Privacy Policy

How TradeMaster collects, uses, and protects your information.

Effective January 1, 2025

CONTENTS

01 Introduction

TradeMaster (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Commodity Trading and Risk Management (CTRM) platform and related services. By accessing or using TradeMaster, you agree to the terms of this Privacy Policy.

 

02 Information We Collect

We collect information you provide directly to us, including: • Account and registration information (name, email address, job title, company name) • Trading and operational data you enter into the platform (trade records, counterparty details, contract information) • Payment and billing information for subscription management • Communications and support requests you submit to us • Usage logs and interaction data when you use our platform We also collect technical information automatically, including IP addresses, browser type, operating system, referring URLs, and platform activity logs.

03 How We Use Information

We use the information we collect to: • Provide, operate, and maintain the TradeMaster platform • Process transactions and send related information • Send technical notices, updates, security alerts, and support messages • Respond to your comments, questions, and requests • Monitor and analyze usage patterns to improve our services • Detect, prevent, and address technical issues and security threats • Comply with legal obligations and enforce our terms

04 Legal Basis for Processing

For users in the European Economic Area, we process personal data under the following legal bases: • Performance of a contract: Processing necessary to provide our services under your subscription agreement • Legitimate interests: Operating and improving our platform, preventing fraud, and ensuring security • Legal obligation: Compliance with applicable laws and regulations • Consent: Where you have provided explicit consent for specific processing activities

05 Data Retention

We retain your personal data for as long as your account is active or as needed to provide services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce agreements. Trading and operational data is retained in accordance with applicable financial recordkeeping regulations, typically a minimum of 7 years. You may request deletion of your account data subject to applicable legal requirements.

06 Data Security

We implement appropriate technical and organizational security measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include: • AES-256 encryption for data at rest and TLS 1.3 for data in transit • Role-based access controls and multi-factor authentication • Regular security audits and penetration testing • SOC 2 Type II certified infrastructure • Continuous monitoring and incident response procedures No method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

07 International Data Transfers

TradeMaster operates globally. Your information may be transferred to and processed in countries other than your country of residence. Where we transfer data outside the European Economic Area, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission and compliance with applicable transfer frameworks.

 

08 Cookies & Tracking Technologies

We use cookies and similar tracking technologies to track activity on our platform and improve your experience. We use essential cookies necessary for platform operation, analytics cookies to understand usage patterns, and functional cookies to remember your preferences. You can control cookie settings through your browser preferences. See our Cookie Policy for detailed information.

 

09 Third-Party Services

We may share your information with third-party service providers who assist us in operating our platform, including cloud infrastructure providers, payment processors, analytics services, and customer support tools. These providers are contractually obligated to maintain the confidentiality and security of your information and may not use it for any purpose other than providing services to us.(HubSpot, LinkedIn). These third parties have their own privacy policies governing their use of cookie data. We do not control these third-party cookies.

10 User Rights

Subject to applicable law, you have the right to: • Access the personal data we hold about you • Request correction of inaccurate or incomplete data • Request deletion of your personal data • Object to or restrict processing of your data • Request portability of your data in a machine-readable format • Withdraw consent where processing is based on consent To exercise these rights, contact us at privacy@trademaster.io.

11 GDPR Rights

If you are located in the European Economic Area, you have additional rights under the General Data Protection Regulation (GDPR). You have the right to lodge a complaint with your local data protection authority if you believe we have processed your personal data in violation of applicable law. Our Data Protection Officer can be contacted at dpo@trademaster.io.

12 Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: TradeMaster Privacy Team Email: privacy@trademaster.io Address: TradeMaster, Inc. Legal Department [Company Address]

13 Policy Updates

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the effective date. For material changes, we will provide a more prominent notice, including notification via email. Your continued use of TradeMaster after any changes constitutes your acceptance of the updated Privacy Policy. Last updated: January 1, 2025