This notice describes how AladiEx Group and its affiliates (referred to as “AladiEx Group”, “we” or “us” in this notice) will collect, make use of and share (i.e. “process”) your personal data in connection with the AladiEx website, apps and services (including API services).
This notice also describes data protection rights you may have (depending on applicable law), such as a right to object to some of the processing which the AladiEx Group carries out. More information about your rights, and how to exercise them, is set out in the “Your rights” section.
We gather and use certain information about individuals in order to provide services and information and to enable functions on this website to work properly. We also collect information to better understand how visitors use this website and to present timely, relevant information to them.
What data we gather
When you input information on our website we may collect, store and use this information. Some data may be extracted automatically. The type of information generally gathered on our site is:
- your name, email address / username, password and other login/security details (e.g. app passcode, two-factor authentication token seed record, public PGP key), and login records;
- your payment details / bitcoin/ETH and other Cryptocurrency wallet addresses;
- your account and portfolio details, such as live and historical orders, trades and positions, and balances;
- your site and account preferences, including site notification, sounds and confirmation dialogs and leaderboard preferences;
- any personal data you submit for ID verification purposes, and your self-reported location plus the geolocation of the IP address you connect from;
- your marketing and other communication preferences, and a record of any consents you have given us;
- information related to the browser or device you use to access our website or apps, as well as data that tells us which features of the website/app are popular, or suffer from issues we need to fix;
- the content and details (e.g. date) of messages you post in chatrooms, or that you send us (e.g. customer support queries); and
- customer service notes and other records.
How we use this data
Collecting this data helps us understand what you are looking for from the company, enabling us to deliver improved services to you.
Specifically, we may use data:
- To fulfill (or take steps linked to) a service agreement with you. This includes:
- creating your account;
- if necessary, verifying your identity;
- taking deposits and fees, and paying out withdrawals;
- allowing you to make trades, maintaining your account and trading history, and closing / auto-deleveraging / liquidating positions in accordance with our published policies and terms of service;
- communicating with you; and providing customer services;
- As required by the AladiEx Group or third parties to conduct their business and pursue their other legitimate interests, in particular:
- to provide services you have requested;
- to monitor, improve and protect the services on our website and apps, in particular by looking at how they are used, testing alternatives, and by learning from feedback and comments you provide;
- to personalize our website, apps and services;
- by publishing de-identified records of market data, including trading records, on https://AladiEx.com, for third party monitoring and research purposes;
- to monitor customer accounts to prevent, investigate and/or report misconduct such as spam, misrepresentation, security incidents or crime (such as fraud), in accordance with applicable law, and to cooperate with authorities seeking to do the same;
- to investigate any complaints received from you or from others;
- in connection with legal claims, compliance, regulatory or investigative purposes (including disclosure in connection with legal process or litigation); and
- to invite individuals to take part in market research and beta tests.
- Where you give us consent (so far as that consent is required):
- we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us and carefully selected partners;
- we place cookies, monitor email engagement, and use other similar technologies in accordance with our Cookies Notice and the information provided to you when those technologies are used;
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
- To customize the website for you
- To contact you via email, telephone or mail for market research reasons.
- We respect your privacy and are committed to protecting it as described in this notice.
- We use your personal data to provide, improve and administer the AladiEx trading platform, to enter into and perform the terms of service with our users, and to comply with regulatory requirements.
- Data is shared with our vendors, and when we have a good faith belief that doing so is necessary to comply with regulatory enquiries or requirements.
- For purposes which are required by law, in particular:
- in response to requests by relevant courts and public authorities, such as those conducting an investigation.
What personal data do we receive from third parties?
We receive personal data from partners when they refer you to us (for example, we receive data about the service you used, and that referred you). Third parties may monitor the Web on our behalf, for example looking for stolen usernames and passwords. Our communications service provider may also enable us to learn more about your social media presence, in order for us to send you more personalized communications. We receive records of trades and transactions from other exchanges and trading platforms to help us monitor exchange rates and market performance. Finally, some authorities or other persons seeking access to information about users may provide information about the circumstances of their request, and about the individuals of interest.
Who will we share this data with, and where?
We will share your personal data between AladiEx Group companies so they can help deliver and improve our services, run our business, and comply with our legal obligations and related third party requests.
Personal data may be shared with affiliates who referred you to our site (so they can track successful referrals), and partners for promotions or co-branded service integrations. Information on historical trades may also be shared with other trading platforms and exchanges. Personal data may be shared with courts or public authorities if required as described above, mandated by law, or required for the legal protection of our or third party legitimate interests, in compliance with applicable laws and authorities’ requests.
Personal data will also be accessed by employees or contractors, or shared with third party service providers, who will process it on our behalf for the purposes identified above.
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s advisers, and to the new owners of the business.
Where personal data is transferred out of the UK or EEA countries to a country (such as those where we have operations or remote staff) or an international organization, and such destination is not subject to what is called an “adequacy decision” issued by the European Commission or other relevant authority (and that such destination therefore cannot be expected to offer essentially equivalent protections for personal data), that personal data will instead be protected by our use of officially-approved standard contractual clauses or a vendor’s Processor “Binding Corporate Rules”, except in very limited, legally-permitted circumstances (for instance, lawful one-off transfers to organizations that do not offer those safeguards). More details are available on request, using the contact details set out below.
Depending on applicable law (in particular, whether the laws of the UK or EEA countries apply), you may have the right to ask us for a copy of personal data about you; to correct or delete that personal data; restrict the processing of that personal data; and to obtain a copy of personal data about you that you provided to us (in connection with our agreement with you, or with your consent), in a structured, machine readable format, and to ask us to port this data to (i.e. share that data with) another organization.
In addition, applicable law may provide the right to object to the processing of personal data about you, in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
If these rights apply, they may however be limited, for example if fulfilling your request would reveal personal data about another person, would infringe the rights of another person or legal entity (including our rights), or if you ask us to delete or change data which we are required by law to keep (or have other compelling legitimate interests in keeping). We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch using the details set out below. If you have unresolved concerns, you typically have the right to complain to regulators, depending on applicable law. For example, in the EEA, your complaint can likely be taken to data protection authorities where you live, work or where you believe a breach may have occurred.
How long does AladiEx Group retain data?
Where we process personal data in connection with performing an agreement with you, we keep the data for 5 years from your last interaction with us.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of that request indefinitely, so that we can continue to respect your request in future.
Where we process personal data for site security purposes, we retain it for 3 years.
Longer retention periods may apply, such as where ongoing access to records continues to be important to our defense of legal claims or where we are required by law to retain information for specific periods.
Cookies and how we use them
What is a cookie?
A cookie is a small file placed on your computer's hard drive. It enables our website to identify your computer as you view different pages on our website. Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit.
Cookies do not provide us with access to your computer or any information about you, other than that information you choose to share with us.
However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.
Controlling information about you
When you fill in a form or provide your details on our website we will assume you are happy to be contacted by us. If we are using your information for marketing purposes, you can change your mind easily, via one of these methods:
We will never lease, distribute or sell your personal information to third parties unless we have your permission or the law requires us to.
Any personal information we hold about you is stored and processed under our data protection policy
We will always hold your information securely.
To prevent unauthorized disclosure or access to your information, we have implemented strong physical and electronic security safeguards.
Links from our site
Our website may contain links to other websites.
Please note that we have no control of websites outside the www.AladiEx.com or www.AladiEx.io domains. If you provide information to a website to which we link, we are not responsible for its protection and privacy.
Although our website and apps only look to include quality, safe and relevant external links, users should always adopt a policy of caution before clicking any links to non-AladiEx Group websites or apps. We cannot control, guarantee or verify their contents. They will have their own policies and practices, for example with regard to privacy and personal data, and you should acquaint yourselves with those before further engaging with those third-party websites or apps.
Always be wary when submitting data to websites. Read the site’s data protection and privacy policies fully.