Privacy Policy

1. Who We Are — Data Controller Identity

The data controller responsible for your personal data collected via this Website is:

ExTrading Research Pte. Ltd. is incorporated under the Companies Act of the Republic of Singapore. Where the General Data Protection Regulation (EU) 2016/679 ("GDPR") applies to the processing of your data, we act as the data controller. Where the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA") applies, we act as a "business" as defined thereunder. Where the Personal Data Protection Act 2012 of Singapore ("PDPA") applies, we act as an "organisation" as defined thereunder.

Risk Reminder: This Website provides financial research and broker comparison services only. We do not hold, manage, or process trading accounts or client funds. For risks associated with Forex and CFD trading, please see our Disclaimer. Between 70% and 80% of retail investor accounts lose money trading leveraged products.

2. Scope of This Policy

This Privacy Policy applies to all personal data collected by ExTrading Research Pte. Ltd. through:

• Your use of and navigation on extrading-platform.com;
• Your submission of any enquiry, feedback, or contact form on the Website;
• Your subscription to any email newsletter or alert service we may operate;
• Your participation in any surveys, competitions, or promotional activities we may conduct;
• Automated data collection technologies, including cookies, web beacons, and analytics tools, as described in Section 5 below;
• Any other means by which you voluntarily provide personal data to us.

This Policy does not apply to the privacy practices of any third-party websites, brokers, or services linked to from this Website. We strongly recommend that you review the privacy policies of any third-party websites you visit through links on our platform.

3. Personal Data We Collect

We collect personal data in two primary ways: data you provide directly to us, and data collected automatically when you use our Website.

3.1 Data You Provide Directly

• Contact Information: When you submit a contact form, enquiry, or job application, we collect your name, email address, and any other information you choose to include in your message.
• Newsletter Subscription: If you subscribe to email updates, we collect your email address and, where you provide it, your first name for personalisation purposes.
• Survey & Feedback Responses: If you participate in optional reader surveys or feedback forms, we collect your responses and, if provided, identifying information.
• Career Applications: If you apply for a position advertised on our Website, we collect your name, contact details, CV, cover letter, and any other documents you submit.

3.2 Data Collected Automatically

When you visit the Website, we and our authorised third-party service providers automatically collect certain technical and behavioural data. This includes:

• Device & Technical Data: IP address (truncated or anonymised where required by applicable law), browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution, and referring URL.
• Usage Data: Pages visited, time and duration of visits, links clicked, scroll depth, broker comparison interactions, and navigation path through the Website.
• Cookie & Tracker Data: Data stored or accessed via cookies, web storage, pixel tags, and similar technologies as described in Section 5 below.
• Approximate Geographic Location: Derived from IP address; typically accurate to city level. We do not collect precise GPS-level location data.

4. How We Use Your Personal Data

We use the personal data we collect for the following purposes, each supported by a specified legal basis under applicable data protection law:

Where we rely on legitimate interests as our legal basis, we have assessed that our interests are not overridden by your interests, fundamental rights, or freedoms, having regard to the reasonable expectations of visitors to a financial information website of this nature.

Where we rely on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent, contact us at privacy@extrading-platform.com or use the unsubscribe link in any marketing email.

5. Cookies & Tracking Technologies

extrading-platform.com uses cookies and similar tracking technologies to operate the Website, analyse usage patterns, and support our affiliate referral tracking system. A cookie is a small text file placed on your device by a web server. Cookies do not contain executable code and cannot be used to access your device or its data beyond what is stored in the cookie itself.

5.1 Categories of Cookies We Use

5.2 Managing Your Cookie Preferences

On your first visit to extrading-platform.com from a jurisdiction where cookie consent is legally required (including all EU/EEA countries, the United Kingdom, and Singapore), you will be presented with a cookie consent banner allowing you to accept, reject, or customise non-essential cookies by category.

You may change your cookie preferences at any time by clicking the "Cookie Settings" link in the footer of this Website. You may also manage cookies directly through your browser settings; most modern browsers allow you to refuse some or all cookies, delete existing cookies, and receive notification when new cookies are set. Please note that refusing certain cookies may affect the functionality of parts of this Website.

For information on managing Google Analytics specifically, Google provides an opt-out browser add-on available at: tools.google.com/dlpage/gaoptout.

6. Third-Party Data Sharing

We do not sell your personal data to third parties. We do not share your personal data with third parties for their own independent marketing purposes without your explicit consent. We may share your data with the following categories of third parties, strictly for the purposes described:

6.1 Analytics Service Providers

We use Google Analytics 4 to analyse website traffic and user behaviour. Google Analytics may collect usage data via cookies and report it to us in aggregated, anonymised form. We have enabled IP anonymisation within our Google Analytics configuration. Google's data processing terms and privacy policy apply to data processed by Google: policies.google.com/privacy.

6.2 Affiliate Network Partners & Broker Partners

When you click an affiliate link on our Website, a cookie or referral parameter is set to attribute any resulting account opening to our platform. Depending on the affiliate programme structure, the broker or affiliate network may receive your IP address and referral source as part of the attribution process. We do not share your name, email address, or any other directly identifying information with brokers or affiliate networks as part of this process. Broker partners' own privacy policies govern how they process data once you navigate to their websites.

6.3 Email Service Providers

Where you subscribe to our newsletter, your email address and name are stored with our third-party email marketing platform. We use industry-standard email service providers who process data under data processing agreements compliant with applicable law. Your data is used solely to send the communications you have subscribed to and to manage your subscription preferences.

6.4 Hosting & Infrastructure Providers

Our Website is hosted on third-party cloud infrastructure. Our hosting providers process technical data (including server logs containing truncated IP addresses) as data processors acting on our documented instructions under data processing agreements. Server log data is retained for a maximum of 30 days for security and diagnostic purposes.

6.5 Legal & Regulatory Disclosure

We may disclose your personal data to competent courts, law enforcement agencies, regulatory authorities, or other third parties where we are legally required to do so, where disclosure is necessary to protect our legal rights or the rights of others, or where disclosure is required to prevent, detect, or prosecute fraud or criminal activity.

7. International Data Transfers

ExTrading Research Pte. Ltd. is based in Singapore. Some of our third-party service providers (including Google Analytics and email service providers) are headquartered or operate infrastructure in the United States and other jurisdictions outside the European Economic Area (EEA) and Singapore. When we transfer personal data internationally, we ensure that appropriate safeguards are in place:

• For transfers from the EEA or UK to third countries, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent mechanisms recognised under UK data protection law, as applicable;
• For transfers from Singapore, we ensure that recipient organisations provide a standard of protection comparable to that required by the PDPA, including through contractual arrangements or reliance on an approved framework;
• Where a third country has been deemed to provide an adequate level of protection by the European Commission, we may rely on that adequacy decision.

You may request further information about the specific safeguards applicable to any international transfer of your data by contacting us at privacy@extrading-platform.com.

8. Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected and to comply with our legal obligations. Our general retention periods are as follows:

• Contact form enquiries: 24 months from the date of last correspondence, unless an ongoing relationship requires longer retention.
• Newsletter subscriber data: Retained until you unsubscribe. Following unsubscription, suppression records are maintained for up to 3 years to prevent inadvertent re-subscription.
• Analytics data: Aggregated analytics data is retained for up to 26 months within Google Analytics. Server-level log data is retained for up to 30 days.
• Career application data: Retained for up to 12 months following the conclusion of the recruitment process, to allow consideration for future suitable openings (with your consent) or to defend against potential employment-related claims.
• Financial and accounting records (including affiliate commission records): Retained for a minimum of 5 years in accordance with Singapore accounting and tax law requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

9. Your Data Protection Rights

Depending on your jurisdiction of residence, you may have the following rights with respect to your personal data. We honour applicable rights regardless of whether a reader is based in the EEA, UK, California, or Singapore.

9.1 Rights Under GDPR (EEA & UK Residents)

• Right of Access (Art. 15): You have the right to request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to Rectification (Art. 16): You have the right to request correction of inaccurate personal data or completion of incomplete data.
• Right to Erasure / "Right to be Forgotten" (Art. 17): You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful, subject to applicable legal exceptions.
• Right to Restrict Processing (Art. 18): You have the right to request that we restrict the processing of your data in certain circumstances, including where you contest its accuracy or where processing is unlawful but you do not wish for it to be deleted.
• Right to Data Portability (Art. 20): Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object (Art. 21): You have the right to object to processing based on legitimate interests at any time. Where we process data for direct marketing, you have an absolute right to object.
• Rights related to Automated Decision-Making (Art. 22): We do not make decisions about you solely through automated means that produce legal or similarly significant effects. If this changes, you will have the right to human review.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your national data protection supervisory authority. For UK residents, this is the Information Commissioner's Office (ICO) at ico.org.uk. For EEA residents, it is the supervisory authority in your EU member state of residence.

9.2 Rights Under CCPA / CPRA (California Residents)

California residents have the following rights under the CCPA as amended by the CPRA:

• Right to Know: The right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business purpose for collection, and the categories of third parties with whom it is shared.
• Right to Delete: The right to request deletion of personal information we have collected, subject to certain exceptions.
• Right to Correct: The right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: We do not sell or share personal information for cross-context behavioural advertising. You may opt out of any such activity via the "Do Not Sell or Share My Personal Information" link in our Website footer.
• Right to Limit Use of Sensitive Personal Information: We do not collect sensitive personal information as defined under CPRA. If this changes, you will have the right to limit its use.
• Right to Non-Discrimination: You will not receive discriminatory treatment for exercising your CCPA/CPRA rights.

To submit a verifiable consumer request under the CCPA/CPRA, contact us at privacy@extrading-platform.com. We will respond within 45 days, as required by law.

9.3 Rights Under PDPA (Singapore Residents)

Under Singapore's Personal Data Protection Act 2012 (PDPA), you have the following rights:

• Access Right: The right to request access to personal data about you that we hold and information about how it has been or may have been used or disclosed in the past year.
• Correction Right: The right to request correction of personal data about you that is inaccurate, incomplete, misleading, or not current.
• Withdrawal of Consent: The right to withdraw consent to the collection, use, or disclosure of your personal data at any time, subject to reasonable notice and applicable legal or contractual restrictions. We will notify you of the likely consequences of withdrawal before acting on your request.
• Data Portability (where applicable): Where the PDPA's portability obligation applies, the right to request that your personal data be transmitted to another organisation in a commonly used machine-readable format.

To exercise your PDPA rights, contact our Data Protection Officer at privacy@extrading-platform.com. We will respond within 10 business days of receiving a complete and valid request.

10. Children's Privacy

This Website is not directed to persons under the age of 18 years. Forex and CFD trading is a complex, high-risk financial activity that is legally restricted to adults in all jurisdictions where it is regulated. We do not knowingly collect personal data from anyone under the age of 18. If you believe that a minor has provided us with personal data, please contact us immediately at privacy@extrading-platform.com and we will take prompt steps to delete that data.

11. Data Security

We implement appropriate technical and organisational security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include TLS/SSL encryption for all data transmitted between your browser and our servers, restricted access controls for staff who process personal data, regular security assessments of our infrastructure, and data processing agreements with all third-party service providers who process personal data on our behalf.

However, no method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority within the timeframes required by applicable law.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law, or regulatory guidance. When we make material changes, we will update the "Last Updated" date at the top of this page and, where the changes are significant, we will provide a more prominent notice — for example, by posting a banner on the Website or sending an email notification to subscribers.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Your continued use of the Website following the posting of changes constitutes your acknowledgement of those changes.

13. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal data, please contact our Data Protection Officer:

We aim to respond to all privacy-related enquiries within 10 business days. For formal data subject rights requests, we will respond within the timeframes mandated by applicable law — 30 days under GDPR (extendable to 60 days for complex requests with notice), 45 days under CCPA/CPRA, and 10 business days under PDPA.

If you are not satisfied with our response, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction:

• UK: Information Commissioner's Office (ICO) — ico.org.uk
• EU/EEA: Your national data protection authority (list at edpb.europa.eu)
• Singapore: Personal Data Protection Commission (PDPC) — pdpc.gov.sg
• California (USA): California Privacy Protection Agency (CPPA) — cppa.ca.gov