PRIVACY POLICY

1. WHO WE ARE

QCL QUAD CODE CY LIMITED, is a company registered in the Republic of Cyprus having its registered address at 82nd street, no. 4 Kato Polemidia, 4153, Limassol, Cyprus. We are the controller and responsible for the data of the users disclosed to us in order to register for an account.

We take measures to implement advanced data protection policies and procedures and to update them from time to time for the purpose of safeguarding the user's data and account. Your data is protected by the legal, administrative and technical measures that we take to ensure the privacy, integrity, and accessibility of data. To prevent security incidents with your data, we use a variety of organizational and technical measures.

We shall not divulge any private information of our users and/or former users, unless provided hereunder or the users approve so in writing or unless such disclosure is required under applicable law or is required in order to verify the user's identity, or it is required for us, to perform our contractual obligations. The user's information is processed only by our employees and/or trusted third parties whose services are necessary for the provision of our services.

2. DATA COLLECTED, REASONS AND USAGE

We may collect, use, store and transfer different kinds of data about you which we have grouped together as follows:

• Identity Data: includes first name, last name, profile picture/photo
• Contact Data: includes email address
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, device information and other technologies on the device(s) you use to access the website, the use of cookies stored on your device, your browser cookies.
• Profile Data: includes your account details, password, your interests, preferences, feedback and/or information received through your interaction with us within the course of providing our services.
• Usage Data: includes information about how you use the website, registration date, IP history.
• Marketing and Communication Data: includes your preferences in receiving marketing from us and your communication preferences.
• Location Data: includes details on your actual location when interacting with our website (for example, a set of parameters that determine regional settings of your interface, namely residency country, time zone, and the interface language).

In general, we collect and process personal data, for the below purposes:

• To comply with our legal and regulatory obligations: we may process data, among others, for the purposes of complying with any applicable laws, respond to requests from competent authorities (including law enforcement and governmental authorities), protect our operations and rights, enforce or defend legal rights and respond to legal claims.
• For marketing purposes: we may send you newsletter, push-up messages, and marketing emails about our website, or information about various events, interviews and other promotions we feel may interest you. This is unless you have indicated to us that you do not wish to receive communications in this manner. Users can opt out of receiving marketing communications at any time by clicking "unsubscribe" in one of the emails. In such a case, we will stop sending you marketing materials and/or other content, within a reasonable time.
• To safeguard our legitimate interests and your vital interests: we will process personal data as necessary for certain legitimate business interests such as, to administer our website and better understand how visitors interact with it, to develop and improve our website, to conduct data analysis, testing and research, for statistical and survey purposes, to keep our website, network, and information systems secure, to respond to any of your inquiries or comments.

Personal data might also be collected on the basis of your consent. We do not generally rely on your consent to allow us to process your personal data if there is another lawful ground available. If we do rely on your consent, we will make this clear to you at that time.

The user is responsible for updating any data provided to us in case of any change. Although we will strive to keep your data up to date and review and inspect any information provided by you, we may not be able to always do so without your help. You acknowledge that we hold neither commitment nor responsibility to you, due to any aforesaid review or inspection of information.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you, including through:

• Direct Interactions. You provide us with your personal data through the website and/or by registering online for an account and/or by corresponding with us by emails or otherwise.

• Automated Technologies or Interactions. When using our services or visiting the website, your device automatically transmits to us its technical characteristics (a set of parameters that determine regional settings of your interface, namely, residence country, time zone and the interface language).We use web analytics tools to track the performance of our website and marketing source of users by cookies in order to optimize our marketing costs and provide users with a better experience.

  You may at any time request that we refrain from any such transmissions (to the degree this is possible and subject to any of our legal obligations), by sending a request via the email address that you disclosed when you registered for an account, by using our details in the Section OUR CONTACT DETAILS below. When you do so, please use the email address you disclosed and registered with us through your Account. We will address your request within 30 business days.

• Cookies: cookie is a small amount of data that often includes a unique identifier that is sent to your computer or device browser from a website's computer and is stored on your device's hard drive for tracking site usage. A website may send its own cookie to your browser, if your browser's preferences allow it. To protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows. When you visit our website, our system automatically collects information about your visit, such as your Technical Data, including, inter alia, your browser type, your IP address and the referring website. Cookies stored may determine the path the user took on our site and anonymously identify repeat users of the website and what pages were most popular. Using cookies is an industry standard and is currently used by most major websites. Stored cookies allow the website to be more user-friendly and efficient for users, while enabling us to know what information is more valued by the users. You can set your browser not to save any cookies from this website, and you may also delete cookies automatically or manually. However, please note that by doing so, you may not be able to use all the provided functions of our website in full.

4. LEGAL BASIS FOR PROCESSING

We set out below a description of all the ways we plan to use your data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process the data for more than one lawful ground, depending on the specific purpose for which we are using your data.

5. DISCLOSURE OF PERSONAL DATA / INTERNATIONAL TRANSFERS

We may share your data with third parties, for the purposes set out above.We take all necessary steps to ensure that these third parties process and treat your personal data in accordance with the provisions of the GDPR and the applicable local legislation, as amended from time to time. We take all reasonable steps so that our third-party service providers do not use your personal data for their own purposes, and we only permit them to process your data for specific purposes and in accordance with our instructions.

In general personal data is shared with:

1. Entities of our group and/or affiliated entities, provide us with relevant services;
2. Service providers: we may share your personal data with our trusted third party service providers, who, on our behalf, operate, maintain, and/or support our website, perform statistical analysis, provide marketing and advertising services and/or perform other important services for us.
3. Regulators and other competent authorities: Any information that is provided and/or will be provided by the user during his/her activity on the website, may be disclosed by us to the regulators and/or other competent authorities. We will make such disclosure only if so required under the applicable law, regulation or court order, and to the minimum required extent.

Other disclosures:

• In addition to where you have consented to a disclosure of the data or where disclosure is necessary to achieve the purpose(s) for which, it was collected, data may also be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise, or defense of legal claims.

• a transfer of your data to another legal entity may also occur as part of a transfer of our business or parts thereof in the form of a reorganization, sale of assets, consolidation, merger or similar.

  Where reasonably possible, we shall ensure that third parties collecting, storing or processing personal information on our behalf have:

• Signed agreements to protect personal information consistent with this Privacy Policy and established information security practices or implemented measures as prescribed by GDPR;
• Signed non-disclosure agreements or confidentiality agreements which include privacy clauses in the contract; and
• Established procedures to meet the terms of their agreement with third parties to protect personal information.

The use of service providers and disclosure of your data to other affiliated companies and/or third parties might imply a transfer of your data to third countries, which may not fall within the ambit of the GDPR (Third Countries) (International Transfers). In such cases, we require that all recipients of your data provide appropriate safeguards to protect your data, when it is transferred to Third Countries, through the adherence to standard data protection clauses adopted by the EU Commission (cf. the GDPR article 46(2) and/or binding corporate rules adopted by the EU Commission (cf. GDPR article 47). A transfer to an affiliate and/or related company and/or third party based in a Third Country would only take place where one of the following applies:

• The individual has given consent to the transfer of information
• The transfer is necessary for the performance of our services, or the implementation of pre-contractual measures taken in response to the individual's request
• The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between us and a third party
• The transfer is necessary or legally required on important public interest grounds or for the establishment, exercise, or defense of legal claims.
• The transfer is required by law.
• The transfer is necessary in order to protect the vital interests of the individual.
• The transfer is made under a data transfer agreement.
• The transfer is otherwise legitimized by applicable law.

Remedial action shall be taken in response to misuse or unauthorized disclosure of personal information by a third-party collecting, storing or processing personal information on our behalf. If you want to obtain further information on any data transfers mentioned above, please contact us through the points of contact listed in section OUR CONTACT DETAILS below, by using the email address you disclosed when registering for an account with us.

6. DATA RETENTION

We store your personal data for as long as reasonably necessary to fulfill the purposes for which it was collected, including, inter alia, to satisfy any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting and other requirements.

At the expiration of the data retention period the data is erased by irreversible destruction, and we also inform all third parties, to whom the data was transferred, regarding such erasure and request implementation of similar actions on their part.

If you consent to receive marketing communications, we will keep your data until you unsubscribe, which is possible via the 'unsubscribe' button at the end of our marketing emails. Additional methods to unsubscribe may be added in the future.

7. YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE

We ask you to provide us with true, accurate and updated information on your identity and not misrepresent yourself to be another individual or legal entity. Any changes in your identifying details shall be notified to us immediately and in any case no later than within seven (7) business days from the date of such changes. If your data is incorrect or incomplete, please contact us at the contact details listed in the section OUR CONTACT DETAILS below, to change your data.

Under certain circumstances, you have rights in accordance with the provisions of the GDPR and the applicable local legislation, as amended from time to time. Some of the rights are rather complex and include exemptions; thus, we strongly advise you to contact us and/or seek guidance from the regulatory authorities for a full explanation of these rights. You can find a summary of your rights below in this section.

• The right to access: You have a right to obtain the confirmation as to whether or not your personal data is being processed by us. In addition, you have the right to obtain more detailed information about the data kept and the processing undertaken by us, and, under certain circumstances, you have the right to receive a copy of this personal data.
• The right to rectification: You have the right to have inaccurate data about you rectified, and, taking into account the purpose of the processing, to have incomplete data completed.
• The right to erasure ("the right to be forgotten"): This right enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request for partial and/or complete deletion and/or erasure of your data, for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• The right to restriction of processing: You have the right to request the restriction of processing of your personal data (a) if it is not accurate;(b) where processing may be unlawful, but you do not want us to erase your data; (c) where you need us to hold the data even if we no longer require it; or (d) where you may have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• The right to data portability: To the extent the legal basis for the processing is your consent, and such processing is carried out by automated means, you have the right to receive your data in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others and/or in case it may be technically impossible to do so.
• The right to object: Subject to the legal basis on which the processing activity is based, you may object to processing of your personal data. Please note that in some cases, we may have compelling legitimate grounds to process your information which we need to comply with.
• The right to withdraw consent: To the extent that the legal basis for the processing is your consent, you have the right to withdraw from that consent at any time. This may apply to marketing purposes and/or with regard to the transfer of your data to third parties. In case you withdraw from a consent given, then we will cease to process your data, unless and to the extent the continued processing is permitted or required according to the applicable data regulation or other applicable laws and regulations. The withdrawal of your consent will in no event affect the lawfulness of processing based on consent before its withdrawal.
• The right to complain: We do our best to ensure that we protect your data, keep you informed about how we process your data, and comply with the applicable data protection regulations. In case you are not satisfied with the processing and protection of your data or the information you have received from us, then we urge you to inform us in order for us to improve.

If you want to exercise any of your rights mentioned above and/or obtain more information regarding your rights and/or our policies and procedures, please contact us through the points of contact listed in the Section OUR CONTACT DETAILS below. Please also provide us with relevant information to take care of your request, including your full name and email address so that we can identify you. We will respond to your request without undue delay.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it could take longer than a month if your request is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.

We may charge you a reasonable administrative fee for any unreasonable or excessive requests we may receive, and for any additional copies of the data you may request.If following your request, we are unable to provide you with a satisfactory answer, then you may lodge a complaint with the local data protection supervisory authority. The data protection supervisory authority in Cyprus is Commissioner for Data Protection P.O. Box 23378, 1682 Nicosia, Cyprus www.dataprotection.gov.cy.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you and the competent regulator of a breach, where we are legally required to do so.

Your help is always valuable in ensuring that your data is kept safe. Upon registration to the Website you will be asked to choose a username and password, to be used by you on each future login. In order to protect your privacy and operation with the Website, sharing registration details (including, without limitation, username, and password) with other persons or business entities is strictly prohibited. We shall not be held responsible for any damage or loss caused to you due to improper use (including prohibited and unprotected use) of your account, including any such use made by a third party -whether or not known to or authorized by you. Keeping your account safe is your sole responsibility and you are obliged to notify us of any suspicious or unauthorized use of your account. You may contact us at any time through the points of contact listed in the Section OUR CONTACT DETAILS below.

• Encryption of your data in transit: Encryption provides a high level of security and privacy for your data and enables us to protect your data during transmission. We also use other safeguards, such as firewalls and access control mechanisms to control unauthorized access to systems and data.
• Protection of your data in our infrastructure. We make it a priority to develop services that are secure "by default". The "default" security of our services means that every new service and feature is designed with strict security requirements in mind before we even begin development. This is the key to a guaranteed protection and privacy of all data that our services handle and store, once the service or new feature is released.
• Pseudonymization: To secure your data, we use the pseudonymization which allows most of our services to operate without using your actual data.
• Secure Data Centers and other measures: We are always vigilant about the security of your data stored in our infrastructure, we are highly knowledgeable about modern threats to data security and privacy and we are well-prepared to combat them. Because of that, we: (i) process your data in secure data centers (ii) all events that occur in our infrastructure are continuously monitored, analyzed and responded to, which allows us to ensure proper protection of your data and keeping it safe from threats, vulnerabilities, and the effects of malware (iii) we restrict logical access to your data for our employees on a "need to know" basis. So, only personnel who really require access to your data for the purpose of providing you with our best service will have access to it (iv) we hold regular training sessions to make sure that each employee understands the principles that we follow to achieve robust data security and privacy (v) we generally do not use automated decision-making. If we use this procedure in individual cases, we will inform you of this separately. In some cases, we may proceed with profiling in order to evaluate certain personal aspects. We shall inform you accordingly in case we perform any profiling. In general, any data collection that is optional would be made clear at the point of collection.

In the context of our business relationship, we may need to collect data by law, or under the terms of a contract we have with you. Without this data (i) we are, in principle, not in a position to offer services to you (ii) it may delay or prevent us from meeting our obligations.

9. OUR CONTACT DETAILS

Who is responsible for the data processing and who you can contact.

The entity responsible for your data processing is QCL QUAD CODE CY LIMITED , and you can contact us using the details set out below:

Registered address: 82nd road, 4 Kato Polemidia, 4153, Limassol, Cyprus

Email: contact@tradingdashboard.com

To enable us to process your requests, please contact us using the email address you disclosed, when registering for an account. We may require that you provide us with additional information, to ensure that we appropriately protect the personal data we hold, from unauthorized access requests and comply with our security obligations.

If you have any questions, or want more details about how we use your data, you may contact us at the above contact details, and we will be happy to provide you with further details.

10. LINKS TO OTHER WEBSITES

We may provide links to third-party websites on our website. These linked websites are not under our control, and we therefore cannot accept responsibility or liability for the conduct of third parties linked to our websites, including without limitation to the collection or disclosure of your data. Before disclosing your data on any other website, we encourage you to examine the terms and conditions of using that website and its privacy policies.

11. Children and sensitive personal data

This website is not directed towards children who are under the age of 18. We do not knowingly contact or collect personal information from children below the age of 18 years, or sensitive personal data ("racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural person's sex life or sexual orientation," etc.). If you believe we have inadvertently collected such information, please contact us immediately.

12. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy was last updated on the date written below. We have the right, at our discretion, to add, modify or remove portions of this Privacy Policy from time to time to ensure that the information herein provides relevant and adequate information about our collecting and processing of your data.

This Privacy Policy may be supplemented by other information received from QCL QUAD CODE CY LIMITED and other terms and conditions applicable to the Website or which you have agreed to as part of your interaction with us.

In case of updates, we will post the revised Privacy Policy on our website. Changes will take effect as soon as the revised version is made available on our website. Your comments and feedback are always welcome. You may contact us at any time through the points of contact listed in the Section OUR CONTACT DETAILS above.

LAST UPDATE - 23rd of April 2025