Last updated: 10 Feb 2025
Please carefully read this Privacy Policy ("Policy"), which governs how Service made available by Electra.trade ("Company", "we"), collects, uses and discloses information, when you access or use Company`s Service as such term is described in Terms of Use, or when you otherwise interact with us.
1.1 This Policy defines the Personal Data, explains how Personal Data is collected, used, processed, and disclosed.
1.2 This Policy shall come into effect at the moment you first access the Service. By accessing, browsing, using the Service, clicking the “Start” button, clicking the “I agree to the terms of the Privacy Policy” button, you unconditionally accept and adhere to provisions of this Policy without any exemptions, limitations and/or exclusions.
1.3 In the event you disagree with any provision of this Policy or would not like to provide your consent for processing of your Personal Data, you shall cease using the Service.
2.1 The data controller of this Service is Electra.trade. For contact details, please refer to the official communication channels available on our platform.
3.1 We process your Personal Data on the basis that it is:
3.1.1 necessary for the performance of a contract, therefore, where we have a contract with you, we will process your Personal Data in order to fulfill that contract (in particular, to provide access to the Service and render Services available through it);
3.1.2 authorized by your Consent, which you give us as it is set out in section 4 hereof;
3.1.3 necessary for compliance with our legal obligation, in particular, when we are obliged to respond to a court order or a regulator;
3.1.4 necessary for performance our legitimate interests;
3.1.5 permitted by applicable legislation.
3.2 We process the Personal Data for a number of legitimate interests, including to provide and improve the Service, administer our relationship with you and our business, for marketing, and in order to exercise our rights and responsibilities as specified in section 6 of the Agreement.
4.1 Including are an EU Person, to process your Personal Data we need to receive your consent, as it is prescribed by GDPR or other applicable law, we will process your Personal Data in the case we have received from you a freely given, specific, informed and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data ("Consent").
4.2 By accessing the Service, browsing, using, clicking the “Start” button, clicking the “I agree to the terms of the Privacy Policy” button, you directly and voluntarily agree that you are clearly informed of the data's intended use, and you give us individual, explicit, active, informed Consent.
4.3 Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the Processing has multiple purposes, your Consent should be deemed given for all of them, unless otherwise provided by this Policy.
4.4 You have the right to withdraw your Consent at any time. You can submit such a request through the designated process available on our platform. Your withdrawal of Consent shall not affect the lawfulness of Personal Data processing that occurred before the withdrawal.
4.5 Except as required or enabled by law we will not use or disclose your Personal Data for any purpose for which you refuse Consent or later withdraw your Consent. If you withdraw Consent, you agree that in spite of this withdrawal, we may continue to use those Personal Data previously provided to us to the extent that we are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation you may have towards the Company or in any other way permitted by law.
5.1 General Provisions
5.1.1 The type of Personal Data we collect depends on how you are interacting with us. In many cases, you can choose whether or not to provide us with Personal Data, but if you choose not to, you may not get full functionality of the Service. When you visit Service, you may provide us with the following types of Personal Data: (i) Personal Data that you voluntarily disclose that is collected on an individual basis; (ii) Personal Data collected automatically when you use the Service; and (iii) Personal Data which we collect from sources other than the Service.
5.1.2 The Service contains links to other third-party websites that may collect Personal Data about you, including through cookies or other technologies. If you use our links to visit other websites, services this Policy will not apply to your use of, and activity on those other websites. You should consult these other websites' privacy policies as we have no control over them and are not responsible for any information that is submitted to or collected by these third parties.
5.2 Personal Data You provide to Us
5.2.1 In order to fulfill our obligations on provision an access to the Service and/or provision of Opportunities for you and applicable terms of use, we are entitled to ask you to provide us with your Personal Data, including (but not limited):
- Cryptocurrency wallet information;
- Telegram username;
- Your feedback, questionnaire and other survey responses, and information you provide to our support teams and chats for Service users.
Personal Data hereof is collected only when voluntarily offered, and solely for purposes that are clearly identified on the Service or in this Policy.
5.2.2 The Company may collect the Personal Data from you in a variety of ways and circumstances, including, but not limited to, registration at the Service, subscription to a newsletter, filling out a form, providing us with feedback, sending messages to the Telegram Bot, clicking on the buttons in the messages sent by the Telegram Bot. The Company shall be entitled to combine Personal Data collected in the course of your interaction with different sections of the Service with any other relevant available information.
5.3 Personal Data We Collect Automatically
5.3.1 Personal Data collected by or transmitted to the Company in the course of accessing, interacting and operating of the Service may include, without limitation, the following Personal Data:
- device information, which may include (but is not limited to) information about the computer or mobile device you use to access the Service, including the hardware model, operating system and version, the web browser you use, and other device identifiers;
- transaction information, which may include type of transaction you make on the Service, transaction amount, and timestamp;
- server log information, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at the Service and the websites you visit just before and just after the Service.
5.4 Data We May Collect from Other Sources. Sometimes, we may receive Personal Data about you from other sources as required or permitted by applicable law, including public databases. We may combine the information collected from these sources with the information we get from the Services in order to comply with our legal obligations and limit the use of the Services in connection with fraudulent or other illicit activities.
6.1 We use Personal Data for the following purposes.
6.1.1 to provide access to the Service;
6.1.2 to handle your orders and requests, including requests for technical support and assistance;
6.1.3 to properly fulfill tax-related and accounting obligations imposed by applicable laws;
6.1.4 to detect, investigate, and prevent illegal activities or conduct that may violate the terms of use of the Service and this Privacy Policy;
6.1.5 to conduct legal and regulatory compliance;
6.1.6 personalize your experience with our Service;
6.1.7 contact you in relation to, and conduct, surveys or polls you choose to take part in and to analyse the data collected for market research purposes;
6.1.8 conduct internal research and development and to improve, test and enhance the features and functions of our Service;
6.1.9 provide you with marketing materials as permitted by law;
6.1.10 meet our internal and external audit requirements, including our information security obligations.
7.1 The Company does its best to not disclose Personal Data, нowever, in some cases the Company may or obliged to do this.
7.2 We treat Personal Data as confidential and may not pass on or use any such data without valid legal grounds. We will only disclose your Personal Data in the following circumstances:
7.2.1 with your Consent or at your instruction;
7.2.2 with companies under common control or ownership with us or our offices internationally;
7.2.3 to respond to court orders and legal investigations;
7.2.4 in connection with a merger or sale of our company assets, or if we do a financing or are involved in an acquisition, or any other situation where Personal Data may be disclosed or transferred as one of our business assets;
7.2.5 if we believe your actions are inconsistent with our terms of use of the Service or applicable legislation, or to protect the rights, property and safety of any assets of the Company or third parties.
7.3 The Company may without limitations share aggregated or de-identified information, which cannot reasonably be used to identify you.
7.4 You can at any time report the misuse of your Personal Data and/or ask us to restrict access to your Personal Data in accordance with this Policy and applicable law.
8.1 The transmission of Personal Data or any other information over the Internet or other publicly accessible networks is not completely secure. The Company is not liable for the security of any Personal Data or information you transmit over the Internet, or for any third-party content.
8.2 Information about you may be transferred to, and processed in countries other than the country in which you are a resident. We have taken appropriate safeguards to require that your information will remain protected in accordance with this Privacy Policy.
8.3 Personal Data of EU Persons transmitted to a recipient outside the European Economic Area may be processed by a staff member operating outside the European Economic Area (EEA) who works for us or for one of digital Content developers or copyright owners. Such staff may be engaged in amongst other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
9.1 We take appropriate security, administrative and technical measures to protect any Personal Data you provide regarding the collection, storage and processing of Personal Data, as well as security measures to protect your Personal Data against unauthorized access, modification, disclosure or destruction.
9.2 Personal Data is safeguarded from unauthorised access and unlawful processing or disclosure, as well as accidental loss, modification or destruction, through state-of-the-art technical and organisational measures. These are adjusted and updated continuously in tandem with technical developments and organizational changes. Additionally, Personal Data protection audits and other controls are carried out on a regular basis. However, no computer security system is entirely foolproof, and the Internet is not a secure method of transmitting information. As a result, we do not assume any responsibility for the Personal Data you submit to or receive from us through the Internet, or for any unauthorized access or use of that information, and we cannot and do not guarantee that information communicated by you to us or sent to you by us will be received, or that it will not be altered before or after its transmission to us. You agree to not hold the Company liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of information provided through the Service
10.1 In accordance with applicable laws and as needed to fulfill our obligations, we may hold your Personal Data. This requirement is conditioned by a need to comply with legal obligations and resolve possible disputes.
10.2 Your Personal Data is stored on a server that we rent in a special third-party cloud infrastructure, unless otherwise provided by this Policy. We do not transfer your Personal Data to such third-party cloud infrastructure.
10.3 The Company may retain your Personal Data until your consent is withdrawn or the Terms of Use are terminated. After the Terms of Use are terminated, the data may be stored for a period of time to comply with legal and regulatory requirements, resolve disputes and prevent money laundering, fraud and other illegal activities
11.1 The Company is committed to making sure you can exercise your respective rights effectively and free of charge. The Company will ensure that each request related to your Personal Data be reviewed in a timely manner.
11.2 You have the following rights relating to your Personal Data in accordance with any applicable laws, including GDPR:
11.2.1 Right to access: You can request access to your Personal Data and obtain a copy of it in a format acceptable to you (e.g., PDF, DOC, DOCX, etc.). To submit such a request, please use the support widget available through our platform. Once received, our privacy team will review the request and verify your identity. Upon successful verification, you will be provided with a copy of your Personal Data.
11.2.2 Right to data portability. You have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another service provider (controller) without hindrance from us.
11.2.3 Right to erasure ("Right to be forgotten") and right to rectification. You may request the deletion or correction of your Personal Data through our platform's designated request system. We will process these requests unless a legal obligation prevents us from doing so. Please note that due to the immutable nature of blockchain technology, data stored on a blockchain cannot be erased or altered. Once a request is fulfilled, you will be informed that your Personal Data has been updated or erased and is no longer collected. However, to comply with legal requirements, the Company may retain information about each requestor as proof that the request has been processed.
11.2.4 Right to object. You have the right to object to the Processing of your Personal Data at any time. This right can be exercised through our platform's request system. Once a request is received, the Company will stop Processing unless a legal or statutory basis requires its continuation.
11.2.5 Right to be informed. If you are inquiring about Processing activities conducted with respect to your Personal Data, the Company, without undue delay, will provide information about: (i) purposes of Processing; (ii) categories and types of Personal Data; (iii) the recipients or categories of recipients to whom the personal data have been or will be disclosed to, in particular recipients in third party countries or international organizations (iii) retention period; (v) source of the relevant Personal Data; (vi) privacy rights and information on data portability; (vii) where the personal data are not collected from the data subject, any available information as to their source; (viii) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject; (ix) information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data in subject to, shall have the right to be informed of the appropriate safeguards relating to the transfer. However, all information about the categories of Personal Data and Processing operational conducted by the Company is available in this Policy.
11.2.6 Right to lodge a complaint with a supervisory authority. Supervisory authority means an independent public authority, for example, which is established by an EU member state pursuant to Article 51 GDPR or any other applicable law.
12.1 The minimum age to use the Service is 18 years. The Company will not knowingly collect Personal Data from children under this age. Insofar as certain countries apply a higher age of consent for the collection of Personal Data, the Company requires parental consent before Personal Data associated with such a child is collected. The Company encourages parents to instruct their children to never give out personal information when online.
13.1 We have the right, at our discretion, to update this Policy at any time. We recommend that you frequently check this Policy to find any changes and stay informed about how we help protect the Personal Data.
13.2 By using the Service, you will acknowledge and agree that it is your responsibility to periodically review this Policy and be aware of the changes.
13.3 The subsequent use of the Service after changes to this Policy will also be considered as your acceptance of these changes.
13.4 This Policy may from time to time be translated into other languages. To the extent that any discrepancy may exist between the English version of this Policy and its version in another language, the English version prevails.
14.1 The Company appoints an expert on data privacy who works independently to ensure that the Company is adhering to the policies and procedures set forth in the GDPR (data protection officer). Data protection officer assists the Company to monitor internal compliance, inform and advise on data protection obligations, provide advice regarding data protection impact assessments (DPIAs) and act as a contact point for data subjects and the supervisory authorities.
15.1 We welcome your questions and suggestions regarding the implementation or amendment of this Policy. Please use the designated feedback form or contact method available on our platform to communicate with us.
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