TPHIT and its affiliates (hereinafter, “TPHIT”, “we”, “us” or “our”) are committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of Use) governs our collection, processing and use of your Personal Information. We define “Personal Information” as information that identifies you personally: your email address, IP address and trades. The purpose of this Privacy Policy is to inform you of:

Gathering and use of personal information

We may collect your Personal Information if you use the Site, open an Account to use the Platform or perform any Transactions on the Platform. The types of Personal Information that we collect may include:

Personal data is collected only according to the order set by law regulations, by receiving it directly from data subject, officially inquiring the subjects, who are qualified to manage and provide it, about the necessary information and connecting, on the grounds of agreements and law regulations, to the databases, registers and information systems storing particular data. We may use your Personal Information for the following purposes:

We will process your Personal Information only for the purpose(s) for which it has been provided to us.

IP addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

Cookies

The TPHIT site uses cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyse trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We use third-party service providers to assist us in better understanding the use of our Site. Our service providers may place cookies on the hard drive of your computer and receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information. Our service providers analyse this information and provide us with aggregate reports. The information and analysis provided by our service providers can be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our service providers may be linked to and combined with information that we collect about you while you are using the Platform. Our service providers are contractually restricted from using the information they receive from our Site other than to assist us. By using our Site you are agreeing that we may use cookies for the purposes set out above.

Disclosure of personal information

We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law. You acknowledge that by using our Services and your acceptance of the TPHIT Terms of Use that you will be providing us with Personal Information. You consent to us disclosing that information where we are required by law to third parties. Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. Any third party that receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for TPHIT unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit. We do not control those third-party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third-party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites.

Correction / updating / deletion of personal information

You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us at Contact. TPHIT will action your request only where this is not inconsistent with its Terms of Use, legal and regulatory obligations. Upon your written request, we will provide you with the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information.

Security

We have implemented security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction. We implement a variety of security measures to maintain the safety of your personal information when you submit a request, place an order or access your personal information. These security measures include: password protected directories and databases to safeguard your information, SSL (Secure Sockets Layered) technology to ensure that your information is fully encrypted and sent across the Internet securely and other measures to protect our servers from hackers and other vulnerabilities. Only authorized personnel of TPHIT have access to your Personal Information, and these personnel are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

Retention of personal information

We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain Accounts and Personal Information for, at least a period of five years after they are closed by Users.

Changes

Our Site policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of TPHIT. If we change this Privacy Policy, we will take steps to notify users by a notice on our Site and will post the amended Privacy Policy on the Site.