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Table of Contents
PRIVACY POLICY FOR THE PAPER TRADER PLATFROM .................................................................. 3
1. DEFINITIONS .............................................................................................................................. 3
2. ELIGIBILITY ................................................................................................................................. 7
3. PT: MAKE TRADE EASY – CODE OF CONDUCT ............................................................................ 9
4. WHO WE ARE ........................................................................................................................... 10
5. TO WHOM DOES THIS PRIVACY POLICY APPLY ....................................................................... 10
6. PERSONAL DATA WE PROCESS ............................................................................................... 11
7. HOW WE USE YOUR PERSONAL DATA ..................................................................................... 13
8. USE OF OUR WEBSITE(S) AND E-MAILS ................................................................................... 15
9. ON WHAT BASIS DO WE USE YOUR PERSONAL INFORMATION ............................................... 16
10. HOW DO WE OBTAIN YOUR PERSONAL DATA ......................................................................... 17
11. WHO WE SHARE YOUR PERSONAL DATA WITH ....................................................................... 17
12. COUNTRIES WE SHARE YOUR PERSONAL DATA TO ................................................................. 19
13. HOW WE RETAIN YOUR PERSONAL DATA ............................................................................... 19
14. HOW WE PROTECT YOUR PERSONAL DATA ............................................................................. 20
15. AUTOMATED INDIVIDUAL DECISION-MAKING ........................................................................ 21
16. YOUR RIGHTS ........................................................................................................................... 21
COOKIE POLICY ......................................................................................................................... 22
1. WHAT ARE COOKIES .............................................................................................................. 22
2. COOKIES ON OUR WEBSITE.................................................................................................... 22
3. WHAT DO COOKIES DO .......................................................................................................... 23
TERMS OF USE OF OUR WEBSITE(S) ........................................................................................... 25
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PAPER TRADER PLATFORM PRIVACY POLICY
PRIVACY POLICY FOR THE PAPER TRADER PLATFROM
Privacy Policy for the Paper Trader Platform
This agreement and all terms incorporated by reference herein (our “Privacy Policy”) apply to
your use of the Paper Trader electronic price matching platform (“Platform”) operated and
maintained by Paper Trader Platform Pte. Ltd. (“Company”, “we”, or “us”), which facilitates
the posting, viewing, selection, and acceptance of bids and offers for price matching between
users on the Platform (“Transactions”) and/or other services provided by the Company through
or in connection with the Platform (collectively, the “Services”) for physical sale and purchases
of Tradable Products (as defined below) of the Platform.
This Privacy Policy informs you about how Paper Trader Platform Pte Ltd handles your personal
data. This Privacy Policy applies to the processing of the personal data from (the contact
people at) our clients, business relations and referrers, recipients of our communications , and
We may amend this Privacy Policy from time to time, if there are changes to how we process
your personal data, for instance, or if this is necessary based on regulations. We shall inform
you of essential changes.
Please read this Privacy Policy carefully. By accessing or using any Services made available by
us, you agree to be legally bound by these Terms and Conditions.
Any decision to be made by us or actions that we may take in these Terms and Conditions may
be made at our sole discretion.
1. DEFINITIONS
Unless otherwise defined in these Terms and Conditions, capitalized terms shall have the meanings
assigned to them in this document. If a term is not explicitly defined, it shall be interpreted in
accordance with general market practice. When in doubt, contact us before signing the agreement:-
“Account” means a user account created by the Company for a User in order to enable such User to
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access the Platform and the Services;
“AML/CFT Policy” shall have the meaning given to it in Clause 2.3;
“Bid” means the listing of an intention by a Buyer to price match on the Platform an offer to buy
Tradable Products off the Platform, such offer comprising the Offer Terms and being a legally
binding offer which is capable of acceptance;
“Buyer” means the User who makes a Bid of Tradable Products on the Platform;
“Commodities” means any technically specified commodity products presented on the Platform,
and any other products that the Company accepts as “Commodities” for the purposes of these
Terms and Conditions from time to time and as notified over the Platform;
“Company” means Paper Trader Platform Pte Ltd, company number 202033836M, a company
incorporated in Singapore whose registered office is at 18 NATHAN ROAD, #04-08 NATHAN PLACE,
SINGAPORE (248747) Singapore. This can also be referenced to with “PT” or “PT: Make trade easy”,
or similar in documents, communication and marketing efforts;
“Licensee” is the User with whom the Company has a SLA that allows them to market the Platform
under any Platform sub-brand;
“Matched Counterparty” means, with respect to a Seller or Buyer (as the case may be), any relevant
counterparty who selected and accepted such Seller’s Offer or such Buyer’s Bid (as the case may be),
and as recorded by the Platform;
“Offer” means the listing of an intention by a Seller to price match on the Platform an offer to sell
Tradable Products off the Platform, such offer comprising the Offer Terms and being a legally
binding offer which is capable of acceptance;
“Offer Terms” means price, quantity, packing type and payment terms, and such other terms as the
Company may, from time to time and in its discretion, direct;
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“Person” includes an individual, a body corporate, an association of persons (whether corporate or
not), a trust, a government department, or any other entity;
“Platform” is the Paper Trader Platform Software being the software owned by us (and marketed via
our Licensees) that is used to provide the Service;
“Restricted Locations” shall have the meaning given to it in Clause 2.1;
“Seller” means the User who makes an Offer of Tradable Products on the Platform;
“Service” means the service as mentioned in the preamble and having the core functionality
described on the Website, as the Website is updated from time to time;
“Buyer/Supplier/Broker SLA” means the service level agreement entered between the Company
and a Buyer / Seller / Broker who intends to make Bids and/or Offers of Tradable Products on the
Platform;
Terms and Conditions for the usage of the Platform solely and is limited to facilitating the price
discovery leading to a price match only. As the Platform as a legal entity, is not a participant in any
price match, we recommend all users (being trading companies, white label brokerage partners, and
individual persons) to share their (local) terms and conditions for trade, buying, or selling with all
Matched Counterparties and consults them to request a signed document back according to the
requirements of local laws. These additional Terms and Conditions do not apply to the actual
exchange of Commodities, their Offer Terms, and financial balancing to finalize the Transaction, nor
to this agreement of the usage of the platform;
“Tradable Product” shall have the meaning given to it in Clause4.1 of the T&C (Conditions of Usage);
“Transaction” means a successful price match through the Platform arising from the acceptance of a
and shared between Users;
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“User” means a Person for whom the Company is maintaining or continuing to maintain one or more
Account(s) for the Services, regardless of whether it is acting as Buyer, Seller, Broker or, any other
type of actor;
“We”, “us” or “our”, means The Company, as defined under the above definitions;
“You” or “your” means you as User; and both, you and the other Person on whose behalf you are
acting.
Words in the singular include the plural and vice versa.
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2. ELIGIBILITY
2.1. The Company may not make the Services available in all markets and jurisdictions and may
restrict or prohibit the use of the Services in such markets and jurisdictions as the Company
may, from time to time and at its discretion, determine (“Restricted Locations”).
2.2. You, the User, represent and warrant that you: -
2.2.1. Are duly organized, validly existing, and in good standing under the laws of your
jurisdiction of organization.
2.2.2. Have not previously been suspended or removed from using our Services or
other similar services provided by other parties.
doing so will not violate any other agreement to which you are a party;
2.2.4. Are not located in, under the jurisdiction of, or a national or resident of any
Restricted Locations (as defined in Clause 2.1 above).
2.2.5. Will not use our Services if any applicable laws in your country prohibit you
2.2.6. Have, always, all requisite permits, licenses, consents or approvals required to
carry out your obligations hereunder, and under any transactions contemplated in
connection with the Platform.
2.2.7. Will not use any robot, spider, scraper, data mining tools, data gathering and
extraction tools, or other automated means of accessing the Services for any
purpose, except with the prior written consent of the Company.
2.2.8. Are not a designated person under regulations issued pursuant to the United
Nations Act (Cap. 339 of Singapore).
2.2.9. Are duly authorized by a User to be active on the Platform on behalf of this
Person.
2.3. The Company may, from time to time and in its discretion, create and maintain an anti-
money laundering, countering the financing of terrorism, and know your customer
compliance policy (“AML/CFT Policy”). Pursuant to such AML/CFT Policy, the Company may
further, from time to time and at its discretion, require identity verification and go through
other screening procedures with respect to the User or Transactions associated with the
User’s Account.
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2.4. The User agrees and undertakes to provide the Company with any and all information and
documents that the Company may from time to time request or require for the purposes of
these Terms and Conditions or in connection with the User’s Account (including, but not
limited to, the User’s name, address, telephone number, email address, certificate of
incorporation, constitutional document, memorandum and articles of association, board
resolution authorizing the opening of the Account, and information regarding the Account).
2.5. The Company will have no liability or responsibility for any permanent or temporary
inability to access or use any Services because of any identity verification or other screening
procedures.
2.6. The Company will have no liability or responsibility for any permanent or temporary
inability to access or use any Services because of any technical downtime.
2.7. The User agrees that the Company shall always have the right to collect, use, process, and
disclose all such information provided to the Company for the purposes of its provision of
the Services or to comply with all laws or requests from regulatory or governmental
authorities.
2.8. The User represents and warrants that where it discloses any personal data to the
Company, the User has obtained all applicable consents from the owner of such personal
data for the collection, processing, use, and disclosure of his or her personal data for the
purposes of carrying out its obligations or exercising its rights under the T&C (Conditions of
policies and meeting any obligation to or requests from governmental entities, agencies,
regulatory authorities or similar, including, without limitation, anti-money laundering and
anti-terrorist obligations, as the Company deems necessary.
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3. PT: MAKE TRADE EASY – CODE OF CONDUCT
3.1. Legal Compliance
3.1.1.All users, brokers, and transactions on PT: Make trade easy must comply with
applicable Singapore law. If a user operates outside Singapore, they must also comply
with local laws, provided they do not conflict with Singapore law.
3.2. Market Access
3.2.1.PT: Make trade easy imposes no restrictions on user access based on nationality,
location, or business type, as long as all activities comply with the legal requirements
outlined in this Code of Conduct.
3.3. Legality of Transactions
3.3.1.All products traded on the platform must be 100% legal under both Singapore law and
the laws of the parties involved.
3.3.2.All users (buyers, sellers, and brokers) must ensure that their participation in trades is
legally permitted.
3.3.3.If a product or transaction is subject to regulatory approvals, licenses, or permits, it is
the responsibility of the parties involved to obtain them.
3.4. Compliance Responsibility
3.4.1.Users and executing brokers are fully responsible for ensuring that all trades comply
with applicable laws and regulations.
3.4.2.PT: Make trade easy does not take liability for legal or regulatory breaches by users or
brokers.
3.5. Enforcement & Consequences
3.5.1.PT: Make trade easy reserves the right to suspend or terminate access to users or
brokers found in violation of this Code of Conduct.
3.5.2.Any disputes or legal matters arising from transactions will be handled following
Singapore law and, where applicable, the relevant local laws.
3.6. By using PT: Make trade easy, all users and brokers agree to this Code of Conduct and
acknowledge their legal responsibilities.
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4. WHO WE ARE
4.1. The controller for the processing of your personal data is Paper Trader Platform Pte Ltd
References in this privacy notice (“the Notice”) to “Paper Trader”, “PTPL”, “PT”, “we” or
“us” are references to:
Paper Trader Platform Pte Ltd
Company number: UEN 202033836M, a company incorporated in Singapore
registered office: 18 NATHAN ROAD, #04-08 NATHAN PLACE, SINGAPORE (248747)
Telephone: +316.1905.6888
Email: info@paper-trader.com
5. TO WHOM DOES THIS PRIVACY POLICY APPLY
5.1. This Privacy Policy applies to everyone who visits our website, platform, mobile app,
and other applications and to people whose personal data are processed by PTPL in
the context of the provision of its services.
5.1.1. Contact persons at our (potential) clients;
5.1.2. Contact persons at our business relations;
5.1.3. Contact persons at our referrers;
5.1.4. Recipients of our communications, such as our newsletters and invitations to
events organised by or in cooperation with PTPL and our partners;
5.1.7. People who contact us otherwise or whose personal data we process otherwise
in the context of our service provision.
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6. PERSONAL DATA WE PROCESS
6.1. We collect this information when you interact with us, for example when you
communicate with our staff, complete our contact forms, sign up to receive
information by e-mail, or visit our website. We also collect or generate personal data
in the course of providing our services;
6.2. The personal data we process in relation to you are:
6.3. Personal data you have provided to us;
6.4. Personal data that give insight into the use of our website or other electronic means of
communication;
6.5. Personal data obtained from other sources;
6.6. Personal data provided by you:
6.7. Contact details and other personal data. These include details such as your name and
(details of) your identification documents (identification data), and other basic
information;
6.8. Contact details and other personal data filled in on contact forms or other web forms.
The precise content of the data depends on the content of the contact forms and web
forms;
6.9. Contact details provided during initial meetings, events, seminars, etc. These may
include details provided on business cards;
6.10. Other personal data that are provided by you;
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6.11. Personal data that give insight into the use of our website or other electronic means
of communication. These could include data such as:
6.11.1. IP address (unique number identifying your device when you connect with the
internet), which we use to measure your interest in our website;
6.11.2. Information in relation to materials and communications we send to you
electronically, for example your use of marketing emails. For example, the
opening and reading of a newsletter or commercial email. This also includes
clicking behaviour in the email or newsletter. In this context, we also refer to our
Cookie Policy;
6.12. Personal data obtained from other sources:
6.13. Personal data available on public professional social media platforms such as
LinkedIn. These are names and contact details;
6.14. Personal data obtained from the Trade Register of the Chamber of Commerce. This
could include a Chamber of Commerce number and contact details; and
6.15. Personal data available on public professional websites, such as company websites.
6.16. Any activity on the platform such as bids, offers or transactions that could relate back
to you as entity or as individual user.
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7. HOW WE USE YOUR PERSONAL DATA
7.1. You are generally under no obligation to disclose personal data to us, unless you have a
contractual relationship with us which foresees such obligation. Yet, in order to conclude
and perform a contract, we must collect and process the personal data which is necessary
for such conclusion and for the fulfillment of the contractual and associated obligations as
well as for the fulfillment of legal obligations.
7.2. Moreover, when using a website, it is necessary to process log data and certain other data.
Also, in relation to communications between you and us, we must process at least the
personal data that you provide to us or that we provide to you.
7.3. We may use your personal data for the following purposes. We use your personal data:
7.3.1.To stay in contact with you and communicate with you. We feel it is important to
contact you with information that is relevant to you. We combine and analyse the
personal data available to us to be able to do so. Based on this, we determine what
information and channels are relevant and which moments are most suitable for
providing information or making contact. In conducting marketing campaigns, we do
not process any special personal data or any confidential data;
7.3.2.To provide, perform, and improve our services to you and our customers, including the
personal data of others;
7.3.3.Provided to us or collected by us on behalf of our clients, for example, processing
identification and background information as part of our onboarding, finance,
administration, and marketing processes;
7.3.4.To administer our relationship with you and with our customers;
7.3.5.To invoice for services rendered;
7.3.6.To promote our services, including by sending alerts, updates, event invitations, etc.;
7.3.7.To inform you about our services and products;
7.3.8.To conduct client satisfaction surveys;
7.3.9.To improve and secure our website;
7.3.10. To prepare user statistics. The user statistics from the website enable us to get a
picture of, among other things, the number of visitors, the duration of the visit, what
parts of the website are viewed, and the clicking behaviour of visitors. These are
generic reports without any information on individual persons. We use the information
obtained to improve the website.
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7.3.11. To prepare analyses. To prepare analyses we use:
7.3.11.1. Interaction data: Personal data obtained from contact between PTPL and you.
For example, on your use of our website or supporting applications. This also
applies to offline interactions, including how often there is contact between PTPL
and you.
7.3.11.2. Behavioural data: Personal data that PTPL processes on your behaviour, such
as your preferences, opinion, wishes, and needs. We can derive this data from
your browsing behaviour on our website, for instance, the reading of our
newsletters or because you requested information. But also, from inbound
telephone conversations and email contact with our employees. See also our
Cookie Policy.
7.3.12. To comply with our legal, regulatory, and risk management obligations, including
performing audits, establishing, exercising, or defending legal claims.
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8. USE OF OUR WEBSITE(S) AND E-MAILS
8.1. When you use our website, we automatically collect metadata about your browsing session
such as your browser, the IP address of your computer, your internet service provider, the
site from which you navigated to our website, the duration of your visit to our website and
what type of device you are using (e.g. a computer, a smartphone or a tablet and the
respective operating system). We also keep a record of the pages that you view during your
visit. This information is used to improve the way in which our website operates, for
statistical and systems administration purposes.
8.2. Our website uses Google Analytics, a service provided by Google, Inc. that tracks and
reports on the way our websites are used. Google Analytics does this by placing small text
files called “cookies” on your computer or other device. Cookies collect information about
the number of visitors to the websites, the pages visited, and the time spent on the
websites. Based on this information we receive analyses from Google. Google stores this
information in the USA. You can prevent the use of Google Analytics through a “Browser
8.3. PTPL uses cookies on its website. A cookie is a small text file that a web browser saves to
your computer. You can block the use of cookies generally by changing your browser
settings accordingly. This could affect the functioning of the website, however. For more
information, please see our Cookie Policy.
8.4. You may refuse the use of cookies by selecting the appropriate settings on your browser.
Note however that this may affect your experience of our websites. To find out more about
8.5. We may use your name and e-mail address(es) to send you alerts, updates, event
invitations and other information by e-mail, but will ask for consent first unless we have
obtained your contact details from you in the context of our services. If you receive
marketing communications from us and no longer wish to do so, you may unsubscribe at
any time by following the link included in these e-mails. Note that we use personal data to
understand if you read our e-mails or click on links included in them.
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9. ON WHAT BASIS DO WE USE YOUR PERSONAL INFORMATION
9.1. We process your personal data only when this is permitted on grounds of one of the legal
bases cited in the General Data Protection Regulation (GDPR). We process personal data on
the following legal grounds:
9.1.1.The processing is necessary in order to establish a contract or in the run-up to the
establishment of a contract;
9.1.2.For legitimate interests. We may also process personal data if we have a legitimate
interest, and this does not breach your privacy disproportionately. For example, we
use your contact details to invite you to seminars and events, for instance. We also
have a legitimate interest if we use your personal data to contact you after you have
approached us yourself. We do not always need permission to contact you.
9.1.3.If we obtain your email address because of providing services, we can offer you similar
services via direct marketing. In that case, we have a legitimate interest in offering you
these services. This also includes, for example, the interest in customer care and
communication with customers outside of a contract; in marketing activities; in getting
to know our customers and other people better; in improving products and services
and developing new ones; in combating fraud, and the prevention and investigation of
offenses; in the protection of customers, employees and other persons and data,
secrets and assets of PTPL; in the guarantee of IT security, especially in connection with
the use of websites, apps and other IT infrastructure; in the guarantee and
organization of business operations, including the operation and further development
of websites and other systems; in company management and development; and in the
enforcement or defence of legal claims;
9.1.4.Statutory obligations;
9.1.5.Based on a consent, where such consent was obtained separately:
9.1.5.1. We ask your consent for participation in a client satisfaction survey.
9.1.5.2. We ask your consent for direct marketing purposes, which will be specified in
detail when you give your consent. More information on this above 9.1.3.
9.2. If we have requested and obtained your consent to process your personal data, you have
the right to withdraw such consent at any time. You can do this by contacting us via email
9.3. Please see “How we process your personal data” above for additional details.
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10. HOW DO WE OBTAIN YOUR PERSONAL DATA
10.1. We obtain some information automatically when you visit our website. We collect this
information via cookies, for instance. In this context, we also refer to our Cookie Policy.
10.2. We obtain other information if you actively provide it to us. For example, if you are or
become our client or if you sign up for newsletters or events.
10.3. We also obtain information from third parties, such as personal data from the Trade
Register of the Chamber of Commerce, or personal data available on public professional
websites. We also obtain information from professional social media sources like LinkedIn.
11. WHO WE SHARE YOUR PERSONAL DATA WITH
11.1. Your personal data are only accessible to people at PTPL authorized to access them on a
‘need-to-know’ basis. Outside of the situations mentioned in this Privacy Policy, we will not
disclose your personal data unless we deem this disclosure necessary in order to satisfy our
statutory obligations, to protect our rights or someone else’s rights, or to enforce
compliance with this Privacy Policy.
11.2. Sometimes it is necessary to share your personal data with third parties. Depending on the
circumstances of the case, this may be necessary. There are also statutory obligations which
mean that personal data must be passed on to third parties.
11.3. We will share your personal data with trusted third parties including:
11.3.1. Business management services (e.g. accounting or asset management);
11.3.2. Consulting services, e.g. services of tax consultants, lawyers, management
consultants, and consultants in the field of personnel recruitment and placement;
11.3.3. IT services, e.g. services in the areas of data storage (hosting), cloud services,
sending e-mail newsletters, data analysis and refinement etc.;
11.3.4. Credit and background check or debt collection agencies, e.g. if you are interested to
become our client or if due receivables are not paid.
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11.4. For the purposes set out in this Policy and where necessary, we may share personal data
with courts, regulatory authorities, government agencies, and law enforcement agencies.
While it is unlikely, we may be required to disclose your information to comply with legal or
regulatory requirements. For example, if a court order requires us to provide personal data
to third parties, we must comply with that. We will use reasonable endeavours to notify
you before we do this, unless we are legally restricted from doing so. Personal data may
also be provided to third parties in the event of a reorganization or merger of our business
or sale of (part of) our business.
11.5. If we look to use your personal data for a new purpose, beyond what it was originally
provided for, we will ask for your explicit consent.
11.6. We may engage service providers (processors) for the processing of your personal data,
who process personal data exclusively on our instructions. We conclude processing
agreements with these processors which fulfill the requirements of the General Data
Protection Regulation (GDPR). For example, we work with service providers who provide
SaaS (software as a service) solutions or hosting services. There are also ICT service
providers who help us keep our systems secure and stable. We also use third-party services
to send newsletters and commercial emails.
11.7. Your personal information will not be shared with third parties/affiliates for
marketing/promotional purposes.
11.8. Our Designated Data Protection Officer is the entity that handles and protects all our Data
legal entity with UEN 201528898G.
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12. COUNTRIES WE SHARE YOUR PERSONAL DATA TO
12.1. When your personal data is processed, your personal data may be shared with third
parties. We may transfer your personal data to recipients abroad, including in countries
that do not provide the same level of protection as Singapore law. Before we do so we will
implement appropriate measures to protect your personal data, for example by requiring
the recipient to agree to data processing agreements (if you would like to receive a copy of
these agreements, please contact us at the address indicated above).
12.2. These agreements are usually based on the Singapore and/or EU standard clauses, which
12.3.We can transfer these data if this is necessary to perform the contract for the provision of
our services. We may also transfer personal data with your explicit consent and in certain
other situations as permitted by applicable law.
13. HOW WE RETAIN YOUR PERSONAL DATA
13.1. We retain your personal data for as long as it is necessary for the purposes for which the
data is collected, and as long as we have a legitimate interest in keeping personal data, for
example, to enforce or defend claims or for archiving purposes and IT security.
13.2. We also retain your personal data as long as it is subject to a legal retention obligation. We
will delete your personal data if you have withdrawn your consent or have decided to opt-
out.
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14. HOW WE PROTECT YOUR PERSONAL DATA
14.1. We use various technical and organisational measures to help protect your personal data
from unauthorised access, use, disclosure, alteration, or destruction.
14.2. To ensure the security of your personal data, we have taken the following technical and
organisational measures, among other things:
14.3. Availability and continuity: We do our utmost to ensure optimal availability and continuity
of our website and our systems.
14.4. Physical security: Our building is secured by physical access control and camera security.
Only people authorized to access our building may enter.
14.5. Authorisations: The access to our systems is protected via role-based security.
14.6. Monitoring of our systems: Our systems are constantly checked for suspicious behaviour
14.7. Threat protection: Various systems have been put in place to prevent unauthorized access
and exchange of personal data.
14.8. GDPR design: Every new system we consider adopting must be tested in advance for the
principles of privacy by design and privacy by default.
14.9. Data Protection Impact Assessments (DPIA): Before we put a new system into use, we will
also subject that system to a data protection impact assessment, if required by law.
14.10. Data Leaks: We have a dedicated partner (Creatella) to detect and report data leaks.
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15. AUTOMATED INDIVIDUAL DECISION-MAKING
15.1. “Automated individual decision-making” means decisions made automatically, i.e. without
relevant human influence, which have a negative legal effect or other similarly negative
effects on you. We will inform you separately if we should use such automated decisions in
individual cases as far as this is required by law.
16. YOUR RIGHTS
16.1. You are entitled to ask for details of the information we hold about you and how we
process it and to receive a copy of your personal data. You may also have your data
rectified or deleted, restrict our processing of that information, and object to the processing
of your personal data.
16.2. You have the right to have certain personal data relating to you erased and to have your
personal data transferred to another party.
16.3. You may also choose to withdraw your consent. Please note that even after you have
chosen to withdraw your consent, we may be able to continue to process your personal
information to the extent required or permitted by law.
16.4. For more information on the rights you can exercise on the basis of the privacy regulations,
rights under the privacy regulations. You may also lodge a complaint in relation to our
processing of your personal data with a local supervisory authority.
16.5. For EU based users, you can get more information, or contact the “Autoriteit
16.7. For US based users, there is not a single, comprehensive data protection authority
equivalent to the GDPR. Instead, enforcement is fragmented. Our applicable agency is the
us to explain more about your specific requirements.
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16.8. For the sake of GDPR compliance, our European Representative for all users is the
brokerage firm that your signed up with, and that is providing you access to the markets
you are active in. If these markets are not Europe based, but you are, our Representative is
Bloemendal Consults B.V. A Netherlands based legal entity with registration KvK 24337448.
For our UK users, the GDPR Representative is Trade Services London (TSL), a UK based legal
entity registered as Voidgate Ltd Registered Cardiff, UK - No. 1559723.
16.9. Should you have a request regarding the processing of your personal data you may contact
us via email or telephone via the following contact details:
Paper Trader Platform Pte Ltd
Tel +31 61 905 6888
Email info@paper-trader.com
16.10. We must ensure that your personal information is accurate and up to date. Therefore,
please advise us of any changes to your information by contacting us via your dashboard, or
at the email address indicated above.
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COOKIE POLICY
In this Cookie Policy, we explain what cookies are, which cookies are used on the PTPL website, what
they do, how you can refuse or allow cookies, and how you can contact us.
This Cookie Policy may be revised, for example if we start using other cookies or if the relevant
legislation changes. We will inform you about substantial changes.
1. WHAT ARE COOKIES
1.1. Cookies are tiny (text) files that are placed on your computer, tablet, smartphone, or other
electronic device (hereinafter “computer”) when you visit a web page.
1.2. When a cookie is on your computer your computer can be recognised, and information can
be collected. This information might include: the IP address, data about surfing habits, such
as first, next, and current visit, the specific web pages you have visited, the manner in which
the website is navigated, the device you use and your settings. For further information, also
see the cookie tables.
1.3. Cookies are valid for a certain period after they are placed on a computer. After the period
of validity lapses the cookie is removed by the browser.
1.4. The period of validity of certain cookies is just as long as the duration of the browser
session, but there are cookies that are valid for longer, so that they can also be read during
a following visit to our website.
1.5. Cookies can be placed by PTPL as well as by third parties. Insofar as we collect personal data
about you, we process these in accordance with our Privacy Policy.
2. COOKIES ON OUR WEBSITE
2.1. The following cookies are placed via our website:
2.1.1.Functional (essential) cookies; and
2.1.2.Analytical cookies.
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3. WHAT DO COOKIES DO
3.1. Functional (essential) cookies:
3.1.1.We use functional cookies. These are essential for the proper layout and navigation of
the website and for us to remember whether cookies have been allowed or refused.
These are our own cookies and can only be read out by duly authorized employees of
PTPL. The data we collect via these cookies are not shared with third parties, except
where there is a legal obligation for us to do so.
3.1.2.Because functional cookies are essential for using the website, they may be placed
without consent.
3.2. Analytical cookies:
3.2.1.Analytical cookies record how visitors use our website. This information allows us to
analyse the use of our website and generate anonymous user statistics and reports.
We use this knowledge to improve our marketing activities and also the quality,
effectiveness, and user-friendliness of our website.
3.2.2.To do this we use the Google Analytics service. As the provider of this service, Google
Inc. (Google)places analytical cookies via our website.
3.2.3.In line with the Data Protection Agency, we have set the Google Analytics cookies to
‘privacy friendly’. This means that your IP address is partly masked and the option for
sharing data is disabled. This way these cookies only have a slight impact on your
privacy, and they can therefore be placed without consent.
Moreover, Google offers the option of disabling data collection within the framework
of Google Analytics, by means of the Google Analytics Opt-out Browser Add-on. Click
uses cookies and about Google’s privacy policy.
3.2.5.We are not responsible for Google’s privacy and/or cookie policy.
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3.3. Allowing, refusing, and removing cookies
3.3.1.We do not use cookies that require your permission.
3.3.2.If you use our website, a banner will appear during your first visit to our website
whereby you have the option to use or no longer use our website whereby an explicit
reference is made to our Privacy and Cookie Policy.
3.3.3.We assume that you agree with the content of our Privacy and Cookie Policy when you
click on “Ok” and continue to use our website.
3.3.4.Moreover, you can manage your cookies by means of your browser settings. You can
set the settings in your browser in such a way that no cookies are stored, that you can
allow or refuse every cookie, or that all cookies are removed when you close your
browser.
3.3.5.Cookies are placed on every computer with which you visit websites. If you wish not to
receive any cookies whatsoever anymore, you must change the settings on all the
computers you use. Please note: if you refuse or remove cookies this could also
influence the functional cookies. It could limit your possibilities for using our website
or components of our website
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TERMS OF USAGE OF THE WEBSITE(S)
The information and materials contained in or accessed through this website /landing page/
mobile application and any web pages herein are provided on an “as is” and “as available” basis
and are of a general nature which has not been verified, considered or assessed by the
Company in relation to the making by any party of any specific investment, business, financial
or commercial decision.
Such information and materials are provided for general information only and you should
always seek professional advice and obtain independent verification of the information and
materials contained herein before making any decision based on any such information or
materials. The Company does not warrant the truth, accuracy, adequacy, completeness, or
reasonableness of the information and materials contained in or accessed through this website
and any web pages herein, and expressly disclaims liability for any errors in, or omissions from,
such information and materials.
No warranty of any kind, implied, express or statutory (including but not limited to, warranties
of title, merchantability, satisfactory quality, non-infringement of third-party intellectual
property rights, fitness for a particular purpose and freedom from computer virus and other
malicious code), is given in conjunction with such information and materials, or this website or
any web pages herein in general.
Under no circumstances shall the Company be liable regardless of the form of action for any
failure of performance, system, server, or connection failure, error, omission, interruption,
breach of security, computer virus, malicious code, corruption, delay in operation, or
transmission, transmission error or unavailability of access in connection with your accessing
this website or any web pages herein even if the Company had been advised as to the
possibility of any such events.
In no event shall the Company, its directors, officers, and employees be liable to you or any
other party for any damages, losses, expenses, or costs whatsoever (including without
limitation, any direct, indirect, special, incidental, or consequential damages, loss of profits or
loss opportunity) arising in connection with your use of this website or any web pages herein,
or any linked site or use thereof or inability to use by any party or in connection with any
failure of performance, error, omission, interruption, defect, delay in operation or
transmission, computer virus or line or system failure, even if the Company or representatives
thereof had been advised as to the possibility of such damages, losses or expenses.
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