Privacy Policy

Last Updated: 2025-12-17 (beta version 2.0)

1. Introduction

8118 Capital LLC FZ ("Company," "we," "our," or "us"), a company incorporated under the laws of the United Arab Emirates (UAE), operates tr8de.ai, a Software-as-a-Service (SaaS) platform offering automated trading bots ("Bots") for executing trades on behalf of users across cryptocurrencies, forex, stocks, indices, and commodities. This Privacy Policy ("Policy") governs how we collect, use, and disclose your information when you use our Services, which are currently offered in beta phase.

By using our Services, you agree to the collection and use of your personal information as described in this Policy and our Terms of Use.

Our Services may include links to third-party websites. We are not responsible for the privacy practices of these sites and recommend reviewing their privacy policies before use.

1.1 Data Protection Roles

For the purposes of applicable data protection laws, including the EU General Data Protection Regulation (GDPR), 8118 Capital LLC FZ acts as a data controller with respect to user account information, platform usage data, analytics, and communications. In relation to data retrieved from third-party exchanges or brokerage platforms via user-provided API credentials, we act as a data processor, processing such data solely in accordance with your instructions and configurations.

2. Our Services

tr8de.ai provides automated trading bots that execute trades on third-party exchanges or brokerage platforms ("Third-Party Platforms") based on your configurations. You connect your accounts via API keys, allowing the Bots to trade and retrieve data (e.g., balances, trade history) for display on the Platform. Additional features include manual trade closure and performance analytics (collectively, "Services"). The Services also include a multi-asset trading terminal that allows users to view market data, manage orders, configure strategies, and monitor performance across supported asset classes.

3. What Types of Data We Collect

We collect two types of data: Personal Data and Non-Personal Data.

  • Personal Data: Information that may identify you, such as your name, email address, or financial account details.

  • Non-Personal Data: Information that does not identify you, such as aggregated usage statistics or technical device information.

3.1 Contact Information

When you register for our Services, we collect your name, email address, and any additional contact details you provide.

3.2 Financial and Account Information

To enable the Bots to operate and display relevant data (e.g., trade history, profit/loss) to you on the Platform, we collect:

  • API Keys: Provided by you to connect your exchange or brokerage accounts to the Platform.

  • Account Data: Information retrieved via API, including portfolio size, asset allocation, and trade history.

  • Transaction Information: Details of trades executed by the Bots, such as timestamps, asset pairs, and outcomes.

Note: API credentials are encrypted at rest and access is strictly restricted. We require API keys to be configured with trade-only permissions and do not request or support withdrawal rights. You may revoke or rotate your API credentials at any time directly through the relevant third-party platform.

3.3 Trading Terminal and Strategy Data

When you use the trading terminal, we collect and process data generated through your interactions with the Platform, including open and closed orders, order parameters, strategy configurations, risk settings (such as leverage, stop-loss and take-profit levels), chart interactions, indicators applied, alerts configured, and manual trade actions. This data is used solely to operate the Services, display performance metrics, and execute trades according to your instructions. This may include interactions with the trading terminal interface, such as chart usage, order management actions, and strategy configuration changes.

3.4 Payment Information

When you purchase a subscription or services using supported payment methods, payments are handled by third-party payment processors. We do not store full payment card details. Payment transactions are processed directly by third-party payment processors. We may receive and store non-sensitive information such as transaction references, billing status, wallet addresses (where applicable), and associated contact details for accounting, reconciliation, and compliance purposes.

3.5 Usage Information

We collect data about your interactions with the Services, including pages viewed, features used, and performance metrics (e.g., Bot activity, trade outcomes).

3.6 Technical Information

We gather technical data about your device, such as IP address, browser type, operating system, language preferences, and access times.

3.7 Communication Information

When you contact us via email or support channels, we collect the information you provide, such as your name, email, and inquiry details.

3.8 Market and Third-Party Data

We process market data, price feeds, and related information obtained from third-party exchanges, liquidity venues, and data providers for purposes of charting, analytics, performance reporting, and execution of trades within the Services.

4. Tracking Technologies

We use tracking technologies (e.g., cookies, pixels) to improve your experience, enhance our Services, and deliver personalized content. These technologies help us analyze usage patterns, optimize performance, and tailor advertisements.

4.1 Categories of Tracking Technologies

  • Strictly Necessary: Essential for navigating and using the Services.

  • Tracking and Advertising: Deliver relevant ads and measure campaign effectiveness.

  • Functionality: Remember your preferences and enhance features.

  • Performance: Collect analytics on user behavior and engagement.

4.2 Managing Tracking Technologies

You can adjust preferences via our cookie settings tool (where available) or your browser settings. Disabling certain technologies may impact Service functionality. For guidance, visit:

5. Why We Collect Your Personal Data

We collect and process your Personal Data for the following purposes, based on applicable legal grounds:

  • Provide and Operate the Services: Enable registration, Bot functionality, and data display. | Performance of a contract; legitimate interests (delivering and enhancing Services).

  • User Support: Address inquiries and provide assistance. | Performance of a contract; consent (when you provide data); legitimate interests (improving Services).

  • Improve the Services: Analyze usage to optimize Bot performance and analytics. | Legitimate interests (enhancing algorithms and user experience).

  • Marketing and Advertising: Deliver personalized ads and promotions (with consent where required). | Consent; legitimate interests (tailored marketing).

  • Compliance: Fulfill legal obligations, such as AML/CTF requirements.

  • Security and Platform Integrity: Monitor system performance, prevent fraud or abuse, investigate incidents, and maintain the security and integrity of the Services. | Legitimate interests (platform security and risk management).

5.1 Automated Processing and Decision-Making

The Services use automated systems and algorithms to execute trades based on user-defined parameters and configurations. These automated processes do not constitute financial advice and do not produce legal effects beyond the execution of trades within the Platform. You remain in control of all configurations and may modify or disable automated activity at any time. Users acknowledge that market conditions, latency, and third-party platform availability may affect execution outcomes.

6. Marketing

We may use your Personal Data to send promotional materials about our Services or affiliates. You can opt out by emailing support@tr8de.ai. Service-related updates may still be sent even if you unsubscribe from marketing.

7. With Whom We Share Your Data

We share your Personal Data with:

  • Service Providers: Analytics, payment processors, and hosting services under strict confidentiality agreements.

  • Marketing Partners: For tailored ads or promotions (with consent where required).

  • Legal Authorities: As required by law or to protect our rights, safety, or property.

  • Business Transfers: In case of a merger, acquisition, or asset sale.

  • Infrastructure and Cloud Providers: Secure hosting, data storage, monitoring, and logging service providers supporting the operation of the Platform under strict confidentiality and security obligations.

We do not sell your Personal Data to third parties.

8. Data Protection Rights

If you reside in the EU or a jurisdiction with similar rights, you may:

  • Request access to your Personal Data.

  • Request correction or deletion of your Personal Data.

  • Object to or restrict processing.

  • Request data portability.

  • File a complaint with a supervisory authority.

To exercise these rights, contact support@tr8de.ai. Rights may be subject to legal limitations.

Requests will be handled by our data protection contact and processed in accordance with applicable law.

8.1 International Data Transfers

Our servers are located in the EU, but we operate from the UAE. Your data may be transferred outside the EU to the UAE or other jurisdictions. We use safeguards, such as standard contractual clauses, to ensure adequate protection in compliance with applicable laws. Where required, we rely on appropriate safeguards such as standard contractual clauses or equivalent legal mechanisms to ensure that cross-border data transfers comply with applicable data protection laws.

9. How We Protect Your Data

We implement industry-standard security measures, including encryption and access controls, to safeguard your Personal Data. However, no system is completely secure, and we cannot guarantee absolute protection. Please safeguard your information and report any suspected breaches to us immediately.

Access to Personal Data is limited to authorized personnel and service providers with a legitimate business need.

10. Retention

We retain your Personal Data for as long as necessary to provide the Services, comply with legal obligations (e.g., tax or AML requirements), resolve disputes, and enforce our policies. You may request deletion of your data by contacting us, subject to applicable legal requirements. Certain data, including transaction records, trade logs, and financial information, may be retained for extended periods where required to comply with legal, regulatory, tax, or audit obligations. Aggregated or anonymized data may be retained for analytical and performance improvement purposes.

11. Minors

Our Services are not intended for individuals under 18. We do not knowingly collect data from minors. If such data is identified without parental consent, we will delete it promptly.

12. Anonymized and Aggregated Data

We may create anonymized or aggregated data sets that do not identify individual users. Such data may be used for research, analytics, performance optimization, and development of new features and services.

13. Updates to this Policy

We may revise this Policy periodically. Changes will be posted on the Website with an updated "Last Updated" date. Significant updates will be communicated to you via email or through the Platform. Your continued use of the Services after updates indicates acceptance of the revised Policy.

14. Further Information

For questions about this Policy or your data, contact us at support@tr8de.aienvelope.

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