This Privacy Policy explains what personal information we may gather about you in connection with our services engagement and how this personal information may be used and shared. This Privacy Policy also sets out your rights in relation to your personal information and tells you who you can contact if you have questions.
This Privacy Policy is divided into the sections listed below.
1. To whom does this Privacy Policy apply and what does it cover?
2. What personal information do we collect?
3. How do we collect personal information?
4. Disclosing personal information to us relating to third parties
5. How do we use your personal information?
6. On what basis do we process personal information about you?
7. To whom will we disclose your personal information?
8. How do we keep your personal information secure?
9. How long will we keep your personal information?
10. What are your rights in relation to your personal information?
11. Changes to this Privacy Policy
12. Contact us

This Privacy Policy applies to smartTrade Technologies, a French simplified stock corporation (société par actions simplifiée), with a share capital of Euros 1 066 650,00 registered with the Trade and Companies Registry of Aix-en-Provence (France) under No.421 663 774 and having its registered office at Immeuble Apogée, 500, Avenue Galilée, 13100 Aix-en-Provence, France and its affiliates parts of smartTrade Technologies group (hereinafter collectively referred as “smartTrade Technologies” or “we”, “us”, and “our”). “Affiliate” means any entity directly or indirectly controlled by smartTrade Technologies SAS (France).
This Privacy Policy sets out how we will process your personal information as part of our activities and professional services.
Your personal information will be protected and handled with consideration for its confidentiality and smartTrade Technologies will only disclose it as set out in the “To whom will we disclose your personal information?” section below.
In this Privacy Policy, we refer to handling, collecting, protecting and storing your personal information as “processing”.

SmartTrade Technologies may collect personal information relating to you such as:
• Name;
• Contact Details (such as work or home address, email and phone numbers);
• Financial information.
Where we receive special category personal information or other information from which special category personal information can be reasonably inferred information (special category personal information is considered to include information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data or sexual orientation), we will require explicit consent in order to process it.

SmartTrade Technologies may collect personal information about you in different ways:
• you may provide it directly to us;
• we may obtain it because of the products or services that smartTrade Technologies provides or has previously provided to you;
• we may receive it from third parties such as your employer/partnership or from relevant authority/administrative bodies;
• we may observe or infer it from the information you provide to us and/or the way you interact with us (as for example, through our Web Site).
This personal information can be received in any manner, including in-person discussions, telephone conversations, and electronic or other written communications.
Without access to all the personal information that we need, we may be unable to provide the products or complete the services.
Where another party (such as a company or a partnership or any third parties acting on your or their behalf) provides your personal information to us, they must also comply with their obligations under the relevant privacy laws and regulations. If you believe that the entity for whom you work, or a third party has not provided you with details of the personal information that it holds about you and/or has not obtained your authority to provide us with that personal information for processing as described in this Privacy Policy, then please contact such entity directly.

If any personal information which you provide to us relates to any third party (such as but not limited buyers or vendors connected through our multi assets trading tools), then by providing us with their personal information you will need to ensure that you have obtained any necessary permissions from those persons to the use of their personal information in the way set out in this Privacy Policy, or you are otherwise permitted to give us this personal information. You should share a copy of this Privacy Policy with those other individuals before disclosing any personal information about them to us.

SmartTrade Technologies processes personal information about you to:
• establish or maintain our relationship with you;
• provide our products or services to you and/or to the entity that you represent;
We may also use your personal information for the purposes of, or in connection with:
• compliance with applicable legal, regulatory or professional requirements;
• protecting our rights and/or property.
In all cases, smartTrade Technologies does not sell or lease your personal information to others.

This Privacy Policy sets out the grounds upon which we rely in order to process your personal information.
We may use your personal information for the purposes outlined above because:
x (a) where relevant, we have a contract with you and/or to the entity that you represent to provide our products or services and processing your personal information is necessary for the performance of such contract;
x or (b) we have a legitimate interest in processing your personal information, which may be to:
• provide our products or services to you and/or to the entity you represent and that has engaged smartTrade Technologies to provide our products or services;
• support the management of our client engagements;
• evaluate, develop or improve our services or products; or
• protect our business interests.
x or (c) we are subject to legal, regulatory or professional obligations.

In connection with one or more of the purposes outlined in this Privacy Policy, we may disclose your personal information to:
• other Affiliates of smartTrade Technologies Group;
• those with whom you have requested us to share information, such as competent authorities, including courts and authorities regulating our activities, in each case to comply with legal, regulatory or professional obligations or requests;
• vendors and administrative, support, infrastructure and other service providers handling your information on our behalf. In each case, such vendors and service providers will be contractually bound by confidentiality and privacy obligations consistent with the obligations in this Privacy Policy;
• third parties to whom we disclose information in the course of providing our products or services to you and/or to the entity you represent and that has engaged smartTrade Technologies to provide our products or services.
Please note that some of the recipients of your personal information referred to above may be based in countries or regions outside of the European Economic Area (“EEA”) without data protection rules similar to those in effect in your area of residence. In such cases, adequate safeguards will be in place to protect your personal information.
For further details about the transfers described above and the adequate safeguards used by smartTrade Technologies with respect to such transfers, please contact us using the details below.

We have in place reasonable commercial standards of technology and operational security to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Only authorized personnel, with appropriate awareness of privacy obligations, are provided access to your personal information.

We retain personal information as long as is necessary to fulfil the purposes identified in this Privacy Policy or (i) as otherwise necessary to comply with applicable laws or professional standards, or (ii) as long as the period in which litigation or investigations might arise in respect of our products or services.

You have various rights in relation to your personal information. In particular, you have a right to:
• obtain confirmation that we are processing your personal information and request a copy of the personal information we hold about you;
• ask that we update the personal information we hold about you or correct such information that you think is inaccurate or incomplete.
Depending on the jurisdiction in which you are located, you may also have the right to:
• ask that we delete personal information that we hold about you, or restrict the way in which we use your personal information;
• withdraw consent to our processing of your personal information (to the extent our processing is based on your consent);
• ask us to stop or start sending you marketing messages at any time;
• obtain and/or move your personal information to another service provider;
• object to our processing of your personal information.
Where our processing of special category personal information is reliant on your consent and you withdraw that consent, we will cease processing the relevant information for the purposes of providing our products or services and the effect may be that we are no longer able to perform our commitments.
However, we may still retain a copy of the relevant information for as long as necessary to comply with applicable laws or professional standards, or as long as the period in which litigation or investigations might arise in respect of our products or services.
To exercise any of your rights or raise any questions that you have about our use of your personal information, please contact us using the details below.

We may modify or amend this Privacy Policy from time to time at our discretion. When we make changes to this Privacy Policy, we will amend the revision date of this page and the modified or amended Privacy Policy shall apply to you and your personal information as of that revision date. We encourage you to review the Privacy Policy periodically to be informed about how we are protecting your personal information.

If you have any questions or concerns regarding this Privacy Policy or your personal information, you can contact us via email at: [email protected]
smartTrade Technologies has appointed a data protection officer who can be reached at the following address: [email protected]

Last updated: July 2020