Privacy Policy

In the event of any legal proceedings, disputes, complaints, reports or litigation arising out of or relating to this Privacy Policy, the English version of this Policy shall be the definitive and governing document. Any translations or versions in other languages are provided for convenience only, and in cases of inconsistency or ambiguity, the English version shall prevail and be binding.

Spotware has a published Privacy Policy, which can be found here, and has appointed a Data Protection Officer (DPO) in accordance with the requirements of the GDPR. Our DPO can be contacted at dpo@spotware.com. In addition, Spotware has implemented various complementary technical and organisational measures that are designed to protect the privacy of the personal information that we collect, store and process.

Our Privacy Policy applies to all information and data relating to living, physical persons (“data subjects”) that are collected from various channels and sources, including our website, through our products (cTrader) and in our forum (cTDN.com).

Our Privacy Policy covers the different forms of interaction you can have with Spotware and classifies you in the following ways:

1. Brokers (direct clients), prospective or actual, contacting Spotware in the context of onboarding cTrader.
2. Traders (end users) opening demo cTrader accounts with Spotware.
3. Traders (end users) using Spotware products (cTrader) with a live and/or demo account via a broker offering the cTrader platform.
4. cTrader.com forum members.
5. Spotware.com visitors.

This policy explains the following for each of the classifications described above:

• The type of information we collect.
• How we use that information.
• The retention policy of the information we collect.
• The mechanisms and tools we offer that allow you to modify or – under specific circumstances – even delete the information we collect.
• How we secure the information we collect.

Brokers (direct clients) contacting Spotware in the context of onboarding cTrader

Information we collect from you

When you contact Spotware via our contact form, we ask you to specify the method you would like us to use to contact you. For this purpose, we only require the information necessary to contact you in accordance with your wishes. For example, if you want us to contact you by Skype, we will not ask for your phone number.

When you submit the contact form, we collect the following information:

• The page you came from in order to understand what feature or product you were interested in.
• Your IP address in order to determine if the request you sent is unique and genuine.
• Your browser and device information in order to identify which environments we should optimise and test for our services.
• Location information in order to determine which sales agent should respond to your request and to localise your experience when communicating with us.

When you send an email to Spotware, we collect the details received from you in that email and store them in our CRM and our email archive.

When you make a telephone call to Spotware, we record the call.

How we use information we collect from you

We use this information to contact you and to discuss your queries. We also share this information with our sales team and retain a record of important information from the correspondence we have with you. For example, if you asked for specific features that we need to investigate and revert to at a later time or plan to develop in the future.

Our retention policy

We retain information for 24 months after our last digitally recorded correspondence with you. After this period, our retention policy requires that we delete your details from our CRM and email archive.

We retain recorded phone calls for a period of 12 months, after which the call will be permanently deleted.

Your ability to disclose, modify or delete the information we collect from you

You can contact us at any time and request us to disclose, modify or, under specific circumstances, even delete the information we hold about you.

Traders (end users) opening demo cTrader accounts with Spotware

Information we collect from you

When you open a demo account in cTrader with Spotware, we require your email address as a unique way to identify you and to provide useful features:

• Linking your trading accounts to a single ID.
• Saving cTrader-related preferences to a single ID:
  • Favourite symbols
  • Favourite strategies
  • Chart templates and settings
  • Email preferences (which events you would like to be notified about)
  • Custom hotkeys

We collect and save your preferences, which are shared and accessible to you across all the cTrader brokers with which you open a live or demo cTrader account. This is because your cTrader ID account is used to sign into the platform with all supporting brokers. Brokers cannot see any details originating from your accounts with other brokers or Spotware or even know that you own other accounts, nor can they see your preferences.

How we use information we collect from you

We collect performance-related data such as crash analytics and a variety of product usage analytics, including:

• number of open positions
• number of open orders
• number of open charts
• number of active indicators
• number of active cBots
• location
• IP address
• device or hardware specifications

Our retention policy

We keep the information we collect for a maximum period of 90 days following inactivity, i.e. if you do not sign into your demo trading account for 30 days, then within the following 90-day period, any identifiable data obtained will be deleted.

Your ability to disclose, modify or delete the information we collect from you

You can submit a formal request at any time for your data to be disclosed, modified or, under specific circumstances, even deleted. However, we may not always be able to fulfill a request for deletion, e.g. when you trade via a broker offering our products, your data belongs to that broker and the request must be managed by them in accordance with their financial regulatory guidelines and anti-money laundering obligations.

Traders (end users) using Spotware products (cTrader) via a broker offering the platform

The cTrader platform is a service provided to and operated by brokers. Spotware provides brokers with a combination of applications and components which are used to provide you with a trading platform for online trading.

Spotware specifically provides the following, which may have an effect on how you can exercise your privacy rights.

cBroker: This is an administration platform. It is an interface which is used internally by your broker for a variety of tasks, including analytics, troubleshooting and reporting. Your broker can limit access rights internally and can only permit access to authorised persons. However, your broker administers these access rights. This application allows brokers to enter and store personal information such as your name, address, ID number, contact details and more. Spotware does not require your broker to provide us with any personally identifiable information except for your email address which you used to create your cTrader ID. This application is available to Spotware personnel but is restricted on a need-to-know basis.

Databases and server: Spotware either hosts the cTrader solution on behalf of brokers or the solution is hosted on-site. However, Spotware still retains root access and the ability to access any such data at any time. This is vital to allow us to troubleshoot problems and provide support so that we can ensure a seamless experience for all traders.

Information we collect from you

Spotware collects and processes performance-related data for its own use such as crash analytics and a variety of product usage analytics, including:

• number of open positions
• number of open orders
• number of open charts
• number of active indicators
• number of active cBots
• location
• IP address
• device or hardware specifications

While providing this service, Spotware may store and have access to personally identifiable information about users. Nevertheless, we do not process or share this information with any third parties. To find out the specific information which is shared with Spotware by your broker, you must contact your broker directly because the information may vary from broker to broker.

How we use information we collect from you

Your personal information is collected in connection with the service Spotware provides to your broker.

Your ability to disclose, modify or delete the information we collect from you

In this case, Spotware is not able to take action on any requests from the public regarding the disclosure, modification or deletion of personal data. Such requests must be made to your broker and formally requested by the latter on your behalf. Please note that your broker's ability to respond may also be restricted due to the financial regulations they are subject to and which may take precedence over the GDPR.

Our retention policy

All the data we collect in connection with providing services to the broker(s) you have chosen to use are retained by Spotware as per the specific broker's retention policy. Once the broker terminates their agreement with Spotware, the broker will be able to take ownership of all the data collected by Spotware throughout the period in which the services were provided. After termination of the agreement between the broker and Spotware, all the data held by Spotware (both identifiable and non-identifiable) will be deleted within 90 days.

Spotware.com visitors

Spotware.com does not automatically collect any personal information from visitors to the website and we do not request any identifiable information by default.

Cookies

Spotware.com uses internet cookies to facilitate navigation throughout the website and to enhance the visitor's experience. Your internet browser is likely to accept these cookies by default. However, you can refer to your browser’s help guide if you would like to reject or to delete them from your system.

We may use both “session” cookies and “persistent” cookies on the website. We use the session cookies to track you while you navigate the website in addition to other purposes. We use the persistent cookies to enable our website to recognise you when you visit in addition to other purposes.

Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted or until they reach a specified expiry date.

Cookies used by spotware.com do not retrieve any personal information or any information from the visitor’s computer.

Pixels

Spotware.com has several third-party pixels installed in order to use the retargeting features of advertising platforms such as Google Ads, Facebook and Adroll. Pixels are also used for certain analytics such as heatmaps to learn how users interact with our site and to identify flaws in the user experience and navigation. We currently use Yandex heatmaps.

Pixels used by spotware.com do not retrieve any personal information or any information from the visitor’s computer.

cTrader.com Forum members

About the site

cTrader.com is a public forum. The information on this site is either submitted by Spotware or by registered users of the site. The information posted here is public to anyone and visible to search engines.

Information we collect from you

When you post on this site, you consent to the fact that anyone can see your username and the information and opinions expressed in what you post.

Your ability to disclose, modify or delete the information we collect from you

You cannot delete your post once submitted, it can only be edited. Only site admins have the ability and authority to delete posts when a post violates the policy of the site. You are able to update your username at any time. Your username is shown next to the posts you submit. While your comments cannot be deleted, they can be made anonymous by changing the username to “Deleted User” when you request us to delete your account. However, the post will remain in its most updated form because removing it would disrupt the flow of the conversation.

The trading robots and custom indicators you submit to the site can be withdrawn at any time.

How we secure the information we collect from you

The measures we employ include logical access controls and user management which are intended to mimimise access to personal (and other customer) information and data to authorised Spotware personnel only. We implement robust user access credentials management with enforced frequent changes, password complexity and maximum/minimum lengths, restrictions on reuse of the same passwords, etc., complemented by a structured process for periodic reviews and confirmation of the continued business need for such personal data. In addition, Spotware uses purpose-specific technologies and tools (such as firewalls, intrusion prevention, email security gateways, etc.) that are designed to monitor and to manage the security of its electronic perimeter. Spotware has in place an active and ongoing patch management programme across security, server and endpoint devices for addressing newly released threats and uses endpoint malware protection at laptop, server and desktop level. Finally, we also use endpoint encryption to protect against privacy risks in the event of hardware theft or loss.

Third parties

This section describes the third-party products or solutions used by Spotware and the context in which they are used.

Gmail from Google

If you email Spotware, your email correspondence may be visible to Google.

MailChimp

If you have given your consent to be subscribed to one of our mailing lists, your email address, first name and last name will be shared with MailChimp in order to send emails to you.

Brevo

If you have given your consent to be subscribed to one of our mailing lists, your email address, first name and last name will be shared with Brevo in order to send emails to you.

SparkPost

If you have opted in to receive email notifications for trading-related events, your email address, cTrader ID username as well as the trading-related details disclosed in the template are shared with SparkPost.

Mandrill

If you have opted in to receive email notifications for trading-related events, your email address, cTrader ID username as well as the trading-related details disclosed in the template are shared with Mandrill.

Pipedrive

If you have contacted Spotware as a broker (direct clients) in the context of onboarding cTrader, your details have been stored in Pipedrive in accordance with this privacy policy.

FreshDesk

When you email support@spotware.com, the email is routed to the FreshDesk ticketing system.

Data Protection Officer (DPO)

Spotware Systems has outsourced the responsibilities of its Data Protection Officer to PhoenixPro. Below is the contact information of our DPO, to whom all privacy-related correspondence should be directed.

Georgios A. Korellis

PhoenixPro Ltd

dpo@spotware.com

+357 22255333