In general, we collect only the information needed to create and manage accounts and/or to operate the Trading Platform. You are not required to provide any Personal Information to us; however, if you choose not to do so, we may be unable to provide our services to you.
We collect contact information and financial information in order to assess and qualify applications for accounts. These accounts may be in the name of a business or an individual. If you choose to open an account as an individual, your use of the Trading Platform will be linked to your identity.
Through your use of the Trading Platform, you may voluntarily provide business and transactional information in order to offer, accept, and carry out transactions, and to receive associated services. We also collect technical information about the use of the Trading Platform to enable us to operate, maintain, and enhance the services we offer.
We generally use your information in order to provide services to you and to operate our business.
1. What Information do we collect?
Our Trading Platform is primarily designed to enable transactions between businesses. We do not require businesses to identify the individuals who are authorized to use the Trading Platform, except where required by law. However, we may permit named individuals to open accounts and we may permit businesses to identify individuals authorized to use the Trading Platform on their behalf.
Personal Information we collect directly from you
We require certain information in order to process and approve applications for accounts. This includes identity, contact, and financial information, as further detailed in the application form.
In the course of using the Trading Platform, you may voluntarily submit information about transactions and proposed transactions, such as the nature, quantity, and price of commodities you wish to buy or sell, and related information. MT DOCS 17998235v3
If you contact us to request technical support, we may request that you provide us with identifying information, contact information, and information about your concern or issue.
You may also voluntarily submit or communicate information to the Trading Platform’s employees including trade facilitators, and logistics and treasury personnel through the use of the messaging or chat functions of the Trading Platform. We will collect and maintain records of those messages.
Personal Information collected through the use of the Trading Platform
As you interact with the Trading Platform, we will automatically collect technical information about your equipment, which may include your internet protocol (IP) address, login credentials, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other information about the devices you use to access this website, and usage information about your browsing actions and patterns when using the Trading Platform. We collect this personal data by using cookies, server logs and other similar technologies.
2. Why do we collect Personal Information?
Generally, we collect Personal Information in order to offer services in accordance with our Terms and Conditions – in particular, to post, execute, and carry out trades and to offer related support services – as well as to operate and improve our Trading Platform and/or other products and services, to protect and enforce our legal rights, and to meet our legal obligations.
3. Who has access to Personal Information?
We limit access to your Personal Information to those employees, agents, contractors and service providers who have a business need to know. They will only access, process, or use your Personal Information on our instructions and they are subject to a duty of confidentiality.
4. To whom do we disclose Personal Information?
In general, we do not disclose your Personal Information to third parties except where necessary to carry out a transaction with you or on your behalf, to protect or enforce our legal rights, or where required by law.
For example, we will share payment information with payment service providers and/or banks in order to process payments for transactions you initiate or accept.
5. How long do we retain Personal Information?
We will retain your Personal Information so long as your account on the Trading Platform remains valid and active and thereafter as required or permitted by law.
6. How do we protect Personal Information?
We have put in place physical, organizational, and technological safeguards to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. MT DOCS 17998235v3
We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. How can you access and update your Personal Information?
In many cases, the Personal Information you provide to us directly through the Trading Platform will be accessible through the Trading Platform itself. However, if you need assistance or additional information, you may contact us as set out below.
We may need to request specific information or supporting documents from you to help us confirm your identity, to ensure that Personal Information is not disclosed to a person who has no right to receive it.
8. How can you contact us?
For additional information on our privacy practices, please contact our privacy officer, as follows.
Telephone: +1 416 363 7070 ext 230
9. External Websites
Our Trading Platform may contain links to other websites, which may have different privacy policies and practices than TradeCafe. TradeCafe has no responsibility for such third party websites.
11. European Data Subjects
While our practices are generally the same for all users and account holders, your legal rights may vary in different legal jurisdictions. This section applies to the use of the Trading Platform in the member states of the European Union.
Lawful Basis for Processing
The following chart identifies the legal bases we rely on to process your Personal Information. Purpose
Type of Information
Basis for Processing
To qualify and register accounts
Performance of a contract with you
12. Location of Processing
The Personal Information referred to above will be transferred to and processed in Canada, which has been determined by the European Commission to provide an adequate level of legal protection.
13. Your GDPR Rights
Under certain circumstances, you have the following legal rights under the General Data Protection Regulation (GDPR).
You may request access to and rectification or erasure of your Personal Information (to the extent permitted by other legal obligations).
You may object to or restrict our processing of your Personal Information.
Where we rely on your consent to collect, process, or disclose your Personal Information, you may withdraw your consent at any time. (Your withdrawal of consent will not affect the lawfulness of processing based on consent before such withdrawal.)
You may raise a concern or lodge a complaint concerning our handling of your Personal Information with a competent supervisory authority.
Please note that, in general, if you exercise these rights in a way that prevents us from lawfully collecting or using information necessary in order for us to provide services to you, we will not be able to provide such services.