Privacy & Cookies Policy
Privacy
1. Introduction
This Privacy and Cookies Policy forms part of our MTradeGo Terms & Conditions. It explains how we will use your
personal information should that be collected through this MTradeGo application. In addition, it explains how we
use cookies.
You may contact us at support@mtradego.com if you have any questions about this Policy. We may change it
from time to time by updating this page.
Other sites linking to or from this MTradeGo will have their own privacy policies and we are not responsible for the
privacy practices of the relevant operators.
2. Personal information collected
We may typically collect the following information about you through this MTradeGo. This is not a definitive list and
details may change from time to time:
• Your name and contact details, including email address, postal address, mobile and fixed line telephone
numbers
• On advisor sites, your job title, business contact details, the charitable body, private investor, corporate entity
or other person or institution you represent for investment purposes and/or to whom you provide financial
advisory services.
• Log in details and pin numbers and/or passwords as necessary to set up and administer registered user
accounts.
• Payment card details as necessary to facilitate your online purchases.
• Investment products and related services which are of interest to you, as relevant to your direct marketing
preferences.
• All personal information about you as may be contained in free text boxes, including in relation to enquiries or
comments submitted to us through this MTradeGo.
3. Purposes
We may typically use your personal information for the following purposes. This is not a definitive list and may
change from time to time:
• For our internal business administration and record keeping purposes.
• To provide you with information about our investment products and related services, to facilitate your online
purchases and for all other administration as may be necessary in relation to the supply of our investment
products and related services and the conduct of our investment management business.
• With your consent, for direct marketing purposes (for further details see “Direct Marketing and Managing Your
Preferences” below).
• To respond to your enquiries or comments submitted through this MTradeGo.
• Where necessary as part of any restructuring relating to MTradeGo, Inc (the Company) and its business or
assets, or as part of a sale of the Company or, as relevant, another company in the Company Investments
group, or its/their assets.
• For legal and regulatory compliance purposes, including as necessary to respond to governmental, regulatory
or law enforcement agency requests; to ensure the continuing security and integrity of our systems, business
dealings, reputation or the security and reputation of the Company and its staff; to identify misuse of the
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Company’s systems and any fraud or other illegal or unlawful activity or any other activity which is or may be
contrary to our legal and regulatory compliance obligations.
• As may otherwise be necessary for responsible corporate governance or as otherwise required or permitted by
applicable laws and/or regulations.
4. Data disclosures and data sharing
Your personal information may be shared as necessary with our service providers. They may be retained, for
example, to provide services in relation to administration, direct marketing; MTradeGo hosting and management;
data storage and back up; and such other services as may be relevant to our business from time to time. This
includes disclosures to any person or company to whom we delegate responsibility for the administration, operation
and/or maintenance of this MTradeGo. In addition, we may disclose your personal information:
• In response to a court order, request for cooperation from a law enforcement or other government agency; to
establish or exercise legal rights; to bring or defend legal claims; as may necessary for responsible corporate
governance or as otherwise required or permitted by applicable laws and/or regulations;
• In circumstances in which we believe disclosure is appropriate in connection with fraud prevention and prevention
of other illegal or unlawful activity or any other activity which is or may be contrary to our legal and regulatory
compliance obligations; to protect and defend the rights, property or safety of the Company and/or other companies
in the Company Investments group, its/their investors and other clients, staff, and/or service providers; responsible
corporate governance or compliance with applicable laws and/or regulations.
• To buyers in the event of any restructuring relating to the Company and its business or assets, or as part of a
sale of the Company or, as relevant, other companies in the Company Investments group, or its/their assets.
5. Data transfers
Your personal information may be transferred outside your own country. In particular, your personal information
may be transferred to other countries. The Company will seek to ensure your personal information is protected in
those other countries or territories in accordance with applicable data privacy law.
6. Retention
In accordance with applicable data privacy law, we will retain your personal information for as long as is necessary
for the relevant purposes described above.
7. Updating and obtaining copies of your personal information
If you believe the personal information we hold about you is inaccurate, incorrect or incomplete, please tell us as
soon as possible. See “Contact Us” below. You may request copies of your personal information from us. All
requests must be in writing (i.e. by post or by email)]. Please contact us for further details. See “Contact Us” below.
8. Security
In accordance with our obligations under applicable data privacy law, we take all reasonable precautions to seek
to keep your personal information secure, including precautions against unauthorised access or loss. Likewise, we
seek to keep secure all confidential information you send to us. Our “Security Statement” on this
MTradeGo contains more details about our MTradeGo security measures. However, in common with all MTradeGo
operators, we cannot guarantee the security of any data transmitted by Internet email or through this MTradeGo.
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9. Data anonymisation and aggregation
We may process anonymised or aggregated data which does not identify you. We may share it with other
companies in the Company Investments group or with other third parties. That data will not be subject to the
relevant sections of this Privacy and Cookies Policy or to data privacy law. That data may be used for statistical
analysis and administration, including analysis of trends, carrying out actuarial work, tailoring products and
services, risk assessment and analysis of costs and charges in relation to our products and product support
services, to compile (non-identifying) demographic data such as which pages of the MTradeGo are used most
frequently (please refer to our Cookie Policy), sales, traffic patterns and related site information.
10. Direct Marketing and Managing Your Preferences
With your consent, we may use your personal information for direct marketing purposes, including sending you
marketing communications about investment products and related services of the Company Investments group.
Direct marketing may include communications by post, email, telephone calls, SMSs, communications through
third party instant messaging systems and such other electronic communication as may become relevant from
time to time. You may unsubscribe from direct marketing from the Company at any time by following the instructions
in the marketing communication itself or by contacting us through this MTradeGo.
11. Monitoring and interception of communications
Emails and telephone calls, SMSs, communications sent through this MTradeGo and communications through
third party instant messaging systems (as relevant), as between you and the Company staff, may be monitored
and, in specific circumstances, intercepted, for legal and regulatory compliance purposes; to address actual or
potential HR disciplinary matters; to ensure the continuing security and integrity of the Company’s systems,
business dealings, reputation or the security and reputation of the Company and its staff; and for all other purposes
as may be required or permitted by applicable legal and regulatory obligations.
12. IP Addresses
An IP address is a number which recognises the computer or other device used to access the Internet. Typically,
a web server automatically collects IP addresses and uses them to administer MTradeGo. IP addresses are
typically used in conjunction with cookies for the purpose of “remembering” computers or other devices used to
access this MTradeGo. For further details see “Cookies” below.
13. Cookies
13.1 Cookies and consent collection
This MTradeGo uses cookies. Cookies are text files containing small amounts of information which are downloaded
to your computer or other device when you visit a MTradeGo. They are used to help you navigate MTradeGo Apps
efficiently and perform certain functions. On your first visit to our home page a banner appeared to make it clear
that this MTradeGo used cookies and to direct you towards this Privacy and Cookies Policy. It was explained to
you on that first visit that by continuing to browse this MTradeGo you would be agreeing to our use of cookies. This
means that by using this MTradeGo, you are deemed to be giving your consent to our use of cookies in the manner
set out below.
13.2 Classification of cookies
Cookies can be classified by duration and by source
Duration: This MTradeGo uses both session and persistent cookies:
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• Session cookies – a cookie that is stored temporarily and is destroyed when you close the link,
specifically by closing the browser and terminating the particular ‘active session’ you are on and during
which you made your visit to this MTradeGo.
• Persistent tracker cookies – a cookie that enables a MTradeGo to remember you on subsequent visits,
speeding up or enhancing your experience of services or functions offered. These cookies are not deleted
when you close your browser and they will remain on your computer or other device unless you choose
to disable them (see above for how to do that).
Source
Cookies can be classified as first party or third party cookies. First party cookies are those issued on behalf of the
MTradeGo visited, all other cookies are third party cookies. This MTradeGo uses both first party and third-party
cookies. For further details, see below.
13.3 Essential (classified as ‘strictly necessary’) cookies: these are essential in order to enable you to move
around this MTradeGo and use its features, such as by accessing secure areas such as the ‘My Account’ function.
A session cookie is only stored on your computer’s hard drive for the duration of your visit (known as an ‘active
session’), it is removed as soon as the active session has ended.
13.4 Functionality cookies: these cookies allow us to remember choices you make (such as language or the
region you are in) and provide enhanced, more personal features. The Company uses functional cookies to
recognise you when you return to this MTradeGo, enabling us to personalise our content for you and remember
your preferences.
13.5 Performance cookies: these are used by web analytics and collect information in an anonymous form about
how visitors use this MTradeGo. They allow us to track site usage, page visits and monitor trends over time. The
data collected is limited to managing the performance and design of this site. These cookies are third-party cookies
(Google Analytics) but the information is in an anonymous form and is obtained for the exclusive use of the
Company.
13.6 Advertising cookies: we use persistent third-party cookies to track user history for advertising and targeted
marketing purposes. We also use pixel tags or transparent GIF files (also known as beacons) in combination with
cookies to target and personalise content. These cookies do not collect or otherwise process any specific personal
information about you. They collect information in an anonymous form about how visitors use this MTradeGo and
other MTradeGo with the information used to tailor advertising or marketing on this MTradeGo and other
MTradeGo.
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scope of digital advertising programmes.
13.7 Other third-party cookies: this MTradeGo has links to other third party MTradeGo, and the linking process
may involve third party cookies being placed on your machine or other device. We may also use embedded widgets
on this MTradeGo to enable content sharing through social media networks.
13.8 Opt Out for Cookies
There are a number of options available to opt-out for cookies. You can set your browser to either block all cookies;
to only allow “trusted” sites to set them, or to accept cookies only from the MTradeGo that you are currently on. If
you choose to block all cookies, you may experience problems accessing certain areas of this MTradeGo.
You can find out more about cookies at www.allaboutcookies.org and the site will give you guidance on how to
control and delete unwanted cookies you have already accepted.