Privacy policy

Effective date: 1st of March 2023

MS TRADE SOLUTION TECHNOLOGY LLC, a Hungarian company with its principal place of business at Bartók Béla út 66. 3. em. 4, Budapest 1114 Hungary, and its affiliates (collectively "Company", "we" and "us") respect your privacy. We offer online and web services on displaying information about prices, volumes and analytical information of the cryptocurrency market.

This Privacy Policy describes the types of Personal Data we collect via our online presence, which include our main website at www.avstrade.me (hereinafter collectively referred to as the "Site"), as well as services and websites that we enable Internet users to access (hereinafter collectively with the Site, referred to as the "Services"). This Policy also describes how we use Personal Data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This Policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third-parties carefully.

In particular, this Privacy Policy outlines:

• What information we collect about you • How we use information we collect • How we share information we collect • Your Rights and Choices • Security and Retention • International Data Transfers • Use by Minors • Updates to this Privacy Policy and notifications • Contact Us

This Policy covers the information we collect about you when you use our Services, or otherwise interact with us (for example, by contacting us), unless a different policy is displayed.

We process your Personal Data as set out in this Policy on the basis of your consent. In situations where we obtain your data from a source other than you, we process your data on the basis of legitimate interests.

If you do not agree with this Policy, do not access or use our Services or interact with any other aspect of our business.

1. Overview

We obtain Personal Data about you from various sources to provide our Services and to manage our Site. "You" may be a visitor to one of our websites or a user of one or more of our Services ("User"). If you visit or use our Site, we may collect Personal Data. For example, we collect Personal Data that you submit to us via online forms and when you contact us by email.

2. Information we collect about you

We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.

2.1. Personal Data you provide to us

Personal Data is any information that relates to an identified or identifiable individual. We collect your Personal Data when you input it into the Services or otherwise provide it directly to us.

(i) Account and Profile Information. We collect information about you when you register for an account, create or modify your profile, set preferences. For instance, you provide your contact information (name and email), when you register for the Services. You also have the option of adding a display name, profile photo and other details to your profile information to be displayed in our Services, which is the type of information that specifically identifies you personally and/or can be used alone to contact you online or offline. We keep track of your preferences when you select settings within the Services.

Your name, photo, and any other information that you choose to add to your profile will be available for viewing to users of the Service. For more information about your choices for the displayed information, see the section below about "Your Rights and Choices".

We also will combine your personal information with all the materials that you upload such as messages, as well as with the operational information that we collect via technology while you navigate through our Services (see the section below.)

By registering with the Services you are authorizing us to collect, store, process and use your Personal Data and other your information in accordance with this Privacy Policy.

Financial Information. If you make payments for our Services, your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information), is collected and stored by a third party payment processing company (the "Payment Processor"), and use and storage of that information is governed by the Payment Processor's applicable privacy policy. We do not collect your financial information, however we may request the Payment Processor to provide us a confirmation of your payment for our Services.

(ii) Content you provide through our Services. We may collect and store content that you post, send, receive and share through our Services. This content includes any information about you that you may choose to include. Examples of content we collect and store include: the messages you send to us, comments you enter in connection with an incident, and any feedback you provide to us, or when you participate in any interactive features, surveys, contests, promotions or activities.

(iii) Information you provide through our support channels. The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. When you speak to one of our representatives directly or otherwise engage with our support team, you can be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

2.2. Information we collect automatically when you use the Services

We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.

(i) Your use of the Services. We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on; frequently used search terms; and how you interact on the Services. We also collect information about which data you mostly use on or Services and how you work with it, like which links you use most frequently.

(ii) Device and Connection Information. We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you access, update or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.

(iii) Cookies. We and our third-party partners, such as advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookie Policy, which includes information on how to control or opt out of these cookies and tracking technologies.

2.3. Information we receive from other sources

We receive information about you from other Service users, from third-party services, from our related companies, and from our business and channel partners.

(i) Other users of the Services. Other users of our Services may provide information about you when they submit content through the Services. We also receive your email address from other Service users when they provide it in order to invite you to the Services.

(ii) Our Partners. We work with a network of partners who provide consulting, implementation, training and other services around our products. Some of these partners also help us to market and promote our products and services, generate leads for us, and resell our products and services. We receive information from these partners, such as what our Services you have purchased or may be interested in, evaluation information you have provided, what events you have attended, what country you are in.

(iii) Other Partners. We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Services and online advertisements.

(iv) Third Party Providers. We may receive information about you from third party providers of business information and publicly available sources (like social media platforms), including addresses, email addresses, phone numbers, intent data (or user behavior data), IP addresses and social media profiles, for the purposes of targeted advertising of products that may interest you, delivering personalized communications and profiling.

3. How we use information we collect

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.

(i) To provide the Services and personalize your experience. We use information about you to provide the Services to you, including to authenticate you when you log in, provide customer support, and operate and maintain the Services. For example, we use the name you provide in your account to identify you. Our Services also include tailored features that personalize your experience and improve your ability to analyze effectively the information you see through our Site. For example, we may use your preferences and activity to return search results we think are relevant to you.

(ii) For research and development. We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. In some cases, we apply these learnings across our Services to improve and develop similar features, to better integrate the Services you use. We also test and analyze certain new features with some users before rolling the feature out to all users.

(iii) To communicate with you about the Services. We use your contact information to send our news, notices, reminders any subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We provide tailored communications based on your activity and interactions with us. These communications are part of the Services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.

(iv) To market, promote and drive engagement with the Services. We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying our ads on other companies' websites and applications. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests. You can control whether you receive these communications as described below under "Opting out of receiving electronic communications from us".

(v) Customer support. We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services. Where you give us express permission to do so, we share information with a third party expert for the purpose of responding to support-related requests.

(vi) For safety and security. We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.

(vii) To protect our legitimate business interests and legal rights. Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

(viii) With your consent. We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.

Legal bases for processing (for EEA users):

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:

• We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services; • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; • You give us consent to do so for a specific purpose; or • We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your representative) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

4. How we share information we collect

We are not in the business of selling information about you to advertisers or other third parties. But, we provide information services and internal chatting tools, and we want them to work well for you. This means sharing information through the Services and with certain third parties.

4.1. Sharing with other Service users

When you use the Services, we sharxe certain information about you with other Service users for communication. Our Site offers publicly accessible chat (forum) on the respective Site's chat room page. You can create content on the chat room page, but you should be aware that any information you provide on this chat room page may be read, collected, and used by any user of the Service who accesses this chat room page. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into the chat room page. To request removal of your information from publicly accessible chat room page operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.

4.2. Sharing with third parties

We share information with our affiliated companies, sub-contractors, other agents or businesses or persons to: provide website hosting, maintenance, and security services; provision of our Services to you; conduct data analysis and create reports for us; offer certain functionality; assist in improving our service and creating new service features, and perform support and marketing for us. We require that these parties process such information in compliance with this Privacy Policy, we authorize only a limited use of such information, and we require these parties to use reasonable confidentiality measures to keep your information secure.

(i) Service Providers. We work with third-party service providers to provide the Service and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.

(ii) Partners. We work with third parties who provide consulting, sales, support, and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localized support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing.

(iii) Links to Third Party Sites. The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

(iv) Social Media Features. Our Services may include social media features or widgets, such as the Facebook Like button. Use of these features may allow them to collect your IP address, detect which page you are visiting on our site, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the third party providing the function.

(v) With your consent. We share information about you with third parties when you give us consent to do so.

(vi) Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights. In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect the Company, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

4.3. Sharing with affiliated companies

We share information we collect with affiliated companies and, in some cases, with prospective affiliates. Affiliated companies are companies owned or operated by us. The protections of this privacy policy apply to the information we share in these circumstances.

(i) Our companies. We share information we have about you with other our corporate affiliates in order to operate and improve products and services and to offer other our affiliates services to you.

(ii) Business Transfers. We may share or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

5. Your Rights and Choices

You have choices regarding our use and disclosure of your Personal Data:

(i) Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

(ii) Turning off Cookie Controls. Relevant browser-based cookie controls are described in our Cookie Policy.

(iii) How you can see or change your account Personal Data. If you would like to review, correct, or update Personal Data that you have previously disclosed to us, you may do so by signing in to your account on the Site or by contacting us.

(iv) Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:

• The right to request confirmation of whether we process Personal Data relating to you, and if so, to request a copy of that Personal Data; • The right to request that we rectify or update your Personal Data that is inaccurate, incomplete or outdated; • The right to request that we erase your Personal Data in certain circumstances provided by law; • The right to request that we restrict the use of your Personal Data in certain circumstances, such as while we considers another request that you have submitted (including a request that we make an update to your Personal Data); • The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.

Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

(v) Process for exercising data protection rights. In order to exercise your data protection rights, you may contact us as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.

For your protection, we may need to verify your identity before responding to your request, such as verifying that your name, phone number or the email address from which you send the request matches your data that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

6. Security and retention

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.

If you are a Service User, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you, even if you deactivate your account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention, enforcement of our agreements, and support business operations. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the Payment Processor that we use. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

Where we retain information for business operations, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you. If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow other users to make full use of the Services. For example, we continue to display messages you sent to the users that received them and continue to display content you provided, but when requested details that can identify you will be removed.

7. International data transfers

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.

8. Use by minors

The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.

9. Updates to this Privacy Policy and notifications

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The "Last updated" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Site. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your dashboard on the Site, email address and/or the physical address listed in your account on the Site.

10. Contact us

Your information is controlled by MS TRADE SOLUTION TECHNOLOGY LLC. If You have any questions or complaints about this Privacy Policy, please contact us by email at [e-mail] (for general inquiries) or [e-mail] (for legal inquiries).

Company's details:

Legal company name: MS Trade Solution Technology LLC Address: Bartók Béla út 66. 3. em. 4, Budapest, 1114 Hungary Company registration number: 0109349035 VAT number: HU27093928

Email (for general inquiries): [e-mail] Email (for legal inquiries): [e-mail] Tel.: [phone]