Privacy Policy

Scope

This Privacy Policy, as amended or otherwise changed from time to time (the 'Privacy Policy' or 'Policy'), explains how FEATrading OÜ, 16856677, Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 5, 10145 (hereinafter 'FEATrading' or the 'Company') handles personal data. The terms 'we,' 'us,' and 'our' refer to the Company; 'you' and 'User' refer to you.

This Policy covers everything we operate:

- our websites https://www.fea-trading.com and https://www.mt5tickdata.com, together with all of their subdomains — for example https://doc.fea-trading.com, https://my.fea-trading.com, https://checkout.fea-trading.com and https://center.fea-trading.com (together, the 'Site'); and
- our trading software — the desktop applications listed in our End-User License Agreement — which is dealt with separately under 'Information collected by our trading software' below, because it collects far less than a website does.

Your Personal Data is processed under this Privacy Policy and in accordance with applicable legislation, including the General Data Protection Regulation (2016/679) ('GDPR') and the applicable national data protection laws ('Data Protection Law').

The Company acts as data controllers of your Personal Data.

On occasion, the Company may revise this Privacy Policy to reflect changes in the law, our personal data collection and use practices, the features on the Site, or advances in technology. If material changes are made to this Privacy Policy, the changes will be prominently posted on the Site.

What if I do not want to accept this Privacy Policy?

This Policy is a notice, not a contract. It explains what we do with your personal data so that you can understand it and exercise your rights — we do not ask you to 'accept' it, and using the Site is not treated as consent to anything. Where we need your consent for something specific, such as non-essential cookies, we ask you for it separately, and you can withdraw it at any time. Everything else we do with your data rests on one of the other lawful bases set out in this Policy. If we change this Policy, we will post the change here and update the date at the top. In case you disclose any Personal Data regarding any third person (e.g., your employee, management board member, co-worker, contracting party, etc.) to us, you are obliged to refer them to this Policy.

What information does the Company collect?

We collect Personal Data and Anonymous Data, as described below. We may collect Personal Data from you, such as:

- first and last name
- email and mailing addresses
- address

If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.

Some information is collected automatically by our servers:

Our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol ('IP') address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or date/time stamp for your visit.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider ('ISP'), referring/exit pages, operating system, date/time stamp, and clickstream data.

Like many online services, we use cookies to collect information. 'Cookies' are small pieces of information that a website sends to your computer's hard drive while you are viewing the website.

We retain information on your behalf, such as transactional data and other session data linked to your account. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

Information collected by our trading software (desktop applications)

Our trading software (the MetaTrader applications listed in our End-User License Agreement) communicates only with our own servers, and only for these limited purposes: to receive software updates; to validate your licence and subscription entitlement (to confirm which products and, for tiered products, which subscription tier your account is entitled to); to receive our economic-events / news feed; and to enforce our licence terms and prevent abuse of free trial periods.

This is the complete list of what the software sends us. Nothing else is transmitted:

- when you sign in, create an account, or reset your password: your email address and your password (and, when you create an account, your confirmation that you accept our legal terms);
- to keep you signed in: an access token, a session key, and the moment your session started;
- to identify the product: which of our applications is running, whether it is the MetaTrader 4 or the MetaTrader 5 edition of it, and our own application's version and build number. This is our software's build, not your MetaTrader's — as stated below, your MetaTrader version and build are never sent to us;
- for licensing and trial-abuse prevention: your MetaTrader trading account number, your broker's trading-server name, the account type (demo or live), and a device identifier derived from your computer's hardware;
- a technical flag indicating whether the software is running in the MetaTrader Strategy Tester.

Our servers additionally record the IP address from which your software connects, and derive an approximate (city-level) location from it for security and audit purposes. Your sign-in details are stored only on your own computer, in encrypted form, so that the software can sign in again; they are never stored by us in that form. The identifiers above relate to you and are processed as personal data — they are NOT anonymous. The lawful bases for this processing are the performance of our licence agreement with you (Article 6(1)(b) GDPR) and our legitimate interests in enforcing our licence and in preventing fraud and the abuse of free trial periods — for example, repeatedly re-claiming a free trial from the same trading account or device, including where it was previously used under a different account with us (Article 6(1)(f) GDPR). This data is transmitted only to our own servers and is used solely to operate, secure, license, and protect our products; we do not sell it, and we do not share it with third parties for marketing or advertising purposes.

Everything in that list exists to sign you in, to confirm what your licence entitles you to, to keep your sessions in order, to deliver updates, and to stop free trials being claimed over and over. It exists for no other purpose.

No financial information of any kind is sent to our servers, and we do not record your trading behaviour. The software does not transmit your account balance, equity, margin, free margin, credit, leverage, account currency, open positions, pending orders, profit or loss, or any trading result or history. It does not transmit the account holder's name. It does not transmit which instruments you trade, your chart symbol, timeframe or spread, your MetaTrader version or build, your terminal path, your time zone, an inventory of your hardware, or any record of how you use the software. We build no profile of you or of your trading, and we could not — none of that information ever reaches us.

This is the complete list of what our servers send back to the software. Nothing else is returned:

- whether your sign-in succeeded, and the token and session key that keep you signed in;
- which subscription tier your account holds, and whether your access is a regular subscription, an evaluation, an unlicensed notice, or locked;
- how many evaluation days remain, so the software can display them to you;
- the list of your own currently active sessions, so that you can see them and end them — for each of your own sessions this includes its IP address, city and country;
- during an evaluation, the list of brokers on which the evaluation may be used;
- once a day, a single yes/no answer telling the software whether a safety suspension is in effect (see the 'Operational Safety Control' section of our End-User License Agreement);
- when a newer version exists: its version, its filename, a download link, and a checksum so the software can verify the download before installing it;
- a diagnostic logging level, which allows our support team to ask the software to write more detailed log files on your own computer when we are helping you troubleshoot. It changes only how much the software writes to its local log; it does not send anything to us and it does not affect trading.

Your trading strategy is contained within the software itself and runs locally on your own device: our servers do not send the software your strategy configuration, trade signals, or any buy, sell, or close instructions, and all trading decisions are computed locally. There is no message in the software by which we could instruct it to open, close, or change a trade — no such instruction exists. The software is a tool that you operate on your own account; FEATrading OÜ does not provide investment advice and does not manage, access, or control your trading account.

Editions of our software distributed through the MetaTrader Market operate entirely offline: they contain no network functionality at all and transmit nothing to us.

Location, jurisdiction, and fraud and sanctions screening

In addition to the IP address recorded in the cases described above, we derive an approximate geographic location (such as country, region, and city) from the IP address from which you connect. This lookup is carried out either on our own servers, using a geolocation database we hold locally, or by a specialist IP-geolocation provider acting on our behalf as our processor. Where the lookup is carried out on our own servers, your IP address is not disclosed to anyone outside FEATrading OÜ. Where a provider is used and it is located outside the European Economic Area, the transfer of your IP address to it is protected by an appropriate safeguard, such as an adequacy decision or the European Commission's Standard Contractual Clauses. We will tell you on request which method is in use at any given time.

We use this location, together with the registration and payment details you provide, to: (i) establish the country from which you transact; (ii) determine whether we may lawfully offer our products in your jurisdiction; and (iii) detect and prevent fraud and abuse of our services.

Purposes (i) and (ii) are carried out to comply with legal obligations that apply to us as a European business — in particular European Union and international sanctions measures and export-control rules, which prohibit us from supplying our products to designated persons or to embargoed destinations, together with any restriction on offering our products in a particular jurisdiction. The lawful basis for that processing is compliance with a legal obligation (Article 6(1)(c) GDPR). Purpose (iii), detecting and preventing fraud and abuse of our services, is based on our legitimate interests in the security and integrity of our services (Article 6(1)(f) GDPR). We keep this information only for as long as is necessary for those purposes.

How does the Company use the information it collects?

In general, Personal Data you submit is necessary for contacting you in the context of the delivery of products or services and administering such products and services. Also, we use your Personal Data in the following ways:

- Facilitate the creation of and secure account on network.
- Identify and perform identity verification through a service provider.
- Provide improved administration of Site and services.
- Improve the quality of experience when interacting with Site and services.
- Send a welcome email to verify ownership of the email address provided when account was created.
- Send administrative email notifications, such as account activity, transaction processing, security or support, and maintenance advisories.
- Notify about important changes to Terms and Conditions.
- Respond to inquiries related to employment opportunities or other requests.

We do not sell your personal data, and we do not share it with third parties for those third parties' own independent marketing purposes. We disclose personal data only: (a) to service providers that process it on our behalf to operate and deliver our services, such as hosting, payment processing, and customer support; (b) to the analytics and advertising providers described in the 'Use of Cookies' section below, subject to your cookie choices; and (c) where required to comply with a legal obligation or to protect our rights.

Marketing and newsletter subscriptions

Where you have an account with us, we use your account information on our website and dashboard — such as your profile details, your user status, and which products you hold — to show you more relevant information and offers while you are signed in to our website. This applies to our website and dashboard only. It does not extend to our trading software: as set out under 'Information collected by our trading software' above, that software does not send us your trading behaviour, your positions, or your results, and we build no profile of how you trade. We do not share this information with third parties. The processing of such personal data is based on our legitimate interest to develop and promote our services and products. If you have subscribed to our mailing list, we will send you information on our new activities, events, and products. We can also send special offers directed to a special user group, users of a certain region, etc. Adding you to our mailing lists is based on your consent. You may also unsubscribe from the mailing list anytime by clicking the unsubscribe link at the bottom of each message.

Customer support

In case you need to contact our customer support, our support personnel will handle your contact information and the contents of your communication. Please do not share any sensitive data in your communication with our customer support. You can contact our customer support through various means. Depending on the means of communication you choose, we'll process the following contact details: – Your IP address (chat support) – Email (email support) – User ID of an instant messaging app (QR code, support through an instant messaging app). We keep a record of the contents of the support tickets to make sure that you receive quality service and to develop our products and services. We do not record telephone calls. The processing of your personal data in connection with your communication with our customer service is based on the service agreement between you and the Company as well as our legitimate interest to follow up on the quality of our customer service, to verify the actions taken based on your request and to develop our service in the future.

How does the Company share my Personal Data?

It may be necessary to disclose your information to comply with any law, court orders, or government request, defend against claims, investigate or bring legal action against illegal or suspected illegal activities, enforce our Terms, or protect the rights, safety, and security of the Company, our users, or the public. We may share your Personal Data with third-party service providers to provide you with the services that we offer you through our Site. All third-party service providers that we share your data with shall be requested to only process your data in accordance with instructions from us and comply fully with this Privacy Policy, any applicable data protection laws and any other appropriate confidentiality and security measures. We may also share your personal data with competent authorities when this is necessary to comply with a legal obligation, court order or comparable official order issued by an authorized authority. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy. The Site may contain links to other third-party websites which are regulated by their own privacy policies. The Company is not responsible for the privacy policies of these third-party websites even if they were accessed using the links from our site.

How long do we store your personal data?

We keep the data you have provided to us on your user account for the whole period of your customer relationship and as long as it is necessary with regard to the purposes of the processing described above.

What legal rights do you have in relation to your information?

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

- Request access to your personal data.
- Request correction of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.

You also have the right to lodge a complaint with a Data Protection Authority ('DPA') if you think that your Personal Data is being processed incorrectly or your rights have been violated by the Company. The Estonian Data Protection Inspectorate is available at http://www.aki.ee/en.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us.

If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Change of personal data

Certain information provided during the registration process cannot be modified once configured. This is particularly true for the email address submitted during registration and the country selected upon initiating your first subscription with our payment service partners, PayPal and Stripe.

However, if you have chosen to use Paddle for your payments, you are permitted to change your selected country at any time. Please note that these restrictions are in place to ensure the security and integrity of your account and our services. We appreciate your understanding and cooperation.

No fees are usally required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent if one of the other legal bases is applicable.

How can you send requests regarding your information?

You can make a request regarding your information by emailing contact@fea-trading.com.

Unless you have made a corresponding request, we will retain your information for as long as your account has not been closed or as needed to provide you access to your account. If you wish to close your account, please choose "Delete Account" in the Account Settings by logging in to your personal Dashboard. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms.

Upon successful deletion of your user account, all remaining subscriptions associated with your account will be immediately invalidated. Consequently, you will no longer have access to our products and services. Please be aware that this action is irreversible and will result in the permanent loss of your account data and subscription benefits. We recommend careful consideration before proceeding with account deletion.

Where do we store your Personal Data?

The information we collect is primarily stored on secure servers managed by Hetzner GmbH, Germany. We will take all steps reasonably necessary to ensure that personal information is treated securely and in accordance with this Privacy Policy and that any third parties that we share your information with are bound to employ similar organizational and technical measures to ensure your information's security.

What security precautions does the Company take to protect me?

We take the protection of your personal information seriously. We use industry-standard data encryption technology and have implemented restrictions related to the storage of and the ability to access your personal information. However, despite all of our efforts, please note that no transmission over the Internet or method of electronic storage can not be guaranteed to be 100% secure.

To protect your account against brute-force attacks — repeated automated guessing of your password — we record the IP address and the time of failed sign-in attempts on your account, keeping only the five most recent attempts for any one address. After five failed attempts from the same address within twenty-four hours, we temporarily block further sign-in attempts from it for the remainder of that period. This applies to any attempt to sign in to your account, whether from our website or from our trading software. The lawful basis for this processing is our legitimate interest in the security of your account and of our services (Article 6(1)(f) GDPR; see also Recital 49).

Google Analytics Usage

Our website uses Google Analytics, a web analytics service provided by Google, Inc. ('Google'). Google Analytics uses 'cookies', which are text files placed on your computer, to help the website analyze how users use the site.

The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

We use Google Analytics only where you have given your consent to analytics cookies through our cookie banner. We do not set analytics cookies, and no data is sent to Google, unless and until you consent. Simply using the website is not consent. You may withdraw your consent at any time — through the cookie settings on our website, or by using your browser settings — and withdrawing it is as easy as giving it. If you withdraw consent, or never give it, the website continues to work; only the analytics stop.

For more information on how Google uses data when you use our website, please refer to Google's privacy policy located at www.google.com/policies/privacy/partners/.

Use of Cookies

Our websites — www.fea-trading.com and www.mt5tickdata.com, and their subdomains (together, the 'Site') — use cookies. Below you can find more information about cookies and how they are used across the Site.

Please note that this Cookie Notice is an integral part of the privacy policy, and the terms used herein without definition shall have the meaning assigned to them.

What are cookies?

Cookies are small text files containing information about e.g., your device, network, connection, your browsing habits, as well as your preferences and interests. These files are stored on your terminal equipment such as your computer or mobile device when you visit a website. Cookies can be set by the website you are visiting (so-called first-party cookies) or by other websites (so-called third-party cookies). Cookies allow a website to recognize a certain device. After a cookie has been placed, it is sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, in order to develop a record of the visitor's online activity.

Cookies are used to make the website work properly and to make navigating between different pages more efficient. Cookies allow the website to remember your preferences and make your user experience smoother. They can also be used for analyzing the use of a website or the services offered on that website. Cookies can furthermore be used for offering you online advertising that is targeted to meet your preferences and interests.

Types of Cookies We Use

We use two types of cookies, 'session cookies' and 'persistent cookies.' Session cookies are temporary cookies that remain on your device until you leave our website, while persistent cookies remain on your device until they expire or are manually deleted.

What kind of cookies are used on our Site and why?

1. Strictly necessary cookies

We use cookies that are necessary for the website to function. These cookies enable you to move around the website and provide access to certain parts or features of the website. Cookies enabling certain features on the website are usually set in response to your actions and requests on the page. These cookies do not gather any such information that could be used to track where you've navigated on the internet or to target online marketing to you. If you want to continue using this website, this category of cookies cannot be disabled. Strictly necessary cookies will be stored for a few minutes and then expire.

2. Analytics cookies

These are set only if you consent to them, and you can withdraw that consent at any time. We use analytics cookies to collect analytics data, such as the number of visits, the popularity of the separate pages, movement around the website, and traffic sources, to understand how visitors use our website. This data is analyzed in an aggregate and anonymized form and is used to measure and improve the performance of our website, as well as the quality of the services provided on it, to better meet our visitor's needs.

To process such analytics data, we use analytics tools provided by third parties, such as Google Analytics. The analytics data is processed in the aggregate and does not allow the identification of a single user; however, it does include certain technical information related to the visitor, such as the visitor's IP address, which can be linked to an individual website visitor's session. Our use of Google Analytics — including the transfer of data (such as your IP address) to Google on servers in the United States — is described in the 'Google Analytics Usage' section above.

If you do not allow these cookies we will not know if you have visited our site before and will not be able to monitor its performance. The analytical cookies will be stored for 30 days.

3. Targeting cookies

These are set only if you consent to them, and you can withdraw that consent at any time. If you do not consent, no targeting cookies are set and nothing is shared with our advertising partners. Where you have consented, our advertising partners may set Targeting Cookies on your device through our site. These cookies do not store directly identifiable information about you but are based on uniquely identifying ID which recognizes your browser and internet device. These cookies are used to track your online behavior across multiple websites and to create a profile of your interests based on your online activity. This profile is then used to generate customized and thus more relevant advertisements for you. The targeting tools used on this website include Facebook.

The targeting cookies will be stored for 2 (two) years. If you want to opt-out of having your web browsing information used for targeting purposes, please use the Facebook opt-out. If you do not allow these cookies, you will experience less targeted advertising.

4. Cookies set by third-party websites

When using our website, you may be directed to other websites, such as application stores or social media platforms. These websites may use their own cookies. We do not have control over the placement of cookies by other websites you visit, even if you are directed to them from our website.

Your Choices Regarding Cookies

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please note, however, that this may prevent you from taking full advantage of the website.

Changes to Our Cookie Policy

Any changes we may make to our Cookie Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Cookie Policy.

Contacting Us

If you have any questions about our Privacy Policy as outlined above, please contact us at contact@fea-trading.com.

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