Trade Oracle Group Ltd

DATA PRIVACY AND PROTECTION - GDPR COMPLIANCE

Trade Oracle Group is committed to protecting your personal data and respecting your privacy rights under applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and UK GDPR.

DATA CONTROLLER INFORMATION

Data Controller: Trade Oracle Group Ltd

US Address: 2489 W Main St. Littleton, CO 80120

UK Address: 12 Hay Hill, Mayfair, London (UK) W1J8NR

Contact Email: tradeoracle@proton.me

LEGAL BASIS FOR PROCESSING

We process your personal data under the following legal bases:

●        Contract Performance: To provide our subscribed services and fulfill our contractual obligations to you

●        Legitimate Interests: To improve our services, prevent fraud, and maintain platform security

●        Consent: For marketing communications (where required and separately obtained)

●        Legal Obligations: To comply with applicable laws and regulations

PERSONAL DATA WE COLLECT

Account Information: Name, email address, phone number, billing address

Payment Information: Payment method details (processed securely by third-party payment processors - we do not store complete credit card numbers)

Usage Data: Login times, features accessed, platform settings and preferences, IP address, browser type, device information

Communication Data: Support inquiries, feedback, survey responses, correspondence with our team

DATA WE DO NOT COLLECT: We do not collect your trading positions, account balances, broker information, actual trading decisions, social security numbers, or national identification numbers (except where legally required for tax reporting).

YOUR DATA PROTECTION RIGHTS

You have the following rights under GDPR:

●        Right of Access (Article 15): Request copies of your personal data

●        Right to Rectification (Article 16): Request correction of inaccurate data

●        Right to Erasure (Article 17): Request deletion of your data (subject to legal retention requirements)

●        Right to Restrict Processing (Article 18): Request limitation on how we use your data

●        Right to Data Portability (Article 20): Receive your data in a structured, machine-readable format

●        Right to Object (Article 21): Object to processing based on legitimate interests

●        Right to Withdraw Consent (Article 7(3)): Withdraw consent for marketing at any time

●        Right to Lodge a Complaint: File complaints with your national supervisory authority

To exercise any of these rights, please contact us at tradeoracle@proton.me. We will respond within one month of your request.

DATA RETENTION

Active Accounts: We retain your personal data for the duration of your subscription plus seven years for financial and legal compliance requirements.

Closed Accounts: Minimum retention period as required by applicable tax, accounting, and legal requirements (typically 7 years).

Marketing Data: Retained until you withdraw consent or we no longer have a legitimate need.

After retention periods expire, your personal data will be securely deleted or anonymized.

INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to and processed in the United States. We implement appropriate safeguards for international transfers, including:

●        Standard Contractual Clauses (SCCs) approved by the European Commission

●        Adequate security measures including encryption and access controls

●        Contractual commitments with data processors

●        Regular review of transfer mechanisms and adequacy decisions

SECURITY MEASURES

We implement appropriate technical and organizational measures to protect your personal data, including:

●        Encryption of data in transit and at rest

●        Multi-factor authentication and access controls

●        Regular security audits and vulnerability assessments

●        Employee training on data protection

●        Incident response and breach notification procedures

However, no internet transmission is completely secure, and you transmit information at your own risk.

THIRD-PARTY PROCESSORS

We engage the following categories of third-party processors:

●        Payment processors for billing and subscription management

●        Cloud hosting providers for platform infrastructure

●        Email service providers for communications

●        Analytics services for platform improvement

All processors are contractually bound to:

●        Process data only on our instructions

●        Maintain appropriate security measures

●        Assist with data subject rights

●        Notify us of any data breaches

●        Not engage sub-processors without authorization

DATA BREACH NOTIFICATION

In the event of a data breach affecting your rights and freedoms, we will:

●        Notify the relevant supervisory authority within 72 hours of becoming aware (as required by Article 33)

●        Notify you directly without undue delay if the breach is likely to result in high risk to you (as required by Article 34)

●        Describe the nature of the breach, likely consequences, and measures taken or proposed

CHILDREN'S PRIVACY

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will delete it promptly.

AUTOMATED DECISION-MAKING

Our platform uses automated algorithms to generate trading signals and pattern predictions. However:

●        These are tools to assist your decision-making, not automated decisions about you

●        You retain full control over all trading decisions

●        No automated processing produces legal effects concerning you or significantly affects you

●        Article 22 GDPR protections for automated decision-making are not triggered by our service

COOKIES AND TRACKING

We use essential cookies necessary for platform functionality. For non-essential cookies and tracking:

●        We obtain your consent before placement

●        You can manage cookie preferences through your browser settings

●        Declining non-essential cookies will not affect core platform functionality

●        Our cookie policy provides detailed information on cookies used

SUPERVISORY AUTHORITIES

EU Users: You may lodge complaints with your national data protection authority. Contact information available at: https://edpb.europa.eu/about-edpb/board/members_en

UK Users: You may lodge complaints with the Information Commissioner's Office (ICO)

●        Website: ico.org.uk

●        Helpline: 0303 123 1113

●        Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

CHANGES TO THIS PRIVACY NOTICE

We may update this privacy notice to reflect changes in our practices, legal requirements, or service features. Material changes will be communicated via:

●        Email notification to your registered address

●        Notice displayed upon platform login

●        Updated version posted on our website

The updated notice will indicate the date of last revision. Your continued use after changes constitutes acceptance, though you may cancel your subscription if you disagree with material changes.

CONTACT FOR PRIVACY MATTERS

For all data protection inquiries, requests to exercise your rights, or privacy concerns, contact:

Email: tradeoracle@proton.me

Subject: "Privacy/GDPR Request - [Your Name]"

We will respond to your inquiry within one month, or within two months for complex requests (we will inform you if an extension is needed).

US STATE-SPECIFIC PRIVACY RIGHTS

California Residents (CCPA/CPRA): You have additional rights including the right to know what personal information is collected, the right to delete personal information, the right to opt-out of sale/sharing (note: we do not sell personal information), and the right to non-discrimination for exercising these rights.

Virginia, Colorado, Connecticut, and Utah Residents: You have similar rights under your respective state privacy laws, including rights to access, deletion, correction, and opt-out of certain processing.

To exercise state-specific rights, contact tradeoracle@proton.me with "State Privacy Rights Request" in the subject line.