When you contact Spotware via our contact form, we ask you to specify the method you would like us to use to contact you. Because of this, we request from you only the information required to contact you in accordance with your wishes, for example, if you want us to contact you by Skype, we will not ask you for your phone number.
When you submit the contact form we collect the following information;
When you send an email to Spotware we collect the details received from you in that email which are stored in our CRM and in our email archive.When you make a telephone call to Spotware, we record the call.
We use this information to contact you, discuss the nature of your inquiry, be able to share that information amongst the sales team and keep important points from the correspondence we have with you, for example if you asked for specific features that we must investigate and revert at a later time or plan to develop in the future.The retention policy of the information we collect from you
We retain this information for 24 months after the last digitally recorded correspondence we had with you. After this period, our retention policy dictates that we delete your details from our CRM and email archive.
We retain recorded phone calls for a period of 12 months, after which, the call will be permanently deleted.
At any time, you can contact us and request us to disclose, modify or under specific circumstances, even delete the information we hold about you.
When you create a demo account in cTrader with Spotware, we require and collect your email address as a unique way to identity you and provide useful features;
We collect performance related data, such as crash analytics and a variety of product usage analytics, including;
At any time, you can submit a formal request for your data to be disclosed, modified or under specific circumstances, even deleted. Circumstances which may mean we shall not be able to fulfil a request for deletion, include for example, when you trade via a broker offering our products, your data belongs to that broker and the request must be managed by them, in accordance with their financial regulatory guidelines and anti money laundering obligations
The cTrader platform is a service provided to and operated by brokers. Spotware provides brokers with a combination of applications and components which are used to provide a trading platform to you for online trading.Specifically, Spotware provides the following which may have an effect on the ways and mechanisms you may be able to exercise your privacy rights;
this is an administration platform, it’s an interface which is used internally by your broker for a variety of tasks, such as analytics, troubleshooting and reporting. Your broker can limit access rights internally and can only permit access to authorized persons, however, your broker administers these access rights. This application allows brokers to enter and store personal information such as your name, address, ID number, contact details and more. Spotware does not require your broker to submit to us any personally identifiable information except from your email address, which used to create your cTrader ID. This application is available to Spotware personnel, but is restricted on a need to know basis.Databases and Server:
Spotware either hosts the cTrader solution on behalf of brokers or the solution is hosted on-site, however Spotware still retains root-access and the ability to access any such data at any time. This is critical to allow us to troubleshoot problems and provide support, with the objective of a seamless experience for all traders.What information we collect from you
Spotware collects and process for its own use performance related data, such as crash analytics and a variety of product usage analytics, including;
While providing this service, Spotware may store and have access to personally identifiable information about users. Nevertheless, we do not process or share this information with any third party. To find out the specific information which is shared with Spotware by your broker, you must make appropriate inquiries with your Broker directly, because it may vary from broker to broker.How we use information we collect from you
Your personal information is collected in conjunction with the service Spotware provides to your broker.
In this circumstance, Spotware is not able to take action on any requests regarding disclosure, modification or deletion of personal data from the public. Any such requests must be issued to your broker and formally requested by them, on your behalf. Please note that the ability for your broker to respond may also be restricted due to the financial regulations they are subject to and which may take precedence over GDPR.The retention policy of the information we collect from you
All of the data we collect in conjunction with providing services to the broker(s) you have chosen to use is retained by Spotware’s according to the specific brokers retention policy. Once the broker terminates their agreement with Spotware, the broker will have the opportunity to take ownership of all data collected by Spotware throughout the period that the services were provided. After termination of the contract between the broker and Spotware all data held by Spotware (both identifiable and not identifiable) shall be deleted within 90 days.
Spotware.com does not automatically collect any personal information from visitors to the website, and we do not request by default any identifiable information.Cookies
Spotware.com uses internet cookies to facilitate easier navigation throughout the website and increase visitor convenience. Your internet browser is likely to accept these cookies by default, however you can refer to your browser’s help guide if you would like to reject or delete them from your system.
We may use both “session” cookies and “persistent” cookies on the website. We will use the session cookies to: keep track of you whilst you navigate the website; and other uses. We will use the persistent cookies to: enable our website to recognise you when you visit; and other uses.
Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
Cookies used by spotware.com do not retrieve any personal information or any information from the visitor’s computer.Pixels
Spotware.com has several third party pixels installed in order to use the retargeting features of advertising platforms such as Google Ads, Facebook and Adroll. Pixels are also used for certain analytics like heatmaps to learn how users interact with our site and identify flaws in the user experience and navigation, currently we use Yandex heatmaps.
Pixels used by spotware.com do not retrieve any personal information or any information from the visitor’s computer.
cTrader.com is a public forum. The information on this site is either submitted by Spotware or by registered users of the site. The information posted here is public to anyone and visible to search engines.What information we collect from you
When you post on this site, you consent to the fact that anyone can see your user name and the information and opinions expressed in what you post.
You cannot delete your post once submitted, it can only be edited. Only site admins have the ability and authority to delete posts when a post violates the policy of the site. You are able to update your user name at any time. Your user name is shown next to the posts you submit. While your comments cannot be deleted, they can be made anonymous, by changing the user name to “Deleted User” when you request us to delete your account, but the post will remain in its most updated form, as removing it will disrupt the flow of the conversation.
The trading robots and custom indicators you submit to the site can be withdrawn at any time.
The measures we employ include logical access controls and user management with the objective of minimising access to personal (and other customer) information and data, only to authorised Spotware personnel. We utilise robust user access credentials management with enforced frequent changes, password complexity and maximum / minimum lengths, restrictions on reuse of same passwords, etc., complemented by a structured process for periodic review and confirmation of continued business need to such personal data. In addition, Spotware uses purpose-specific technologies and tools (such as firewalls, intrusion prevention, email security gateways, etc.), all designed to monitor and manage the security of its electronic perimeter. Spotware has in place an active and ongoing patch management program across security, server and endpoint devices for addressing newly released threats, and benefits from the use of endpoint malware protection at laptop, servers and desktop level. Finally, we also employ endpoint encryption, to protect against privacy risks in cases of hardware theft or loss.
This section highlights the third party products or solutions used by Spotware and in what context they are used.Gmail from Google
If you email Spotware; your email correspondence may be visible to GoogleMailChimp
If you have given your consent to be subscribed to one of our mailing lists, your email address, first name and last name will be shared with MailChimp in order to send emails to you.Sendinblue
If you have given your consent to be subscribed to one of our mailing lists, your email address, first name and last name will be shared with Sendinblue in order to send emails to you.SparkPost
If you have opted in to receive email notifications for trading related events, your email address, cTrader ID nickname as well as the trading related details disclosed in the template are shared with SparkPost.Mandrill
If you have opted in to receive email notifications for trading related events, your email address, cTrader ID nickname as well as the trading related details disclosed in the template are shared with Mandrill.Pipedrive
When you firstname.lastname@example.org this email are routed to the FreshDesk ticketing system.
Spotware Systems has outsourced the responsibilities of it’s Data Protection Officer to PhoenixPro. Our DPO details can be found below, where all privacy-related correspondence should be directed:Georgios A. Korellis