Privacy Policy

TradeXSports - Privacy Policy

SECTION 1: INFORMATION WE COLLECT

TradeXSports collects personal information in the following ways:

1.1 Information You Provide Directly

When you create an account or otherwise interact with the Platform, you may provide the following categories of personal information:

• Account Registration Data: Your full name, email address, username, date of birth, and password (stored in hashed/encrypted form).
• Profile Information: Any additional information you choose to include in your user profile.
• Support Communications: Records of correspondence with our customer support team, whether submitted by email or through in-app messaging features.
• Identity Verification Information: Where required to verify your identity and eligibility for reward distribution, we may request documentation or other identifying information.
• Reward Redemption Information: Information necessary to facilitate the delivery of gift card rewards, including your name and email address provided at time of redemption.

1.2 Information Collected Automatically

When you access and use the Platform, we and our service providers automatically collect certain technical and usage information, including:

• Device Information: Device type, operating system version, browser type and version, device identifiers (such as Apple IDFA, Google Advertising ID (GAID), and similar persistent device identifiers).
• Log Data: Internet Protocol (IP) address, access timestamps, pages or screens viewed, links clicked, and in-application activity logs.
• Usage Data: Virtual trading activity, leaderboard participation and rankings, session duration, feature engagement frequency, and other interactions with Platform functionality.
• General Location Data: General geographic location inferred from your IP address (e.g., country, state, or city). We do not collect precise GPS-level location data.
• Analytics Data: Aggregated behavioural and performance data collected via third-party analytics tools and software development kits (SDKs) integrated into the Platform.

1.3 Information from Third Parties

We may receive personal information about you from third parties in the following circumstances:

• Third-Party Login Providers: If you choose to register or log in using a third-party authentication service such as Google Sign-In or Apple Sign-In, we receive basic profile information (such as name and email address) from that provider in accordance with their applicable terms and privacy policies.
• Analytics and Attribution Partners: We receive aggregated and user-level analytics data from analytics and mobile attribution partners to help us understand user acquisition, retention, and Platform performance.
• Gift Card Fulfillment Partners: Our gift card delivery partners may provide us with delivery confirmation and related information to administer our reward program.
• Fraud Prevention Partners: We may receive signals and data from fraud detection and identity verification providers to assist us in detecting and preventing fraudulent activity on the Platform.

1.4 Cookies and Tracking Technologies

TradeXSports and its authorised service providers use cookies, pixel tags, web beacons, software development kits (SDKs), and similar tracking technologies to recognise you across sessions, analyse usage patterns, and deliver a consistent and secure experience on the Platform.

We use the following categories of tracking technologies:

• Strictly Necessary: Essential for the operation of the Platform, including authentication, session management, and security. These cannot be disabled.
• Functional: Allow the Platform to remember preferences and settings you have selected.
• Analytics: Used to collect anonymous or aggregated data about how users interact with the Platform in order to improve its functionality and performance.
• Advertising / Attribution: Used for mobile attribution purposes to understand which marketing channels led users to the Platform. We do not use these technologies for cross-context behavioural advertising targeting.

You may manage your cookie and tracking technology preferences through your device settings, browser settings, or by contacting us at support@tradexsports.com. Please note that disabling strictly necessary cookies or SDKs may impair or prevent access to certain Platform features. For additional information, please refer to the device-level and platform-level privacy controls offered by Apple (iOS) and Google (Android).

SECTION 2: HOW WE USE YOUR INFORMATION

TradeXSports uses the personal information we collect for the purposes described below. Where required by applicable law, we will only process your personal information on a lawful basis, as further described in Section 3.

2.1 To Provide and Operate the Platform

• Creating, maintaining, and managing your user account.
• Processing and delivering gift card rewards to eligible participants.
• Communicating with you regarding your account status, transactions, and Platform updates.
• Administering the weekly leaderboard competition and associated reward programme.
• Verifying user eligibility, including age verification (users must be 18 years of age or older).

2.2 For Safety and Security

• Detecting, investigating, and preventing fraudulent, abusive, or unlawful activity on the Platform.
• Monitoring account security and protecting the integrity of the Platform.
• Detecting and enforcing violations of our Terms of Service.
• Verifying user age and identity in connection with reward eligibility and applicable compliance obligations.

2.3 For Analytics and Improvement

• Analysing how users interact with the Platform to understand usage patterns and trends.
• Improving existing features and developing new Platform functionality, performance, and user experience.
• Conducting internal research, product testing, and development activities.

2.4 For Marketing and Communications

• Sending promotional emails, push notifications, and in-app notifications relating to the Platform, new features, contests, and reward opportunities, where you have provided consent or where permitted by applicable law.
• You may opt out of marketing communications at any time by clicking the "unsubscribe" link in any marketing email, adjusting your notification preferences within the Platform settings, or by contacting us at support@tradexsports.com. Opting out of marketing communications will not affect transactional or account-related communications.

2.5 To Comply with Legal Obligations

• Responding to valid legal process, including subpoenas, court orders, and regulatory inquiries.
• Cooperating with law enforcement agencies as required or permitted by applicable law.
• Maintaining records required by applicable accounting, tax, and regulatory law.
• Exercising or defending legal rights and claims in dispute resolution proceedings.

2.6 With Your Consent

For any processing purposes not described above, we will seek your prior consent at the time of collection and will process your information only for the specific purpose(s) for which you have provided consent. You may withdraw your consent at any time by contacting us at support@tradexsports.com, subject to the limitations described in this Policy.

SECTION 3: LEGAL BASIS FOR PROCESSING (GDPR / UK GDPR)

This Section applies to users located in the European Union (EU), European Economic Area (EEA), and United Kingdom (UK). For all other users, our lawful authority to process your personal information is governed by the applicable laws of your jurisdiction, as described in Section 7.

Under the General Data Protection Regulation (GDPR) and the UK General Data Protection Regulation (UK GDPR), we process personal information only where a valid lawful basis exists. The following table summarises the lawful bases we rely upon:

Where we rely on Legitimate Interests as the lawful basis for processing, TradeXSports has conducted a legitimate interests assessment (balancing test) and has determined that our legitimate interests are not overridden by your interests, rights, or freedoms, having regard to reasonable expectations of users of the Platform and the nature and limited scope of the data processed. You have the right to object to processing based on legitimate interests at any time (see Section 7.2).

SECTION 4: HOW WE SHARE YOUR INFORMATION

4.1 We Do Not Sell Personal Information

TradeXSports does not sell, rent, lease, or trade your personal information to third parties for their own independent marketing, advertising, or commercial purposes. This applies under all applicable laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the General Data Protection Regulation (GDPR), and all equivalent state, national, or regional privacy laws.

4.2 Service Providers and Data Processors

We share personal information with carefully selected third-party service providers and data processors who perform services on our behalf. These categories of service providers include:

• Cloud Hosting and Infrastructure Providers: For storing, processing, and securing Platform data.
• Analytics and Attribution Partners: For measuring Platform performance, user acquisition, and engagement analytics.
• Email Communication Providers: For delivering transactional and marketing emails.
• Gift Card Fulfillment Partners: For processing and delivering gift card rewards to eligible users.
• Customer Support Platforms: For managing customer support tickets and communications.
• Fraud Prevention and Identity Verification Providers: For detecting fraudulent activity and verifying user identity where required.

All service providers and data processors are contractually required to handle your personal information solely in accordance with TradeXSports's documented instructions, to implement appropriate technical and organisational security measures, and to comply with all applicable data protection and privacy laws. We do not authorise our service providers to use your personal information for their own independent purposes.

4.3 Business Transfers

In the event of a merger, acquisition, sale of all or substantially all assets, corporate reorganisation, insolvency, or similar business transaction, your personal information may be transferred to a successor entity as part of that transaction. In such circumstances, TradeXSports will use commercially reasonable efforts to notify affected users by email or in-app notification prior to any transfer taking effect, and to ensure that any successor entity continues to honour the commitments set forth in this Policy or provides users with adequate prior notice of any material changes.

4.4 Legal Disclosures

We may disclose your personal information without prior notice where we believe in good faith that disclosure is necessary or appropriate to:

• Comply with a valid legal obligation, court order, subpoena, regulatory inquiry, or other legal process;
• Respond to requests from law enforcement authorities or government agencies in accordance with applicable law;
• Enforce or apply our Terms of Service or other agreements; or
• Protect the rights, property, or safety of TradeXSports, our users, or the public.

Where permitted by applicable law, we will endeavour to notify you before making such a disclosure, unless doing so would be prohibited by law or would compromise the purpose of the disclosure.

4.5 Aggregate or De-identified Data

TradeXSports may share aggregated, anonymised, or de-identified data with third parties for research, marketing, analytics, or other business purposes. Such data is processed in a manner that does not reasonably identify or re-identify any individual user, and does not constitute personal information for purposes of this Policy or applicable privacy law.

SECTION 5: INTERNATIONAL DATA TRANSFERS

5.1 Transfers from the EU/EEA and United Kingdom

TradeXSports is based in the United States. If you are located in the European Union, European Economic Area, or United Kingdom, your personal information will be transferred to and processed in the United States, which is a country whose data protection laws may not provide the same level of protection as those in the EU/EEA or UK.

To ensure that such transfers are lawful and that your personal information receives an adequate level of protection, TradeXSports relies on the following legally recognised transfer mechanisms, as applicable:

• EU Standard Contractual Clauses (SCCs): As adopted by the European Commission pursuant to Commission Implementing Decision (EU) 2021/914 for transfers from the EU/EEA to third countries.
• UK International Data Transfer Agreement (IDTA): As approved by the UK Secretary of State, for transfers from the United Kingdom to third countries.
• Other Recognised Transfer Mechanisms: Including any adequacy decisions, binding corporate rules, or other legally recognised mechanisms as may be applicable from time to time.

You may request a copy of the applicable transfer mechanism documentation by contacting us at support@tradexsports.com.

5.2 All Other Users

Regardless of your country of residence, by using the Platform you acknowledge and accept that your personal information may be transferred to, stored, and processed in the United States and in other countries where TradeXSports or its service providers operate. Such processing will be conducted in compliance with this Policy and in accordance with applicable law.

SECTION 6: DATA RETENTION

We retain personal information only for as long as necessary to fulfil the purposes described in this Policy, or as required or permitted by applicable law. The following retention periods apply unless a verified deletion request is received (see Section 7):

Upon receipt of a verified account deletion or erasure request, we will delete or anonymise the relevant personal information within 30 calendar days of verification, subject to any applicable legal retention obligations (such as tax and accounting record-keeping requirements) that may require us to retain certain information for longer periods. Information subject to such obligations will be retained in isolated, access-controlled storage and will not be used for any other purpose.

Where data is retained beyond the standard retention periods solely due to legal obligations, it will not be actively processed for any operational purpose and will be securely deleted as soon as the applicable legal retention obligation expires.

SECTION 7: YOUR RIGHTS

Depending on your country of residence, you may have certain rights regarding your personal information. TradeXSports is committed to honouring these rights in accordance with applicable law. To exercise any of the rights described below, please contact us at support@tradexsports.com with sufficient detail to identify your account and the specific right you wish to exercise. We may need to verify your identity before processing your request.

7.1 Universal Rights (All Users)

Regardless of your country of residence, TradeXSports provides all users with the following rights:

• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Correction: You may request that we correct any inaccurate or incomplete personal information about you.
• Right to Deletion: You may request the deletion of your account and associated personal information, subject to applicable legal retention obligations.
• Right to Opt Out of Marketing: You may opt out of receiving marketing communications from us at any time, without affecting your use of the Platform.

To exercise any of these rights, please contact us at support@tradexsports.com.

7.2 EU/EEA and United Kingdom Users (GDPR / UK GDPR)

If you are located in the EU, EEA, or UK, you have the following rights under the GDPR and UK GDPR:

• Right to Be Informed (Article 13–14): The right to receive clear, transparent information about how your personal data is collected and used, which this Policy is intended to fulfil.
• Right of Access (Article 15): The right to obtain confirmation as to whether we process personal data about you, and to receive a copy of that data along with supplementary information about how it is processed.
• Right to Rectification (Article 16): The right to have inaccurate personal data corrected and incomplete personal data completed without undue delay.
• Right to Erasure / Right to Be Forgotten (Article 17): The right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other lawful basis applies), where you object and there are no overriding legitimate grounds, or where the data has been unlawfully processed.
• Right to Restriction of Processing (Article 18): The right to request that we restrict the processing of your personal data in certain circumstances, such as while the accuracy of data is contested or while an objection is pending.
• Right to Data Portability (Article 20): Where processing is based on your consent or on the performance of a contract and is carried out by automated means, the right to receive your personal data in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible.
• Right to Object (Article 21): The right to object to the processing of your personal data on grounds relating to your particular situation, where processing is based on legitimate interests. You have an absolute right to object to processing for direct marketing purposes at any time, without providing reasons, and we will cease such processing immediately upon receipt of your objection.
• Rights Related to Automated Decision-Making (Article 22): The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you. TradeXSports does not currently engage in solely automated decision-making of this nature. If this practice changes, we will update this Policy and provide appropriate safeguards.

We will respond to all verified GDPR/UK GDPR rights requests within one (1) calendar month of receipt. This period may be extended by up to two further months where the request is complex or where we receive a high volume of requests, in which case we will notify you of the extension within the initial one-month period.

If you are not satisfied with our response, or if you believe we are processing your personal data in violation of applicable law, you have the right to lodge a complaint with your national data protection supervisory authority. Contact details for supervisory authorities are provided in Section 12.3.

7.3 California Residents (CCPA / CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA):

• Right to Know: The right to know what categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the purposes for which it is used, and the categories of third parties with whom it is shared or disclosed.
• Right to Delete: The right to request the deletion of personal information we have collected from you, subject to certain exceptions provided under California law.
• Right to Correct: The right to request correction of inaccurate personal information we maintain about you.
• Right to Opt Out of Sale or Sharing: The right to opt out of the sale or sharing of your personal information. TradeXSports does not sell or share your personal information as defined under California law.
• Right to Limit Use of Sensitive Personal Information: The right to direct us to limit the use and disclosure of sensitive personal information to uses necessary to provide the services or goods you request, or as otherwise permitted under California law.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising any of your rights under California law. TradeXSports will not deny you goods or services, charge you different prices, or provide a different level of quality of service as a result of your exercise of any California privacy right.

To exercise your California privacy rights, please contact us at support@tradexsports.com. We will respond to verified requests within 45 calendar days of receipt, with a possible extension of an additional 45 days where reasonably necessary, in which case we will notify you of the extension within the initial 45-day period.

7.4 Australian Users (Privacy Act 1988 / Australian Privacy Principles)

If you are located in Australia, we handle your personal information in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). You have the following rights:

• Right to Access: The right to request access to the personal information we hold about you, subject to certain exceptions under the Privacy Act.
• Right to Correction: The right to request the correction of personal information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading.
• Right to Make a Privacy Complaint: If you believe we have interfered with your privacy, you may first make a complaint to us at support@tradexsports.com. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

7.5 Canadian Users (PIPEDA / Quebec Law 25)

If you are located in Canada, your personal information is handled in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, including Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25). You have the following rights:

• Right to Access: The right to access the personal information we hold about you and information about how that information is being used and disclosed.
• Right to Accuracy and Correction: The right to challenge the accuracy and completeness of your personal information and to have it amended where appropriate.
• Right to Withdraw Consent: The right to withdraw consent to the collection, use, or disclosure of your personal information at any time, subject to legal and contractual restrictions, by contacting us at support@tradexsports.com. Note that withdrawal of consent may affect our ability to provide you with certain features of the Platform.
• Right to Data Portability (Quebec Law 25): Quebec residents have the right to receive personal information that we hold about them in a structured, commonly used, and technological format, and to request that such information be communicated to another person or body who collects such information.
• Right to Lodge a Complaint: You may lodge a privacy complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca. Quebec residents may also contact the Commission d'accès à l'information at www.cai.gouv.qc.ca.

7.6 Brazilian Users (Lei Geral de Proteção de Dados — LGPD)

If you are located in Brazil, your personal information is processed in accordance with the Lei Geral de Proteção de Dados Pessoais (LGPD — Law No. 13,709/2018). You have the following rights under the LGPD:

• Right to Confirmation of Processing: The right to obtain confirmation of whether we process personal data about you.
• Right to Access: The right to access the personal data we hold about you.
• Right to Correction: The right to correct incomplete, inaccurate, or out-of-date personal data.
• Right to Anonymisation, Blocking, or Deletion: The right to request anonymisation, blocking, or deletion of unnecessary or excessive personal data, or personal data processed in non-compliance with the LGPD.
• Right to Portability: The right to request the portability of your personal data to another service or product provider.
• Right to Information on Sharing: The right to information about which public and private entities your personal data has been shared with.
• Right to Opt Out of Consent-Based Processing: The right to revoke consent at any time, where processing is based on your consent.
• Right to Information on Consequences: The right to be informed of the consequences of refusing consent where processing is based on consent.

To exercise your LGPD rights, please contact us at support@tradexsports.com. If you are not satisfied with our response, you may lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at www.gov.br/anpd.

SECTION 8: CHILDREN'S PRIVACY

The TradeXSports Platform is intended exclusively for users who are 18 years of age or older. Users between the ages of 13 and 17 are not permitted to use the Platform, and by registering for an account, you represent and warrant that you are at least 18 years of age.

TradeXSports does not knowingly collect, use, or disclose personal information from children under the age of 13 years, in compliance with the Children's Online Privacy Protection Act (COPPA) and equivalent laws in other jurisdictions. If we become aware that we have inadvertently collected personal information from a child under the age of 13, we will take prompt steps to delete such information from our systems.

If you are a parent or legal guardian and have reason to believe that a child under the age of 13 has provided personal information to TradeXSports without your consent, please contact us immediately at support@tradexsports.com. Please include in your message sufficient detail to allow us to locate and delete the child's information from our systems. We will use commercially reasonable efforts to delete such data promptly upon verified notification.

SECTION 9: SECURITY

TradeXSports takes the security of your personal information seriously and implements a range of appropriate technical and organisational measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include, but are not limited to:

• Encryption: Encryption of personal data in transit using industry-standard TLS (Transport Layer Security) protocols, and encryption of data at rest using appropriate cryptographic standards.
• Access Controls: Role-based access controls, least-privilege principles, and multi-factor authentication for systems containing personal information.
• Employee Training: Regular training programmes for employees and contractors who handle personal information, covering data protection, security awareness, and incident response.
• Incident Response: Documented incident response procedures for identifying, containing, and remediating security incidents involving personal data.
• Vendor Security: Contractual requirements obligating service providers to maintain appropriate security standards.

Notwithstanding the foregoing, no method of electronic transmission or storage is completely secure. While we strive to protect your personal information, we cannot guarantee or warrant the absolute security of any information transmitted to or from the Platform.

If you become aware of or suspect any security incident, unauthorised access to your account, or unauthorised disclosure of your personal information, please notify us immediately at support@tradexsports.com.

For users located in the EU/EEA and UK: In the event of a personal data breach, TradeXSports will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, where the breach is likely to result in a risk to the rights and freedoms of natural persons, in accordance with Article 33 of the GDPR. Where the breach is likely to result in a high risk to affected individuals, we will also notify those individuals without undue delay, in accordance with Article 34 of the GDPR.

SECTION 10: THIRD-PARTY LINKS AND SERVICES

The Platform may contain links to, or integrations with, third-party websites, services, or applications that are not owned or controlled by TradeXSports. This includes, without limitation, external gift card provider websites, authentication providers, and any other third-party services referenced within the Platform.

TradeXSports has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third-party websites or services. This Policy applies solely to information collected by TradeXSports through the Platform. We strongly encourage you to review the privacy policies of any third-party services you interact with through the Platform before providing them with any personal information.

The inclusion of any link or integration within the Platform does not imply endorsement by TradeXSports of the linked website or service, or any association with its operators.

SECTION 11: CHANGES TO THIS PRIVACY POLICY

TradeXSports reserves the right to update or modify this Policy at any time to reflect changes in our practices, the Platform, applicable law, or regulatory guidance.

For material changes to this Policy — meaning changes that significantly affect your rights or the way we process your personal information — we will provide you with advance notice of at least 30 days prior to the revised Policy taking effect, unless applicable law requires a shorter or longer notice period. Notice will be provided via email to the address associated with your account and/or through a prominent in-app notification.

Your continued use of the Platform following the effective date of a revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must discontinue your use of the Platform prior to the effective date of the changes and may request deletion of your account and data in accordance with Section 7.

For users in jurisdictions where applicable law requires explicit affirmative consent for material changes to privacy policies, TradeXSports will seek such consent before any material change takes effect for those users. Processing of your personal information for new purposes will not commence until such consent has been obtained.