Tradara Terminal LLC: Privacy Policy

Last updated: October 9, 2026

Tradara Terminal LLC, with its principal place of business at 273 Ponce de León Avenue, Suite 901, San Juan, PR 00917 ("Tradara Terminal," "Company," "we," "us," or "our"), owns and operates the website located at tradara.com (the "Website") and the Tradara Terminal trading platform (the "Platform"). This privacy policy ("Policy") describes the information collected through the Website, the Platform, or any other website or mobile application upon which this Policy is posted (the "Site(s)") and the related products and services we provide, whether online or offline, and how that information is collected, used, and disclosed.

The Website, Platform, Site(s), our products and services (including any mobile applications, online platforms, application programming interfaces, and other software (the "Software")), and all related content, technology, and tools are, together, referred to as the "Services." We may collect or receive the types of information described below as a result of your access to and use of the Services (together, "Collected Information") by visitors and users ("you," "your," or "User"). This Policy applies to you and to all visitors to and users of the Services.

This Policy also explains your rights and choices regarding your personal information (if applicable), how we communicate changes to this Policy, and how you may contact us regarding questions or issues with respect to any matter addressed by this Policy. This Policy is incorporated into and made a part of our Services, our Subscriber Terms and Conditions, and any other agreement that references this Policy or governs access to or use of the Services (together, our "Terms").

The data controller of Collected Information is Tradara Terminal LLC (at the address and contact information set forth under the "Contact Us" section below) or such other data controller identified on the applicable website or mobile application on which this Policy is posted.

By accessing, browsing, or otherwise using the Services, by accepting or entering into our Terms, you agree on behalf of yourself and any organization or company that you represent (together, "you") that you have read and understand this Policy and that you consent to our collection, use, and disclosure of your personal information and other Collected Information pursuant to the terms of this Policy. If you do not agree with this Policy, do not access or use the Services.

1. Collection of Information

The information we collect generally falls into the following categories:

1.1. Information that you voluntarily submit to us ("Submitted Information"), for example, your contact information, account registration information, payment information, user-generated content, support requests, and job applications.

1.2. Information collected automatically through your use of the Services, for example, user activity, data collected by the servers used to operate the Services (such as IP addresses and device information), data collected by analytics providers, data collected when you connect using or share information via social media platforms, and data collected by cookies and similar tracking technologies.

1.3. Information we receive from third-party sources, for example, identity verification providers, brokerages and clearing firms, proprietary trading firms and evaluation providers through which you access the Services ("Firms"), market data vendors, and publicly available sources, as further described in this Policy.

2. Submitted Information

We will collect information that you choose to submit to us through, using, or in connection with the Services, including the types of information described below.

2.1. Identifying and Contact Information

You can visit certain portions of the Services without submitting your contact information to us, but you will be required to provide your contact information in order to sign up for or subscribe to the Services, to create an account or profile, to request information from us, to use certain Services or features, and to request customer support. We will collect any information from or about you that you choose to provide to us, which may include, without limitation, your full legal name, date of birth, email address, telephone number, postal address, and country of residence. We will use your information as described below in this Policy, including, without limitation, to provide the Services and their functionality, to set up and administer user accounts, to process orders for our Services, to verify that you meet our age and eligibility requirements, and to communicate with you for marketing and administrative purposes.

2.2. Accounts

To sign up for an account, you must provide specific information, including your full legal name, email address, a username, and a password. You may also be asked for additional information such as your country of residence and zip code or postal code. Once you are registered, we will collect your login information to facilitate your access to, and to administer, your account.

2.3. Phone Numbers

If you provide a mobile or other telephone number to us, you consent to receiving telephone calls and/or text messages from us, if and as applicable, as described in this Policy, but only to the extent permitted by applicable law.

2.4. Payment Information

Payments submitted in connection with the Services (including subscription fees, one-time fees, and any other charges) must be made via the Services using a credit card, debit card, or alternate payment method that is personal to you, where such alternate payment methods are made available as an option. Alternate payment methods may be provided by third parties (for example, Stripe, PayPal, or similar processors), subject to that third party's privacy policy. This Policy does not apply to such third party's collection and use of your information. With regard to credit and debit card payments, all credit and debit card information is provided directly to our third-party payment processor and must be made using a card personal to you. We do not directly access, handle, or store your full credit or debit card information. To submit payment using the Services, you will need to provide your full legal name, email address, telephone number, billing address, and your credit or debit card number, expiration date, and security code, as well as any other information necessary to verify the applicable payment. Our payment processor will use your payment-related information in accordance with its privacy policy.

2.5. Market Data Subscriber Information

Access to certain market data made available through the Platform requires that you provide additional information in order to comply with the entitlement and reporting requirements of the relevant exchanges and market data redistributors (including, without limitation, CME Group). This information may include your full legal name, residential address, country of residence, employment status, employer, professional/non-professional classification, registration status with regulatory authorities, and a signed market data subscriber agreement. We collect, retain, and disclose this information to the relevant exchanges and market data vendors as required by their licensing terms and applicable law. By subscribing to market data through the Services, you authorize us to share your subscriber information with the applicable exchange(s) and market data vendor(s), and you agree to be bound by the terms of the applicable exchange's subscriber agreement.

2.6. Sensitive Personal Information

In connection with the Services, we may collect information that is considered "sensitive" under applicable laws, including:

government-issued photo identification documents and identification numbers;
financial account information (such as bank account numbers, routing numbers, and related contact information); and
tax identification information (such as a taxpayer identification number) where required for compliance, billing, or reporting purposes.

We collect and use sensitive personal information for the following legitimate business purposes:

to carry out our obligations under applicable law (including anti-money laundering, know-your-customer, sanctions screening, tax, and exchange-licensing requirements);
for the performance of our agreement with you and to provide the Services requested by you and as reasonably expected in the context of such performance (for example, using a copy of a valid government-issued identification to verify your identity and to protect against fraud);
to protect our legal interests and to ensure the physical safety of ourselves and other individuals;
as otherwise required by law; and
for other purposes, with your prior consent.

If we have valid concerns about fraud or identity verification, as determined in our sole discretion and in alignment with applicable KYC requirements, we may submit your identity information to a third party for the purposes of identity verification. Please note that this Policy does not apply to such third parties' collection and use of the information you submit to them.

We do not sell your sensitive personal information, and we do not share your sensitive personal information for purposes of cross-contextual behavioral advertising.

2.7. User-Generated Content

We will collect all data, information, and other content that you enter into, submit to, upload to, or transmit using the Services, including any messages, support tickets, screenshots, charts, custom indicators or scripts, watchlists, alerts, layouts, and saved configurations. If you post a submission to any public-facing area of the Services (for example, public chat rooms, community forums, or shared layouts), please be aware that any personal information disclosed in such submission can be read, viewed, collected, or used by other users, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor we control. If you share a trade link or performance display, or participate in a Competition or leaderboard, your username, results, and related trading statistics may be visible to other users or to anyone with the link. You are responsible for any content you submit, and such content is provided at your own risk. We cannot guarantee that user-generated content will not be viewed by unauthorized persons. You understand that, even after removal, copies of user-generated content may remain viewable in cached and archived pages and may have been copied or stored by other users or by Internet archives.

2.8. Order, Position, and Trading Activity Data

When you connect a brokerage account to the Platform or otherwise route orders or receive account data through the Services, or when you trade in a simulated, evaluation, or Competition account, we collect information about your trading activity, including order entries and modifications, fills, working orders, positions, account balances, profit and loss, margin and risk metrics, copied orders and trade copier settings, and related metadata (such as timestamps, instruments, venues, and order routes). We use this information to provide the Services, to display your account state to you within the Platform, to operate features such as risk controls, analytics, and reporting, to troubleshoot and improve the Services, to detect and prevent fraud and abuse, and to comply with applicable law and the requirements of brokerages, exchanges, and regulators. For the avoidance of doubt, your trading account, the underlying funds, and the execution relationship are with the applicable brokerage or futures commission merchant, and not with Tradara Terminal. If you connect a brokerage account, we also collect and store the credentials, API keys, or access tokens needed to connect it, and we use them only to provide the Services.

2.9. Contact Forms and Requests for Information or Support

To contact us for more information, or to request support via the Services, you will need to provide your contact information as applicable, as well as details of the products or services you are interested in and the subject matter of your inquiry.

2.10. Chat and Messaging

If you use any chat or messaging feature on the Services, we will collect all text and other information and content that you provide or input using those features. If you use a chat or messaging feature while signed into your account, we may link that information to your account.

2.11. Marketing Communications

If you sign up or otherwise opt in to receive newsletter updates, promotional or marketing communications, or other communications from us, you will need to provide your email address. We will use this information to send you updates, marketing, promotional, and other electronic communications. You may opt out of receiving promotional emails from us at any time by following the unsubscribe instructions in the applicable email or by contacting us using the contact information provided below under "Contact Us." Note that, even if you opt out of receiving promotional communications, you may still receive administrative communications from us with respect to your account and use of the Services. We may use third-party email providers to deliver these communications.

2.12. Job Applications

If you submit a resume, job application, or related materials to us, we may use that information to evaluate your qualifications and consider or respond to your inquiry or application. Your submission of a resume, job application, or related information does not in any way require us to review that information or consider you for employment. To submit a job application, you may be redirected to an online career portal operated by a third party. We encourage you to review any terms and privacy policies posted on that portal.

3. Other Information Collected Automatically

As you navigate and use the Services, certain information is collected automatically using various technologies.

3.1. Usage, Device, and Location Data

We collect information about your activities on the Services, which may include device and connection identifiers (such as IP addresses, device identifiers, browser type and version, operating system, screen resolution, internet service provider, and approximate geographic location derived from IP address), pages or features you use, length and frequency of use, time and date of access, referring URLs, exit pages, clickstream data, and other usage information. We use this information to administer the Services and their servers, to generate statistical information, to monitor and analyze Service traffic and usage patterns, to monitor and help prevent fraud and abuse, to investigate complaints and policy violations, to enforce entitlement and licensing requirements (including for market data), to enforce eligibility and geographic restrictions (including sanctions and market data country restrictions, and detection of VPN or proxy use), and to improve the Services.

3.2. Cookies and Similar Tracking Technologies

See Section 5 ("Cookies and Tracking Technologies") below.

3.3. Information from Third-Party Sources

We may obtain information about you from the following sources:

Service Providers and Vendors. We may collect information about you from companies that we do business with, including identity verification and fraud prevention partners, customer support and analytics vendors, and infrastructure providers.
Brokerages, Clearing Firms, and Trading Venues. Where you connect a brokerage or trading account to the Platform, the relevant brokerage, clearing firm, or trading venue may transmit account, order, position, and balance information to us at your direction.
Firms. If you access the Services through a Firm, the Firm may provide us with your name, email address, account identifiers, account type and status, the program rules that apply to your account, and your market data subscriber classification.
Market Data Vendors and Exchanges. We receive market data from exchanges and licensed redistributors and may receive subscriber-related data and audit information from these sources.
Connected Services. If you link, connect, or log in to the Services using a third-party service or account (such as Google, Apple, or Microsoft single sign-on), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you in your privacy and security settings at that service.
Publicly Available and Social Media Data. This may include your contact information, employer, social media handles, and other information from publicly available sources.

4. Sharing and Use of Collected Information

In addition to the uses and sharing described above, we and our suppliers may use and disclose Collected Information as described below. We do not generally rely on or require your consent to allow us to process your personal data if there is another legal ground available. If we do rely on your consent, we will request it and make this clear to you at that time. We do not use, sell, rent, or otherwise disclose Collected Information except as stated in this Policy and as required or permitted by applicable law.

4.1. Purpose Collected and Communications with You

We will use and share your personal information and other Collected Information for the purpose for which it was collected, including to provide and operate the Services, to administer your account, to provide customer support, to process payments and orders, to enforce our Terms, to communicate with you regarding your use of the Services and your support requests, and to notify you of changes to the Services or this Policy.

4.2. Personalization

To tailor the content and information that we send or display to you, to suggest personalized help and instructions, and to otherwise personalize your experience while visiting or using the Services.

4.3. Promotional Communications

To the extent permitted by applicable law and in accordance with your preferences, we may use Collected Information to send you promotional communications about us and our products and services. We will obtain your prior consent for such promotional communications solely to the extent required by applicable law. You may opt out of receiving promotional communications from us at any time by following the unsubscribe instructions contained in the applicable email or by contacting us using the contact information provided below under "Contact Us." Even if you opt out of promotional communications, you may still receive administrative communications.

4.4. Text Messages

If you opt in to receive text messages (SMS and MMS) on the Services when prompted, we may send you autodialed and other text messages at the telephone number you provide relating to your use of the Services. Consenting to receive text messages is not required to buy goods or services or to otherwise do business with us. Message and data rates may apply. You can opt out at any time by replying STOP.

4.5. Brokerages and Clearing Firms

When you connect a brokerage account, clearing relationship, or futures commission merchant to the Platform, you direct us to interact with and disclose your information, including your personal information, to the applicable brokerage, clearing firm, or futures commission merchant for the purpose of providing the Services. Your account, the underlying funds, and the execution relationship are governed solely by the agreements between you and that third party. We are not a party to those agreements and are not responsible for the acts, omissions, solvency, execution quality, or regulatory compliance of any such third party. We encourage you to review the privacy policy of any brokerage, clearing firm, or futures commission merchant that you use in connection with the Services.

4.6. Firms

If you access the Services through a Firm, we share with that Firm your account and contact information, account identifiers, trading activity in your Firm-provided accounts (including orders, fills, positions, balances, profit and loss, and risk metrics), rule-monitoring results, platform usage, and market data subscriber status. We share this information so the Firm can operate its program, enforce its rules, provide you with support, and pay for your access. The Firm uses this information under its own privacy policy, and we are not responsible for the Firm's practices. We may also act on a Firm's instructions to suspend or close your access to the Services.

4.7. Market Data Vendors and Exchanges

As described in Section 2.5, we share market data subscriber information with the relevant exchanges and market data redistributors (including CME Group and its licensed redistributors) as required by their licensing and entitlement terms and applicable law. We may also disclose information to such exchanges and redistributors in response to audits, investigations, or other compliance inquiries.

4.8. Sharing with Affiliates and Related Entities

We may share Collected Information with our affiliated entities and related companies for legitimate business purposes consistent with this Policy and applicable law, including an affiliate that processes payments as merchant of record.

4.9. Sharing with Third-Party Suppliers and Service Providers

We will disclose Collected Information to our suppliers, vendors, and service providers as necessary for us to provide the Services and to engage in the use and sharing of Collected Information as permitted by this Policy and applicable law. These third parties include, without limitation, our cloud infrastructure providers, hosting providers, customer support and chat providers, email and messaging providers, identity verification and fraud prevention providers, payment processors, analytics providers, and observability and security tooling providers. Our service providers are authorized to use and disclose Collected Information only as necessary for them to provide the applicable products and services to us and as provided by their own privacy policies and our agreements with them.

4.10. Evaluation and Improvement of Our Products and Services

We may use and disclose Collected Information to analyze, develop, and improve the content, materials, products, and services that we provide; to inform marketing and communication plans and strategies; to understand user demographics and preferences; to analyze the effectiveness of the Services; and to evaluate user needs and customize the Services and the user experience.

4.11. Usage Data and Analysis

To better understand how users access and use the Services, both on an aggregated and individualized basis, including monitoring, evaluating, and analyzing which features and portions of the Services are most popular, for troubleshooting, for statistical purposes, and for other operational purposes.

4.12. Deidentified and Aggregated Data

We may deidentify and/or aggregate personal information, user-generated content, trading activity data, and other Collected Information, and use and disclose that aggregate or deidentified data for our business purposes, in each case to the extent permitted by applicable law. We will maintain such information in aggregate or deidentified form and will not attempt to reidentify it (except as may be necessary to determine whether the deidentification process satisfies applicable legal requirements).

4.13. Lawful Process; Protection of the Company

We may use and share Collected Information in accordance with and in response to regulatory authorities, courts of competent jurisdiction, valid law enforcement requests, governmental agency requests, emergency services, exchange regulatory bodies (such as CME Group's Market Regulation department), self-regulatory organizations, and other necessary third parties for legal, protection, security, and safety purposes (for example, to comply with laws or regulations, to respond to subpoenas and legal processes, to protect the safety of our employees, agents, and customers, or any other person). We may also use Collected Information and share it with third parties if we believe doing so is necessary or appropriate to protect our rights or the rights of others, including to enforce our agreements, policies, and Terms, to bring legal action, to protect our operations and assets, or to pursue remedies or limit damages.

4.14. Business Transactions

If we undergo a change in control, acquisition, merger, reorganization, asset sale (in whole or in part), or similar transaction, we may transfer, sell, share, or otherwise disclose Collected Information to the subsequent owner(s) or successor(s). We may also disclose Collected Information in connection with the evaluation of those transactions. The recipients will be bound by this Policy as it applies to the information disclosed.

4.15. With Your Consent

With your consent, we may use and share your personal information and other Collected Information in ways not specifically described in this Policy.

4.16. No Sale of Personal Information; No Cross-Contextual Behavioral Advertising

We do not sell your personal information for monetary consideration, and we do not share your personal information with third parties for purposes of cross-contextual behavioral advertising, as those terms are defined under applicable U.S. state privacy laws. If our practices change, we will update this Policy and provide you with the opt-out rights required by applicable law.

5. Cookies and Tracking Technologies

The Services use cookies and similar tracking technologies (such as web beacons and pixels) to operate the Services, to recognize you when you return, to remember your preferences, to analyze how the Services are used, and to help us improve the Services. Cookies are small pieces of information stored on your device by your web browser.

5.1. Categories of Cookies We Use

Strictly necessary cookies. Required for the operation of the Services (for example, to authenticate users, prevent fraudulent activity, and maintain session state). Without these cookies, certain features of the Services cannot be provided.
Functional cookies. Allow us to remember choices you make (such as your preferences or settings) and to provide enhanced functionality.
Performance and analytics cookies. Help us understand how visitors interact with the Services so that we can measure and improve performance.

We do not currently use cookies or similar technologies for the purpose of cross-contextual behavioral advertising. If we begin using such technologies, we will update this Policy and provide the opt-out rights required by applicable law.

5.2. Managing Cookies

Most browsers automatically accept cookies and allow you to manage cookies through your browser settings. You can disable or limit cookies, but doing so may impact your use and enjoyment of the Services.

5.3. Do-Not-Track Signals

Due to the automatic collection of data using cookies as described above, we do not currently honor "Do Not Track" signals. However, residents of certain U.S. states may opt out of certain activities that are considered "selling" or "sharing" personal information for targeted advertising purposes by broadcasting an Opt-Out Preference Signal as defined under applicable law, including the Global Privacy Control (GPC). For more information, visit https://globalprivacycontrol.org.

5.4. Embedded Content

The Services may incorporate content provided by third parties (such as embedded videos, charts, or maps). In some cases, those third parties collect data about how you interact with their content. Their collection and use of your information is governed by their own privacy policies.

6. Retention of Personal Information

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy and our Terms, unless a longer retention period is required or permitted by law (for example, tax, accounting, anti-money-laundering, exchange audit, or other legal or regulatory requirements). When we have no ongoing legitimate business need to process your personal information, we will take reasonable measures to delete or anonymize it. If deletion is not possible (for example, because your information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible. Content you have published to other users may be retained after you close your account, as described in our Terms; if you ask us to delete your account, we will remove your name, username, and other identifying information from retained published content, or delete it where the law requires.

7. Automated Processing

Other than as may be described in this Policy, you will not be subject to decisions based on solely automated information processing that produce legal or similarly significant effects without your prior consent or another lawful basis under applicable law. Risk monitoring tools may automatically flag, restrict, or close simulated or Firm-provided accounts under rules you or your Firm have configured; questions about those outcomes may be directed to us or to your Firm.

8. International Transfers of Personal Information

Tradara Terminal LLC is organized in the Commonwealth of Puerto Rico, United States. Depending on your particular interaction with us, your personal information may be transferred to, accessed, stored, and otherwise processed by us, by our affiliates and related entities, or by our service providers in jurisdictions outside of your home jurisdiction, including the United States. These jurisdictions may not provide an equivalent level of data protection as your home jurisdiction. We take steps to protect personal information, including, where required by law, through appropriate written data processing terms and/or data transfer agreements (for example, by entering into the EU standard contractual clauses approved by the European Commission). Subject to applicable law, you have the right to obtain details about the mechanism under which your personal information is transferred cross-border. For more information, please contact us as set out in the "Contact Us" section below.

9. Your Choices and Access

Depending on the laws applicable to our processing of your personal information and the location in which you reside, you may have the ability to exercise the rights listed below. Subject to all applicable limitations, exemptions, and exceptions, these rights may include:

Right to Access. You may have the right to request access to the personal information that we hold about you, including the categories of personal information collected, the categories of sources, the business or commercial purposes for collection, the categories of third parties with whom we share personal information, and the specific pieces of personal information we have collected about you.
Right to Data Portability. You may have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to require us to transmit it to another entity where this is technically feasible.
Right to Deletion. You may have the right to request the deletion of your personal information.
Right to Correction. You may have the right to request the correction of inaccurate personal information.
Right to Withdraw Consent. Where your personal information is processed on the basis of your consent, you may have the right to withdraw consent at any time with effect for the future.

To exercise any of these rights, please see Section 12 ("Exercise Your Rights") below.

10. Additional Information for Certain U.S. Residents

Certain U.S. states require additional disclosures and provide users residing in such states with additional choices and rights. This section applies to individuals located in such U.S. states and where such state data protection laws apply to our processing of your personal information.

10.1. Categories of Personal Information Collected

The categories of personal information we collect, and the purposes for which we collect each category, are described throughout Sections 1 through 4 above. They include:

Identifiers (such as name, postal address, email address, telephone number, IP address, and account identifiers).
Customer records information (such as identifying information collected for KYC, billing, or market data subscriber purposes).
Commercial information (such as records of products and services purchased and subscription history).
Financial and trading information (such as orders, fills, positions, balances, and profit and loss in connected, simulated, and Firm-provided accounts).
Internet or other electronic network activity information (such as log files, login information, cookies, and device information).
Approximate geolocation information (such as country and region derived from IP address).
Professional or employment-related information (collected for market data professional/non-professional classification).
Sensitive personal information as described in Section 2.6, and account log-in credentials for connected brokerage accounts.
Inferences drawn from the above categories of personal information.

10.2. Sources

We collect personal information from the categories of sources described in Sections 1.3 and 3.3 above.

10.3. Disclosures to Third Parties

The categories of third parties to which we may disclose personal information are described throughout Section 4 above, and include Firms, brokerages and clearing firms, exchanges and market data vendors, affiliates, and service providers.

10.4. Rights

Applicable laws in your jurisdiction may grant you the rights set forth in Section 9 above, as well as:

The right to opt out of targeted advertising and the sharing of personal information for cross-contextual behavioral advertising purposes;
The right to opt out of the sale of your personal information; and
The right not to be discriminated against due to your exercise of your rights under applicable law.

We do not discriminate against users for exercising the rights granted to them under applicable law.

10.5. No Sale; No Sharing for Cross-Contextual Behavioral Advertising

As stated in Section 4.16, we do not sell personal information and we do not share personal information for purposes of cross-contextual behavioral advertising. If our practices change, we will update this Policy and provide you with the opt-out rights required by applicable law.

11. Additional Information for Individuals Located in the EEA and the United Kingdom

This section applies to residents of countries or jurisdictions located in the European Economic Area (EEA), including the European Union and, to the extent applicable, the United Kingdom.

11.1. Controller

Tradara Terminal LLC is the controller of your personal information covered by this Policy for purposes of European data protection legislation. Where you access the Services through a Firm, the Firm is a separate controller of the information we share with it under Section 4.6.

11.2. Rights

To the extent the European Union's General Data Protection Regulation (GDPR), the United Kingdom General Data Protection Regulation (UK GDPR), or other law granting particular rights to data subjects applies to you and is applicable to us, and subject to all applicable exceptions and exemptions granted under such law, you may have the rights described in Section 9 above, as well as:

Right to Restrict Processing and Right to Object. You may have the right to restrict our use of your personal information where (i) you contest its accuracy; (ii) the use is unlawful but you do not want us to erase the personal information; (iii) we no longer need the personal information for the relevant purposes, but you require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our use of personal information justified on our legitimate interests, pending verification of whether we have compelling interests to continue the relevant use.
Right to Lodge a Complaint. You may have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the collection and use of your personal information violates this Policy or applicable law.

11.3. Legal Bases

Where the GDPR, the UK GDPR, or similar law applies to us, we process your personal information for the purposes set forth in this Policy under the following legal bases (as applicable):

Performance of a contract. Our processing is necessary to perform our obligations under a contract with you or to perform steps requested by you prior to entering into a contract (for example, to verify the information you have provided).
Legitimate interests. Our processing is necessary for our legitimate interests, including to operate and secure the Services; to protect the health and safety of you or others; to establish, protect, and defend our legal rights and interests; to prevent fraud and verify identity; to understand and analyze usage trends; to improve our products and services; to provide Firms with the information they need to operate the programs through which you access the Services; and to send marketing communications.
Legal compliance. Where our processing is required to comply with applicable law (for example, to maintain transaction records for tax or audit purposes, or to respond to subpoenas, court orders, and other lawful requests by regulators, courts, and law enforcement agencies).
Consent. Where we have your express consent as defined by applicable law.

We may use your personal information for reasons not described in this Policy where permitted by law and where the reason is compatible with the purposes for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

12. Exercise Your Rights

If this Policy or applicable law grants you certain rights as it relates to Collected Information, you may submit a verifiable request to us by emailing privacy@tradara.com.

Only you, or a registered agent that you authorize to act on your behalf (if and only as permitted under applicable law), may make a verifiable consumer request related to your personal information. If you have a registered agent act on your behalf, we have the right to authenticate such agent's authority to act. Without limiting the foregoing, the verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor's identity or authority.

We will respond to your request within the applicable timeframe required under applicable law. If we deny your request, you can appeal the denial by emailing us at privacy@tradara.com.

13. Accuracy and Information Security

Personal information you provide to us should be relevant to the purposes for which it is to be used and, to the extent necessary for those purposes, should be accurate, complete, and up to date.

We have implemented reasonable and appropriate administrative, technical, physical, and organizational security measures designed to help protect against unauthorized access, unauthorized disclosure, loss, theft, misuse, and alteration of information under our control. This includes measures designed to limit access by employees and contractors. We do not publish all of our security measures online because doing so may reduce their effectiveness. We educate our personnel with respect to their obligations to protect Collected Information. However, no system is perfectly secure: we do not and cannot guarantee that unauthorized access, disclosure, loss, theft, misuse, or alteration of information will not occur. The storage and communication of information can never be completely secure.

If you become aware of any breach of the Services' security or of this Policy, please notify us at privacy@tradara.com immediately. If our security is breached, we will notify you only if and to the extent required under applicable law.

14. Access by Children

The Services are not directed at children, and you must be at least 18 years old and have reached the age of majority where you live to use them. We do not knowingly collect or use information from children under 18 through the Services. If we learn that a user does not meet these age requirements, we will close the account and delete the user's personal information, except where we must retain it by law. If we learn that we have collected personal information from a child under 13, we will delete it as required by the Children's Online Privacy Protection Act. If you believe a child under 18 has provided us with personal information, please contact us at privacy@tradara.com and we will take steps to delete such information.

15. Third-Party Websites and Services

The Services may link to, or be linked to, websites, applications, or services not maintained or controlled by us, including brokerages, clearing firms, Firms, exchanges, market data vendors, payment processors, identity verification providers, and social media platforms. We are not responsible for the privacy policies or practices of any third parties or third-party websites, applications, or services. This Policy does not apply to any third-party websites, applications, or services or to any personal or other information that you may provide to third parties. You should read the privacy policy for each website, application, and service that you visit or use.

16. Changes to this Policy

We reserve the right to modify this Policy at any time. All changes will be effective immediately upon posting of the updated Policy on the Website, the Platform, or any Site, and, by accessing or using the Services after any changes are made, you agree to those changes. Material changes will be clearly posted on the Website, the Platform, or any Site, or otherwise communicated to you (for example, via email), and where applicable law requires, we will provide notice before material changes take effect or obtain your consent.

17. Contact Us

If you have any questions or concerns regarding this Policy, please contact us:

Tradara Terminal LLC 273 Ponce de León Avenue, Suite 901 San Juan, PR 00917 Email: privacy@tradara.com

Tradara Terminal LLC is a limited liability company organized under the laws of the Commonwealth of Puerto Rico.