Effective Date: 4.07.2018
Thanks for visiting DARA TRADE! DARA TRADE ( “we”, “us” or “our”) respects your privacy. When it comes to your personal information, we believe in transparency, not surprises. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights.
1. Some key terms
3. Personal information we collect
We collect various personal information regarding you or your device. This includes the following:
- Information you provide to create an Account, specifically email address, first name and last name, forex broker you use. If you sign up for Paid Services, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card) and we ask you to select your jurisdiction.
- Your marketing preferences.
- The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our site is available to others.
- Information you share with us in connection with surveys, contests or promotions.
- Information from your use of the Services and website. This includes: IP addresses, preferences, web pages you visited prior to coming to our site, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services.
- Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
- Other information you submit to us directly or through Third Party Services (such as aForex broker)
- Information about your trading account number and account type (no trading account passwords are collected or stored)
- Information about your trading activity such as trades you have placed on your trading account.
4. How we collect personal information
We obtain personal information from various sources. We do this in three main ways:
- You provide some of it directly (such as by registering for an Account).
- We record some of it automatically when you use our Services and webiste (including with technologies like cookies).
- We receive some of it from third parties (like when you register for a trading account using a Forex Broker or when you make payments to us using our payment processor).
We’ve described this in more detail below.
a. Personal information you provide
When you use our Services, we collect information from you in a number of ways. For instance, we ask you to provide your name and email address and your brokers name to register your Account. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions.
Sometimes we require you to provide us with information for contractual or legal reasons. For example, we may ask you to select your jurisdiction when you sign up for Paid Services to determine if, and how much, tax we need to collect from you. We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you will not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
b. Personal information obtained from your use of our Services
When you use our Services, we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages you visit and for how long and identifiers associated with your devices.
We collect information about your trading activity on or servers such as when did you log in to VPS, what IP address was used and for how long user was logged in to the VPS, are your trading robots running and what trades you have placed on your trading account along with your trade account number (we don't store trade account passwords). This is so we can provide the assistance and service to you about our trading robots. This information is collected automatically and reviewed by our Staff when necessary.
c. Personal information obtained from other sources
If you use a Third Party Service (such as Forex Broker) to register for an Account, the Third Party Service may provide us with your Third Party Service account information on your behalf, such as your name, email address and your trade account number (we don’t store passwords you use to access Third Party Services). Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service.
5. How we use your personal information
We use the personal information we obtain about you to:
- Provision of the Services. Create your Account, provide and personalize our Services, process payments and respond to your inquiries.
- Communicating with you. Communicate with you, including by sending you emails about your transactions and Service-related announcements.
- Surveys and contests. Administer surveys, contests and other promotions.
- Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions of DARA TRADE and our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on your subscription plan or what we think may interest you based on other information we hold about you.
- Advertising. Analyze your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for Paid Services or we may choose to serve you a particular advertisement based on your subscription plan or what we think may interest you based on other information we hold about you.
- Improving our Services. Analyze and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. For example, if we learn that most Users of Paid Services use a particular integration or feature, we might wish to expand on that integration or feature.
- Security. Ensure the security and integrity of our Services.
- Third party relationships. Manage our vendor and partner relationships.
- Enforcement. Enforce our Terms of Service and other legal terms and policies.
- Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).
- Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.
We process your personal information for the above purposes when:
- Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.
- Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign in to our members area.
- Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
- Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
- To operate the DARA TRADE business and provide you with tailored advertising and communications to develop and promote our business.
- To analyze and improve the safety and security of our Services - we do this as it is necessary to pursue our legitimate interests in ensuring DARA TRADE is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.
- To provide and improve the Services, including any personalized services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.
- Protecting you and others. To protect your vital interests, or those of others.
6. How we share your personal information
We share personal information in the following ways:
- Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.
- Users. We share with our Users data regarding you. For example, we provide a User with information about your FXBLUE link if you have provided one. This is so Users can analyze the trading stats and performance.
- Business partners. We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing.
- Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.
- Process payments. We transmit your personal information via an encrypted connection to our payment processor.
- Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms of Service) or prevent fraud or abuse of DARA TRADE or our Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
- Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third party social media platform on which we advertise to avoid serving DARA TRADE ads to people who already use DARA TRADE.
7. Your rights and choices
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.
You can access, update, change or delete personal information either directly in members area or by contacting us at firstname.lastname@example.org to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address.
You can also elect not to receive marketing communications by changing your preferences in members area or by following the unsubscribe instruction in such communications.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law.
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
8. How we protect your personal information
While no service is completely secure, we have a security team dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders.
9. How we retain your personal information
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread.
10. Data transfers
Personal information that you submit through the Services may be transferred to countries other than where you live, such as, for example, to our servers in the U.S. We also store personal information locally on the devices you use to access the Services. Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.
15. How to contact us