at tw@traderwagon.com
9. What Choices Do I Have?
If you have any questions or objections as to how we collect and process your personal information, please contact dpo@traderwagon.com
10. How Long Does TraderWagon Keep My Personal Information?
We will retain your personal information to enable your continued use of TraderWagon Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Notice, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to you. Additionally, identity information and Sensitive Personal Data may be retained for eight years to comply with Anti-Money Laundering laws.
11. Contact Information
Our data protection officer can be contacted at dpo@traderwagon.com and will work to address any questions or issues that you have with respect to the collection and processing of your personal information. Please do not hesitate to contact us if:
  • You have a general question about how TraderWagon protects your personal data.
  • You wish to exercise your rights in relation to your personal data rights (as set out in section 8, 9, 10 and 11)
  • You wish to make a complaint about TraderWagon’s use of your data.
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