Политика конфиденциальности

Redot Exchange Privacy Policy
Last revised: 1 February 2022


“Redot” “us”, “our” or “we”, “website” in this Privacy Policy refers to an ecosystem comprising Redot
websites (whose domain names include but are not limited to https://redot.com), mobile applications, clients,
applets, and other applications that are developed to offer Redot Services, and includes independently-operated
platforms, websites, and clients within the ecosystem. “Redot Operators” refer to all parties that run Redot,
including but not limited to legal persons, unincorporated organizations, and teams that provide Redot Services
and are responsible for such services. “Redot” as used in this Policy includes Redot Operators.

Any reference to “you”, “your”, “yours” or “yourself” in this privacy notice is a reference to any of our
customers and potential customers as the context requires unless otherwise stated.

This Privacy Policy applies to all platforms, websites, and departments of Redot and Redot Operators. By
using Redot Services, you are consenting to the collection, storage, processing, and transfer of your personal
information as described in this Privacy Policy. Redot Operators are the data controllers for personal
information collected in connection with the provision of Redot services.

Your privacy is very important to us. We are committed to protecting and respecting your personal data. This
Privacy Policy describes what types of personal data we collect about you when you choose to use our
services, how we will use your personal data, when and with whom we share it and how we will keep it safe. It
also details your rights in respect of our processing of your personal information and how you may exercise
them. Please take the time to read and understand this policy.

We may make changes to this Notice from time to time and it is important that you check this Notice for any
updates. Any personal information we hold will be governed by our most current privacy notice. If we make
changes, we consider to be important, we will communicate them to you.

Please note that this notice is addressed to customers and potential customers. If you are a Redot employee,
contractor to Redot or a third-party service provider, your personal information will be used in connection with
your employment contract, your contractual relationship, or in accordance with our separate policies which are
available by contacting us.

By accessing our websites including using any of the communication channels to contact us, we consider that
you have read and understood the terms of this notice and how we process any information you disclose to us
including personal data prior to becoming a client. Once you open an account with us, you agree that this
notice, including any amendments, will govern how we collect, store, use, share, and in any other form of process
your personal data and your rights during our business relationship and after its termination.


As part of our business, we collect personal data from customers and potential customers including the
• name, surname, and contact details
• date of birth and gender
• photograph(s) and video(s)
• information about your income and wealth including details about your assets and liabilities, account
balances, trading statements, tax, and financial statements
• ID and passport photograph(s)
• profession and employment details
• location data
• knowledge and experience in trading, risk tolerance, and risk profile
• IP address, device specifications, and other information relating to your trading experience
• bank account, e-wallets, and credit card details
• details of your visits to our Website or our Apps including, but not limited to, traffic data, location data,
weblogs and other communication data.
• transaction history
• information from other sources: we may receive information about you from other sources such as credit
history information from credit bureaus
• information about your behavior: we may process information about you on your behavior and your
activity for marketing and advertising purposes

We use cookies to store and collect information about your use of our Website. Cookies are small text files
stored by the browser on your equipment's hard drive. They send information stored on them back to our web
server when you access our Website. These cookies enable us to put in place personal settings and load your
personal preferences to improve your experience. You can find out more about our cookies on our "Cookies
We also keep records of your trading behavior, including a record of:

• products you trade with us
• historical data about the trades and investments you have made including the amount invested
• your preference for certain types of products and services

Depending on your jurisdiction, we may be required by law to identify you if you are opening a new account or
adding a new signatory to an existing account. Anti-money laundering laws may require us to sight and record
details of certain documents (i.e. photographic and non-photographic documents) to meet the standards, set under
those laws. Identification documentation, as required under anti-money laundering legislation or other
legislation relevant to the services we provide to you includes:

• (a) passport;
• (b) driver's license;
• (c) national identity card (if applicable);
• (d) utility bills;
• (e) trust deed (if applicable);
• (f) a credit check on the individual; or
• (g) other information we consider necessary to our functions and activities.

If you are a corporate client, depending on your jurisdiction, we may be required to collect additional
information such as corporate documents of address, shareholders, directors, officers including additional
personal information on the Shareholders and Directors. We have the right to ask any additional information
we deem necessary to be compliant with our legal and regulatory requirements.

We obtain this information in a number of ways through your use of our services and websites, the account
opening applications, our demo sign up forms, webinar sign up forms, website cookies, and similar tracking
technology built into our Websites and Apps, subscribing to news updates and from information provided in
the course of our ongoing relationship.

We may also collect this information about you from third parties either through bought-in third-party marketing
lists, publicly available sources, social media platforms, introducing brokers and affiliates, bankers and credit card
processors, subscription-based intelligence databases and other third-party associates.

We may ask for other personal information voluntarily from time to time (for example, through market
research, surveys or special offers). If you choose not to provide the information, we need to fulfill your request
for a specific product or service, we may not be able to provide you with the requested product or service.

We may record any communications, electronic, by telephone, in person or otherwise, that we have with you
in relation to the services we provide to you and our relationship with you. These recordings will be our sole
property and will constitute evidence of the communications between us. Such telephone conversations may be
recorded without the use of a warning tone or any other further notice.

Further, if you visit any of our offices or premises, we may have CCTV which will record your image.


As part of using your personal information for the purposes set out above, we may disclose your information to:

• other companies within the Redot group who provide financial and otherservices;
• third party apps providers when you use our apps, communication systems and trading platforms which are
provided to us by third parties;
• service providers and specialist advisers who have been contracted to provide us with services such as
administrative, IT, analytics and online marketing optimization, financial, regulatory, compliance,
insurance, research or otherservices;
• introducing brokers and affiliates with whom we have a mutual relationship;
• payment service providers and banks processing your transactions;
• auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;
• courts, tribunals and applicable regulatory authorities as agreed or authorized by law or our agreement with
• government bodies and law enforcement agencies where required by law and in response to other legal and
regulatory requests;
• any third-party where such disclosure is required in order to enforce or apply our Terms and Conditions of
Service or other relevant agreements;
• anyone authorized by you.

We endeavor to disclose to these third parties only the minimum personal data that is required to perform their
contractual obligations to us. Our third-party service providers are not permitted to share or use personal data
we make available to them for any other purpose than to provide services to us.

Our websites or our apps may have links to external third-party websites. Please note, however, that third-party
websites are not covered by this privacy notice and those sites are not subject to our privacy standards and
procedures. Please check with each third party as to their privacy practices and procedures.


We may process your personal data for one or more lawful bases of processing ("Lawful Basis") depending on
the specific purpose for which we are using your data.

The Lawful basis are the following:

• to perform our contractual obligations towards you
• to be compliant with the legal and regulatory requirements
• to pursue our legitimate interests

Where our use of your personal information does not fall under one of these three Lawful basis, we require
your consent. Such consent shall be freely given by you and you have the right to withdraw your consent at
any time by contacting us using the contact details set out in this privacy notice or by unsubscribing from
email lists.


We are committed to safeguarding and protecting personal data and will implement and maintain appropriate
technical and organizational measures to ensure a level of security appropriate to protect any personal data
provided to us from an accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to
personal data transmitted, stored or otherwise processed.

We have appointed a Data Protection Officer to ensure that our management of personal information is in
accordance with this privacy notice and the applicable legislation.

We require organizations outside the Redot who handle or obtain personal information acknowledge the
confidentiality of this information, undertake to respect any individual's right to privacy and comply with all
relevant data protection laws and this privacy notice.

In brief, the data protection measures we have in place are the following:

• we train our employees who handle personal information to respect the confidentiality of customer
information and the privacy of individuals
• requiring our employees to use passwords and two-factor authentication when accessing our systems;
• we apply Chinese walls and employees only have access to the personal data required for the purposes of
the tasks they handle.
• we apply data encrypting technologies during data transmission during internet transactions and client
access codes transmitted across networks
• employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorized
persons and viruses entering our systems;
• using dedicated secure networks or encryption when we transmit electronic data for purposes of
• practicing a clean desk policy in all premises occupied by us and our related bodies corporate and providing
secure storage for physical records; and
• employing physical and electronic means such as access cards, cameras and guards to protect against
unauthorized access.


We hold personal information in a combination of secure computer storage facilities and paper-based files and
other records and take steps to protect the personal information we hold from misuse, loss, unauthorized access,
modification or disclosure.

When we consider that personal information is no longer needed, we will remove any details that will identify
you or we will securely destroy the records.

However, we may need to maintain records for a significant period of time. For example, we are subject to
investment services and anti-money laundering laws which require us to retain copies and evidence of the
actions taken by us in regard to your identity verification, sources of income and wealth, monitoring of your
transactions, telephone, chat and email communications, orders and trades history, handling of your complaints
and records that can demonstrate that we have acted in line with regulatory code of conduct throughout the
business relationship. These records must be maintained for a period of five years after our business
relationship with you has ended or even longer if we are asked by our Regulators.

Where you have opted out of receiving marketing communications, we will hold your details on our suppression
list so that we know you do not want to receive these communications.

The data that we collect from you may be transferred to, and stored at, a destination outside the European
Economic Area (" EEA"). It may also be processed by staff operating outside the EEA who work for us or for
one of our suppliers or Affiliate companies. We will take all steps reasonably necessary to ensure that your
data is treated securely and in accordance with this Privacy Policy.

When we transfer your data to other third parties outside the EEA, we may in some cases rely on applicable
standard contractual clauses, binding corporate rules, the EU-US Privacy Shield or any other equivalent
applicable arrangements.

If you would like a copy of such arrangements, please contact us using the contact details below.


Please note that these rights do not apply in all circumstances. You are entitled to:

(a) request access to your personal data (commonly known as a "data subject access request");
(b) request correction of the personal data that we hold about you;
(c) request erasure of your personal data. Note, however, that we may not always be able to comply with your
request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your
(d) object to processing of your personal data where we are relying on a legitimate interest (or those of a third
party) and there is something about your particular situation which makes you want to object to processing
on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to
object where we are processing your personal data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your information which override your
rights and freedoms;
(e) request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios:
• if you want us to establish the data accuracy;
• where our use of the data is unlawful, but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or
defend legal claims; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate
grounds to use it;
(f) request the transfer of your personal data to you or to a third party. We will provide to you, or a third party
you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that
this right only applies to automated information (i.e. not to hard copies) which you initially provided
consent for us to use or where we used the information to perform a contract with you; and
(g) withdraw consent at any time where we are relying on consent to process your personal data.
Please complete the personal data request by email using the registered email address you disclosed to us, to
the following email address: help@redot.com.

We try to respond to all requests within 1 (one) month. Occasionally, it may take us longer than 1 (one) month
if your request is particularly complex or you have made a number of requests. In this case, we will notify you
within 1 (one) month of the receipt of your request and keep you updated.

We may charge you a reasonable fee when a request is manifestly unfounded, excessive or repetitive, or we
receive a request to provide further copies of the same data. In this case, we will send you a fee request which
you will have to accept prior to us processing your request. Alternatively, we may refuse to comply with your
request in these circumstances.


If you want to exercise your rights, please contact us by email at help@redot.com using the registered email
address you disclosed to us.

We try to respond to all requests within 1 (one) month. Occasionally, it may take us longer than 1 (one) month
if your request is particularly complex or you have made a number of requests. In this case, we will notify you
within 1 (one) month of the receipt of your request and keep you updated.