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Legal & Compliance

Privacy Policy

Traydstream is committed to protecting your privacy. This policy explains how we collect, use, share, and protect your personal information across all our platforms and services.

LAST UPDATEDApril 2025
VERSIONv8.0
1

Overview & Definitions

As a leading technology platform provider, Traydstream Limited together with its affiliates ("we", "us" or "Traydstream") takes your privacy seriously. It is fundamental to how we operate. This policy explains how we collect, use, share, and protect your information.

Key Definitions

PERSONAL INFORMATION

Refers to types of information we may collect and use, including:

  1. Contact details such as your name, email address, postal address and telephone number
  2. For employees: emergency contact details, salary, date of birth, gender, marital status (if required by law)
  3. Professional background information
  4. Comments, feedback, posts and other content submitted
  5. Interests and communication preferences including marketing permissions
  6. Location information (e.g. the country in which you are based)
  7. IP address information and information relating to your use of the website
  8. Non-identifiable information which, when combined with other data, can identify an individual

DATA SUBJECT

Individuals that are identified or identifiable by Personal Information. "Processing" means any operation performed on Personal Information, whether or not by automatic means, such as collection, recording, organization, storage, retrieval, use, or disclosure.

SENSITIVE PERSONAL INFORMATION

A subset of Personal Information that, due to its sensitive nature, has been classified by law or policy as requiring additional privacy protection. Processed only when required by law or provided voluntarily with explicit consent.

THIRD PARTY SERVICE PROVIDER

Any natural or legal person, public authority, agency, or other body apart from Traydstream that processes or stores Personal Information solely on behalf of and under the instructions of Traydstream, under contractual obligation and in compliance with privacy laws.

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What Data Do We Collect?

We collect only the Personal Information necessary to deliver our services, fulfil contracts, and meet legal obligations.

  1. Identification and contact data
  2. Employment-related data (for internal HR purposes)
  3. Preferences and interests
  4. Technical and usage data via cookies
  5. Sensitive Personal Information where legally required or voluntarily provided
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How Do We Use the Data?

We process your Personal Information for the following purposes:

  1. Delivering and improving our services
  2. Communicating with you and responding to inquiries
  3. Managing recruitment and HR processes
  4. Complying with legal obligations
  5. Conducting marketing (with proper consent)
  6. Preventing fraud and securing systems
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Privacy Principles & Data Sharing

Traydstream will only share your Personal Information with others for the following purposes:

  1. At your request
  2. To process or service a transaction or product authorized or requested by you — this may include sharing within the Traydstream group of entities
  3. When required by law to disclose such information to appropriate authorities
  4. To companies that assist us in marketing, recruiting, placement and servicing our products and services
  5. In connection with corporate restructuring or reorganization process
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Cookies

Our website utilizes standard technology called "cookies" and web server logs to collect information about how our website is used. Cookies are small pieces of data stored by a user's web browser.

Information gathered through cookies and web server logs may include the date and time of visits, pages viewed, time spent on our website, and the website visited just before and just after ours. This information is collected on an aggregate basis and is not associated with you as an individual.

How to Manage Cookies

You can control cookie usage via your browser settings. Disabling cookies may affect the functionality of certain website features. Refer to your browser's help documentation for detailed guidance.

You can disable cookies on your computer by indicating this in the preferences or options menus in your browser. However, it is possible that some parts of our website will not operate correctly if you disable cookies.

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Storing & Retaining Your Information

We store information on Azure and Amazon web servers located in the United States of America and Europe.

  1. Cookie data is kept for 30 days, after which it is disposed of and cookies are reset
  2. Other Personal Information is stored for the duration of our relationship and 120 days after the relationship has ended and/or consent is withdrawn
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Security

The security of all information including Personal Information is extremely important to Traydstream.

  1. We implement and maintain a data security program that includes appropriate administrative, technical, physical, and operational safeguards
  2. Safeguards are designed to maintain security and confidentiality of Personal Information and protect against accidental, unlawful, or unauthorized destruction, loss, alteration, or disclosure
  3. We implement and maintain practices designed to secure the access, storage, and transmission of Personal Information
  4. We maintain appropriate security upon the disposal and destruction of records containing Personal Information
  5. We restrict access to Personal Information to those employees who need to know that information to provide our Services
  6. We train our employees about the importance of confidentiality and maintaining the privacy and security of Personal Information
  7. We have implemented protocols to verify ongoing compliance and enforce disciplinary action against violations

To report a privacy violation, contact info@traydstream.com

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Data Integrity

We endeavour to keep Personal Information accurate and current; and we update it whenever we receive a request to do so.

  1. We take reasonable steps to ensure the Personal Information we have collected is accurate, complete, and current
  2. We rely on the accuracy and completeness of the Personal Information provided to us to perform the requested Services
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Your Rights

Based on jurisdiction, individuals may have certain access, erasure, and other rights relating to their Personal Information.

As an EU Citizen

As a data subject under EU data protection laws, you have specific legal rights relating to the Personal Information we collect from you:

  1. Right to withdraw consent — where you have given consent for processing, you may withdraw it at any moment
  2. Right to rectification — you may obtain rectification of inaccurate Personal Information
  3. Right to restriction — you may require us to restrict processing of your Personal Information in specific circumstances
  4. Right to access — you may request information regarding Personal Information we hold about you, including categories and usage
  5. Right to portability — you have the right to receive Personal information you have provided to us in a structured, machine-readable format
  6. Right to erasure — you have the right to request deletion of Personal Information we process about you (subject to legal exceptions)
  7. Right to object — you may object to the processing of your Personal Information due to your particular situation
  8. Right to lodge a complaint — you can lodge a complaint with the data protection authority in your Member State or in the Republic of Ireland

Children's Online Privacy Protection

Our website and services are not intended for children under 16 years of age. We do not knowingly collect Personal Information from children. If we learn that we have collected information from a child without appropriate consent, we will delete it.

Important Notes

  1. We will try to fulfill your request within 30 days (may be extended for complex requests)
  2. In certain situations, we may not be able to give you access to all personal data due to statutory provisions
  3. If we cannot identify you as a data subject, we may not be able to comply with your request without additional identification information
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ICO Registration & Document Control

ICO Registration Number:ZA522383

This Policy needs to be formally reviewed on a yearly basis or if required changes are identified. A change in business activities, the way Traydstream manages Information assets, or an identified shortcoming in effectiveness may also trigger a review.

versiondateNotesApproved By
1.0TBCInitial draft of policyNA
2.0TBCRevised following initial feedback from Senior ManagementSenior Management
3.0February 2019Updated to reflect latest scopeExecutive Management Committee
4.0August 2021Updated to reflect latest scope and WFH due to pandemicExecutive Management Committee
5.0June 2022Minor changes; WFH updatesLead - People & Culture, CRO, CEO
6.0September 2023Annual ReviewLead - People & Culture, CRO, CEO
7.0May 2024Annual ReviewLead - People & Culture, CRO, CEO
8.0April 2025Annual ReviewChief Risk Officer