PRIVACY AND COOKIE POLICY FOR NEURONALTRADER
This Privacy Policy explains how NeuronalTrader collects and processes personal data concerning you. NeuronalTrader is committed to protecting the privacy of all personal information it acquires and will only use your personal information in accordance with this Privacy Policy.

¿Who are we?
NeuronalTrader is a website developed for the purpose of centralizing valuable information tools for our users in one location when they are operating in various financial markets. Currently, NeuronalTrader is focused on creating tools for Deriv Broker, which includes a core called Neurolink that processes high-speed transactions and serves as a mediator between the Broker and the user.

¿What information do we collect?
In order to provide you with our services, we need to process certain information about you. We request information that allows us to offer and provide you with products and services tailored to your interests and needs. Additionally, when you use our services, we collect information about your use of our website and mobile app (“Websites”), which helps us improve your experience on our websites and allows us to manage the services we provide.

Information collected by us.
We may also retain information automatically when you visit our websites and/or use our services, such as deposit and withdrawal history, information about funds and financial instruments held by the company on your behalf, relevant data and types of transactions made, documents downloaded and/or uploaded, your use of our websites, for example, how often you access them, the areas of the site visited, and the duration of visits, the pages visited, Internet Protocol (IP) address, geographic location information, identifiers of computers and mobile devices, general identifiers, website activity, as well as the text you enter on the websites, websites that referred you to ours or to which websites you link and your preferred languages.

As long as you are registered as a client, we will collect information about you (“your data”) for administrative, service-related, or legal reasons when you sign up for a demo or a trading account with us, fill out any form on our website, contract our services, receive news, announcements, or publication materials.

We will limit the collection of personal information to what is necessary for managing our business and conducting our regulated activities in order to offer you superior service.

The information you give us directly includes:

• Personal information, such as names, surnames, and email addresses.

• Importantly, NeuronalTrader does not store the access tokens provided by Deriv at the time of verification. Once the verification is executed, these tokens are not used again by NeuronalTrader.
• However, “provided” data to NeuronalTrader is not limited to this. It also encompasses personal data resulting from observing your activities (when using a device or service).

This may include:

• History of webpage use or search activities, details of your visits to our webpage, including communication data.
• Data traffic and location.
• Website traffic pattern information, including IP address, operating system, and browser type, for system management and to relay information to our advertisers. This type of information is used only in a masked or aggregated form, meaning the individual user will not be identifiable. These data do not identify the person.
• We communicate with you through Live Chat on our website, Telegram, email, or by phone.
• The company may use your email in connection with its products and services (including any advertising campaign related to such products or services). If you do not wish to receive this advertising or informational material, you can opt out by clicking “unsubscribe”.

Type of data collected and purpose of collection
The type of data we collect and the purpose of the collection are described below:
Personal information such as names and surnames. For compliance with our Anti-Money Laundering (AML) and other regulatory obligations related to the Know Your Customer (KYC) policy and due diligence with the client. To verify your identity using our verification processes.

Contact information (email address). For sending you correspondence about the services provided and to fulfill our regulatory obligations.

Unsolicited information
If you provide us with personal information we have not requested, we will endeavor to retain only the information to which we have a right or are required to keep due to the products and services we offer. However, if this additional information exceeds our requirements but is provided in a manner that combines it with information we are obligated or have the right to retain, or if it is technically impossible to isolate and remove, then you acknowledge that this unsolicited information may be retained by us in the same way as the rest of your personal information.

How we use your personal information

• To improve the effectiveness of our website content presentation and enhance the site content.
• To communicate with you, maintain contact, and offer you products and services you request or that we believe may interest you.
• To manage and administer the products and services we provide to you.
• To keep you informed as a Client about changes in our services and relevant issues.
• To provide, improve, test, and monitor the effectiveness of our Services.
• To develop and test new products and features.
• To monitor metrics such as the total number of visitors, traffic, and demographic patterns.
• To diagnose or fix technology problems.
• To comply with our obligations under any contracts with you.
• To notify you about updates to our website.
• To send newsletters or information about other opportunities that we believe will interest you. We will only send this if you have indicated that you wish to receive this information, and we will respect your decision if you choose not to receive it. You can stop receiving marketing communications at any time if you do not wish to receive this material by clicking on “unsubscribe”;
• To promote safety. We use the information we have to help verify accounts and activity, and to promote safety in our regulated services by investigating suspicious activities or violations of our terms or policies.
• We strive to protect your account through the use of IT specialist teams, automated systems, and advanced technology such as encryption.

Whom do we share your personal information with?

We will not rent or sell your information to third parties outside of the Company (Company Group) without your consent. We also impose strict restrictions on how our processors may use and disclose the data we provide. Here are the types of third parties with whom we share your information:

Service providers and other partners: We transfer information to service providers (processors), and other partners who globally support our business by providing technical infrastructure services, analyzing how our services are used to measure the effectiveness of ads and services, providing customer service and support, onboarding clients, performing identity verification, conducting marketing and communication designs, and related services for managing our website, software development, and business services.

Measurement and analytics services: Partners who use our analytics services like Google Analytics (non-identifiable information). We do not share information that personally identifies you (personally identifiable information is information such as name or email address that by itself can be used to contact you or identifies who you are) with advertising, measurement, or analytics partners. We will share personal information with law enforcement or other authorities if required by applicable law.

Statistical Data
Neuronaltarder may combine your personal identification information with information from other users of its websites to create non-personal aggregated statistical data to monitor and improve its services and products. Under no circumstances will you be identified from these statistical data: you will remain anonymous.

Marketing
Neuronaltrader uses personal information to keep its customers updated at all times about marketing matters, including but not limited to providing its customers with information about the products and services offered by Neuronaltrader. For marketing purposes, Neuronaltrader will use email, Telegram, text messages (SMS), and/or any other appropriate electronic communication.

Cookie Data
We use cookies and similar technologies to provide and support our Services. When you use our website, we use cookies to distinguish you from other users of our website. Cookies are small text files stored by your browser on your computer or device when you visit certain pages or take certain actions on this and other websites. They help your browser remember your choices and show you the correct information, such as items in your cart, and not treat you as a new visitor each time you visit a page.
Some cookies are only set while you visit the web (“session cookies”) to help you navigate and give you relevant information. Others are set for longer periods (“persistent cookies”) so that your browser can remember your choices from a previous visit. Cookies stored cannot harm your device, are anonymous, and unique to your browser. You can choose to deactivate or block these cookies in your browser, but without some of them, our site will not function properly. For more detailed information about cookies, visit http://www.allaboutcookies.org.

How do we use cookies?
Below, we outline how we use different types of cookies, as well as information about the various options you have for managing settings related to data collected by these technologies:

Performance/Analytics Cookies (performance and analytics cookies): These cookies are used to recognize and count the number of visitors to the Site, collect statistics about how visitors move around the Site (including the number of pages viewed and the amount of time spent on each page), as well as to track conversions and clicks on access points. This helps us improve both the way our Site works and the overall user experience. For example, these cookies allow us to ensure that users can easily find what they need.

Other Third-Party Cookies: In some parts of the Site, including in the news widgets, we use content provided by other websites (third parties). In some cases, these third-party sites set their own cookies. Please note that we have no control over these types of cookies. You can disable them by disabling them in your browser. You can find more information on the help pages of the most popular browsers:

Google Chrome
Mozilla Firefox
Microsoft Edge
Safari (macOS)
Safari (iOS)
For any other browser, you can consult the documentation provided by the browser manufacturer itself.

Data Transfer to Third Countries
Due to our nature as an online service, we may store and process information in various locations around the world. If you reside in a jurisdiction such as the European Economic Area member states, where transferring your personal information to another jurisdiction requires your consent, then you provide us with your explicit and unequivocal consent for such transfer.

Access
When using this website, you may be able to link to other websites. This Privacy Policy does not apply to those other sites.

Remarketing with Google Analytics
We may use the information we collect to help us send you relevant advertisements (remarketing). Remarketing is a way to connect with visitors to our websites and advertisements, based on their previous interactions with our website and ads. Neuronaltrader may hire third-party marketing providers to perform such remarketing services. As a result, third-party providers, including Google, may display Neuronaltrader advertisements on internet sites. These third-party providers, including Google, may also use their cookies, third-party cookies, and similar technologies to publish advertisements based on a visitor’s previous visits to Neuronaltrader websites.

If you decide to opt-out of Google Analytics for Display Advertisers and the Google Display Network’s customized advertising network, please visit the following Google address: Ads Preferences Manager. We also advise you to visit: Google Analytics Opt-out Browser Add-on. For more information, you can also visit: Google’s privacy center.

Your Rights
You have several important rights, including:

⦁ Fair treatment of information and transparency about how we use your Personal Information.
⦁ The right to request correction of your personal data if it is inaccurate: ask us to correct any mistakes in your information that we have.
⦁ The right to object at any time to the processing of personal data concerning you for direct marketing.
⦁ If you want to unsubscribe from any email or any marketing communication, you can also click on the “unsubscribe” button at the bottom of the email.

Keeping Your Personal Information Safe
Neuronaltrader takes security very seriously and strives to protect your personal information and ensure that unauthorized persons do not access it. Measures include encryption, strong authentication mechanisms, and the separation of machines and data to provide secure areas.

Your data is stored and kept confidential in accordance with legislation on personal data protection and its processing applicable in the jurisdiction where the company you have signed up with is located.

We have appropriate security measures in place to prevent personal information from being accidentally lost, misused, altered, disclosed, or accessed without authorization. We limit access to your personal information to those who have a genuine need to know it. Those processing your data will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach when we are legally required to do so.

Legal Basis for Personal Data Processing

There must be a legal basis for processing any personal data (unless an exemption or irregularity applies). We rely on:

• Compliance with legal obligations. The processing is necessary to comply with our legal obligation. Neuronaltrader needs to fulfill a legal obligation.

• Legitimate interest. Data will only be processed when necessary for the purposes of the legitimate interests pursued by Neuronaltrader, and these interests or fundamental rights are not overridden by the interests, rights, and freedoms of the data subject and that the processing would not cause unjustified harm. For example, it is a legitimate interest of Neuronaltrader to process personal data about data subjects to expand the business, develop new business relationships, prevent fraud, maintain the security of our systems if/when necessary, and to increase, modify, or improve our services. The data subject should receive information about the specific legitimate interest if processing is based on this provision.

Data Retention
We will retain personal information for as long as required and necessary for the purposes for which it was originally collected, including for the provision of our services and contractual obligations, for our business purposes and objectives, for compliance with applicable legal and regulatory obligations, for the protection and exercise of our legal rights and defense, and for maintaining adequate business records.

Enforcement
Neuronaltrader is doing everything possible to comply with this Privacy Policy. If you have any questions, concerns, or complaints regarding this policy and its implementation, please send them to: [email protected] After receiving your complaint, Neuronaltrader may contact you to better understand your concerns and will do its best to promptly respond to your question or resolve your complaint to your full satisfaction.

Minors
Our services and websites are not available to users under the age of 18 (or the legal age of consent in the jurisdiction where the user is located). We do not knowingly collect personal information from or about minors. If you are under the legal age, you should not download or use any of our services or provide us with any personal information. If you have any reason to believe that a minor has shared information with us, please contact us.

Policy Amendment
Neuronaltrader may occasionally change and update the terms of this Privacy and Security Policy. All changes will take effect seven days after their initial publication on the website, unless Neuronaltrader amends this policy to comply with legal or regulatory requirements; in such cases, the amendments will take effect as required or ordered.

¿How to Contact Us?
Contact us at [email protected] if you have any questions about this privacy policy or the information, we hold about you.
The English version of this document is the official and authorized version between the parties. Translations are provided for your convenience only and must be referenced with the English text, which is the only version of the text that has legal effect.