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This policy explains what personal data we collect about you, why we collect it, who we share it with, how long we keep it and what you can ask us to do with it. We collect what we need to run a regulated financial service and to keep your account safe, and we do not sell your data to anyone.
Trade909., an International Business Company incorporated in Saint Lucia. registered office Ground Floor, Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia, is the controller of the personal data described in this policy.
Our data protection contact is info@trade909.com. That mailbox reaches the people accountable for data protection at Trade909, and it is the route to use for any question or request about your data. We ask you to write to the mailbox rather than to an individual, so that a request is logged and answered even when a particular person is unavailable.
We are established in Saint Lucia, so the data protection law of our own jurisdiction is the Data Protection Act of Saint Lucia, which establishes a Data Protection Commissioner. Depending on where you live, the law of your own country may also give you rights against us.
We do not make your rights depend on which law reaches you. Working out whose data protection regime governs a given client is a question lawyers argue about, and it is not a question you should have to win before we will correct a wrong address or delete something we no longer need. So the rights in section 10 are given to every person whose data we hold, as a matter of our own policy, wherever you live and whichever regime turns out to apply.
This policy covers our websites, our client onboarding and account services, our trading platforms to the extent we process data through them, and our communications with you. It applies whether you are a client, an applicant, a visitor, an introducing broker, or a representative of a corporate client.
Name, date of birth, nationality, gender where a document shows it, photograph and document images, national identifier where a document carries one, and the result of a liveness check.
Residential address, email address, telephone numbers, and the messaging identifiers you give us.
Employment, income, source of funds and source of wealth, net worth, tax residence and taxpayer identifiers, and your answers to our questions about trading knowledge and experience.
Deposits, withdrawals, payment method identifiers such as a masked card number or bank account, account balances, orders, positions, and your full trading history.
IP address, approximate location derived from it, device and browser identifiers, operating system, login times, and platform session data.
Emails, chat transcripts, support tickets, and recordings of telephone calls with us.
Sanctions and watch-list screening results, adverse media matches, politically exposed person status, and records of our due diligence and any internal report.
Your preferences, consents and opt-outs, and how you interact with our emails and website.
Before we launch, the only personal data we collect from the public is an email address. If you asked to be notified when we open, we hold the address you gave us and the time you gave it, and we use it to send you the launch notice and nothing else. You can have it removed at any time by writing to info@trade909.com.
We do not seek special category data, such as data about health, beliefs or biometrics, except where an identity document or a liveness check necessarily contains it, in which case we use it only to verify your identity.
Taking steps at your request before entering into a contract
Performance of our contract with you
Compliance with a legal obligation, and our legitimate interest in preventing financial crime
Compliance with a legal obligation, and our legitimate interest in resolving disputes
Our legitimate interest in the security of our service
Our legitimate interest in improving what we offer, and consent where cookies require it
Consent, or our legitimate interest where you are an existing client and can opt out at any time
Our legitimate interest in protecting our position
If you do not give us the identity, address and source of funds information we ask for, we cannot open or maintain your account. That is a legal requirement on us, not a commercial preference. See our AML and KYC Policy.
We will only send you marketing where you have agreed to receive it, or where you are an existing client and the message concerns services similar to those you already use. Every marketing message carries an unsubscribe link, and you can also opt out at any time by writing to info@trade909.com.
Opting out of marketing does not stop service messages. We will still send you the things we are required to send you, such as statements, margin notifications, changes to your agreement and security alerts.
We do not sell your personal data, and we do not share it for another organisation’s own marketing.
We share personal data only where there is a reason to, and only as much as is needed:
We operate internationally and our service providers do too, so your data may be processed in countries other than the one you live in, including countries whose data protection law differs from your own.
Where we transfer personal data across borders, we do so under a contract requiring the recipient to protect it to the standard described in this policy, to use it only for the purpose we specify, and to return or delete it when the engagement ends. You may ask us for information about the safeguards applying to a particular transfer.
We keep personal data for as long as you are a client, and after that for as long as the law requires us to and for as long as a claim could still be brought.
At least six years after the end of the relationship, as required of us in Saint Lucia. Where the end of a relationship is unclear, we treat it as ending on the date of the last transaction. See our AML and KYC Policy.
At least six years after the transaction, so that any transaction can be reconstructed on a lawful request.
At least six years after the communication. These records evidence the instructions you gave us, so they are kept on the same basis as the transactions they relate to.
Kept for the period needed to evidence why the application was declined and to meet our reporting obligations, then deleted.
Until the launch notice has been sent, or until you ask us to remove you, whichever is sooner.
Indefinitely, because an opt-out has to outlive the record it relates to in order to be honoured.
When a retention period ends we delete the data or anonymise it so that it can no longer be linked to you.
You can ask us to:
Write to info@trade909.com to exercise any of these. We will respond within 30 days, and we will tell you before that runs out if a request is complex enough to need longer. We may need to verify your identity first, which is itself a protection for you. We do not charge for a request unless it is manifestly unfounded or excessive.
If you are unhappy with how we have handled your data, tell us first so that we can put it right. You may also complain to the data protection supervisory authority in your own country, and to the Data Protection Commissioner of Saint Lucia.
We use technical and organisational measures appropriate to the sensitivity of the data, including encryption of data in transit and at rest, access control on a need-to-know basis, multi-factor authentication for our systems, logging and monitoring, supplier due diligence, and staff training.
No system is perfectly secure. Where a breach occurs that is likely to affect you, we will tell you and the relevant authority as required. You can help by using a strong and unique password, enabling any second factor we offer, keeping your devices patched, and treating any message asking for your credentials as fraudulent. We will never ask you for your password.
Our websites use cookies and similar technologies. Strictly necessary cookies make the site work, remember your locale, and protect against abuse, and they cannot be switched off. Analytics and marketing cookies are used only with your consent, and you can change or withdraw that consent at any time through the cookie settings on the site.
You can also block or delete cookies in your browser. Blocking strictly necessary cookies will stop parts of the site from working.
We use automated tools in onboarding, principally for identity verification, sanctions screening and fraud detection. Where an automated check produces a result that would lead to an application being declined or an account being restricted, a person reviews it before the decision takes effect. You may ask for that review to be explained to you, and you may contest the outcome, except where telling you would breach a legal restriction on disclosure.
We do not use your trading data to make automated decisions that produce legal effects for you.
Our services are not offered to anyone under 18 and we do not knowingly collect data about children. If we discover that we hold data about a child, we will delete it.
We may update this policy. The current version is always the one published here, and where a change is material we will tell you before it takes effect.
Trade909, Ground Floor, Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia. Email info@trade909.com.