In brief:

We are

Decode Global Limited

("Decode Global," "we" or "us"). We respect

your privacy and work hard to protect the confidentiality of information that you give

us. We will only share your personal data with third parties in the event that it’s needed

for the provision of services and data you have requested (explained in detail in this

About Us

Decode Global

is the data controller responsible for your personal data and is the sole

owner

the

www.decodefx.com

website

("Website"),

Decode

Global

mobile

and desktop

applications,

Decode

Global

services

(each,

"Service")

and

all

the information collected on it.

Decode Global

collects information from users in

several

ways (explained in detail in this privacy policy).

This privacy policy applies to personal data that we collect from you when you visit this

Website,

create

an account,

use

our

applications

services

("you"

"your"

being

interpreted accordingly). It provides information on what personal data we collect, why

we collect personal data, how it is used, the lawful basis on which your personal data

is processed, how it is stored, and how we share information.

As used in this privacy policy, "personal data" means any information that relates to

you from which you can be identified.

By using our Service or submitting your personal data, you are agreeing to accept the

terms of this privacy policy, so please read it carefully. If you disagree with this privacy

policy at any point or time, you should stop using our Services and delete your user

account.

Updates

We may update this privacy policy at our discretion from time to time by posting a new

version

our

website.

You

should

check

our

website

occasionally

ensure

any

changes made are suitable for you. If required by applicable law, you will be informed

of any significant changes made to the privacy policy.

The current version of this privacy policy was

published on

October

19, 2023.

Personal data that we collect

There is no need to create an account when searching and viewing information from

certain markets, such as symbols, quotes, financial data, as well as ideas and publicly

available data of Decode Global users.

Data we receive from you

User Accounts

If you decide to create an account, you will need to provide us with some personal

data so we can provide you with access to our additional services that users benefit

from. You may also elect to provide us with additional information about you, as

described below.

During registration you will be required to provide us with:

• your username, email address;

• your first name, last name and date of birth

• if you want to buy a subscription, we will need your first name, last name

and postal address.

In some cases, you may need to provide and verify your phone number. You can also

add additional information about yourself in the profile settings.

The following information will be publicly displayed:

• username, the image you have elected to provide as your user avatar,

signature

The following information will not be publicly displayed:

• your first and last name, phone number and email.

Our third party payment processor will also process information about your payment

card and bank account information or payment account information that we require for

the purpose of recording and processing your account registration.

Contact data

We also process any personal data you choose to give when corresponding with us

by phone, email, or otherwise visiting and interacting with this Website or any other

services we operate.

Partners data

We also process personal data you choose to give at registration and connection to

the Orion Academy (for more information please see Orion Trading Academy).

Cookies and other technologies

We use browser cookies (small text files placed on your device) to administer our Site,

gather and analyze statistical information, ensure security, to fight spam, and for

advertising purposes. Cookies allow us to provide you with a better user experience

when you browse our Website and also helps to improve its features. More detailed

information on the use of cookies can be found in our Cookies Policy.

Log files

Like most websites, we use web server log files. Records in our log files include

internet protocol (IP) addresses, browser types, internet service providers, referring

pages, exit pages, platform types, and date/time stamps. We use web server log files

to administer the site, provide broad traffic information for site planning purposes, and

to ensure that our terms of service agreement is being adhered to. Note that IP

addresses are not tied to personal data in our web server log files.

Device information

We collect the following information about the devices you use to interact with our

services: IP address of the device (from which we can also infer the country you are

connecting from), device type, operating system, application and browser version. We

collect this information to prevent spam and abuse of our services. IP addresses may

be considered personal data in certain jurisdictions and will be treated in accordance

with this privacy policy.

Analytics

When you are using our Website, mobile and desktop applications, or widgets we

provide to another site, we may collect analytics information automatically. This

information may include your general device information, device identifiers (for

example, Google Advertising ID, if you are using an Android device, or Advertising

Identifier (IDFA), if you are using an iOS device), network information, website, and

application interaction events. We collect pseudonymous data only and this analytic

information does not include any personal identifiable information from your profile.

We use this information to analyze and improve the work of our services and

applications, and to develop, test, and improve our service further. For this purpose

we may use internal analytic as well as third party service providers. For further details

about our use of third party service providers, please refer to the Analytics providers

section below.

How personal information is used

We use personal data in various ways that are necessary to provide the services you

intend to use, certain legitimate interests, and as a necessity in order to comply with

applicable law, as further described below.

We do not generally rely on your consent to allow us to process your personal data if

there is another lawful ground available. If we do rely on your consent, we will make

this clear to you at that time.

Profile

A profile is a set of information for each individual user that details his/her viewing

preferences. User settings (chart settings, toolbars, buttons, etc.) are kept solely for

the purpose of customizing the user’s experience when using the Website,

applications or user accounts. We do not share private profile settings with any third

parties.

Note that when you create an account, other users or visitors may access your public

profile and see any information you have made publicly available about yourself.

User account and profile operations

We use your contact details, such as username, email address, or phone number, in

the following ways:

• to authenticate your user account, ensure its security along with the security

of our services, and to prevent spam, fraud, and abuse;

• to acknowledge, confirm, and deal with your user account;

• to send all new users a welcome activation email to verify their email

address;

• (For Paid Users) to provide you with subscription services and contact you

regarding your use of such services. This is necessary for us to implement

your requests; and

• Paid Users will also receive a notification email from our payment processor

if there are any issues regarding billing their cards for subscriptions. Users

cannot opt out of these messages, though they can delete their account.

User account deleting

You may refuse to use our Website and/or application and may ask us to delete your

account by request support tickets. Your account will be deleted after 14 days. During

this time, you can stop the deletion process at any time.

Please note that if you have requested your account to be deleted, we will delete the

subsequent personal data you have supplied us. However some data, such as

published ideas/scripts and messages sent to other users, will be saved as they have

already integrated into our system. This data must be stored to maintain the integrity

of the platform, as well as for legitimate business processes, including audits and

security purposes.

Note that search engines, as well as third parties, can keep copies of your publicly

available information once your account has been deleted. It should also be noted that

published ideas will remain on the site and messages sent to other users cannot be

deleted.

Marketing

We may send you marketing emails about our products or services that are similar to

the products or services you are subscribed to, including information about events and

other promotions we feel may interest you. This is unless you have indicated to us that

you do not wish to receive communications in this manner. We will send you other

promotional information by email only with your consent, which was given at the time

you provided us with your personal data. Users can opt out of receiving marketing

communications at any time by clicking "unsubscribe" in one of the emails.

Service-Related Announcements

On rare occasions, it may be necessary to send out service-related announcements.

For instance, if our service is interrupted for a prolonged period or a major functionality

upgrade is released, we might send all users an email message.

Customer Service

When you open a support ticket, we use your contact details as well as information

about your device, server logs, a description of the problem, along with any other

supporting materials (videos, screenshots, etc.) to help resolve the issue(s).

API

If you are using our API (Application Programming Interface) services, then we may

process your personal data in order to be able to provide and support those services.

Legitimate interests

We will process your personal data as necessary for certain legitimate business

interests, which include the following:

• where we are asked to respond to any of your inquiries, comments, or

grievances;

• to administer our services in order to better understand how visitors interact

with the Website and application, and ensure that they are presented in the

most effective manner for you and your computer/device;

• to develop and improve our mobile applications;

• to share personal data among our affiliated businesses for administrative

purposes, provide subscription services, and in relation to our sales and

marketing activities, except where we require your consent, as described

above;

• to send you information about our products or services that are similar to

the products or services you subscribed to (unless you have refused or

opted out of receiving these emails at the time you provided us with your

email address or you have indicated to us that you do not wish to receive

communications in this manner). Our legitimate interest is to ensure our

marketing is relevant to you, so we may process your data to send you

information on our products or services that is specifically tailored to your

interests;

• we may anonymize, pseudonymize, aggregate and de-identify the data that

we collect and use this data for our own internal business purposes,

including sharing it with our business partners, our affiliated businesses,

agents and other third parties for commercial, statistical and market

research purposes. For example, to allow those parties to analyse patterns

among groups of people and conducting research on demographics,

interests, and behavior;

• for internal business/technical operations, including troubleshooting, data

analysis, testing, research, statistical and survey purposes, and as part of

our efforts to keep our Website, network, and information systems secure;

and

• to (a) comply with legal obligations, (b) respond to requests from competent

authorities; (c) enforce our Terms of Use; (d) protect our operations or those

of any of our affiliated businesses; (e) protect our rights, safety or property,

and/or that of our affiliated businesses, you or others; and (f) enforce or

defend legal rights, or prevent damage. This means we can store and

disclose your information to law enforcement authorities, state, or

government agencies if we establish that such disclosure is necessary to

comply with the law. This includes responses to court orders or subpoenas,

as well as other judicial or regulatory processes.

As used in this privacy policy, “legitimate interests” means the interests of Decode

Global and our affiliated businesses in conducting and managing our business. When

we process your personal data for our legitimate interests, we make sure to consider

and balance any potential impact on you and your rights under data protection laws.

Our legitimate interests do not automatically override your interests. We do not use

personal data for activities where our interests override the impact they may have on

our users, unless we have their explicit consent or those activities are otherwise

required or permitted by law. You have the right to object to the processing of your

personal data that is based on our legitimate interests at any time, on grounds relating

to your particular situation.

When would we share personal information

We share your personal data with third parties in the following situations:

• Service providers: Decode Global, like many businesses, occasionally

engages with selected third parties who act on our behalf to support our

operations, such as (i) card processing or payment services (ii) IT suppliers

and contractors (i.e. data hosting providers or delivery partners) as

necessary to provide IT support and enable us to provide subscription

services and other goods/services available on this Website or to users, (iii)

web and mobile analytics providers, (iv) providers of digital advertising

services, and (v) providers of marketing and sales software solutions.

Pursuant to our instructions, these parties may access, process or store

your personal data in the course of performing their duties to us and solely

in order to perform the services we have hired them to provide.

• Payment information: Paid Users must provide payment information

(name, postal address, payment card information or payment account

information). This information is used for billing purposes only and is

processed by our payment processors. When you are making a payment,

we do not have access to your payment card information. Should we have

any issues with processing an order, the email address you have provided

will be used to contact you.

• Decode Global affiliated businesses: In order to provide the services you

request from us, our affiliated businesses may access and process the

information which we collect from you for the purposes described above,

including offering products and services to you. Our affiliated businesses

will only use your data for the purposes for which we originally collected

said data.

• Business transfers: If we sell our business or our company assets are

acquired by a third party, personal data held by us about our general

account users, subscription account users or customers may be one of the

transferred assets.

• Administrative and legal reasons: If we need to disclose your personal

data (i) to comply with a legal obligation and/or judicial or regulatory

proceedings, a court order or other legal process, (ii) to enforce our Terms

of Use, or other applicable contract terms that you are subject to, or (iii) to

protect us or our contractors against loss or damage. This may include, but

is not limited to, exchanging information with the police, courts or law

enforcement organisations.

• Advertising: We display advertising on the Website and may use

remarketing and tracking features. Remarketing features allow us to display

advertising in a more targeted manner in order to present advertisements

of interest to users, based on their activity on other websites. Tracking

features allow us to collect information about impressions, ad clicks and

certain actions that users complete through our Website. This data also

helps us evaluate the performance of ad campaigns. Note that we collect

pseudonymous data only.

• Note that we do not share any personal information with our advertisers.

They can only access general statistics that include the amount of

impressions their ads have generated as well as clicks.

Public information on our site

Public Profile

When you create your profile on our Service, other users or visitors may access your

public profile and see any information you have made available about yourself. When

browsing for trading ideas, they will only be able to view your market information (i.e.

published ideas and scripts, markets allocation, top mentioned Symbols, etc.), social

information (i.e. followers and following lists along with the ideas that you follow and

comment on), contact information (i.e. your About section, avatar, links to your social

media accounts, website, etc.), your community status (i.e. Moderator or Pro badges,

statistical information such as reputation points, views, likes, followers, registration

date, as well your last visit date). Your email address, however, will not be visible

(unless you choose to make it visible).

Chats and Private Messages

When you communicate with other users in public and private chats, we store and

process your messages and any related information. We check links to make sure

there is no malicious software or content as well as to detect spam and prohibited

images/text. When you use private messages to communicate, please keep in mind

that the recipients have a copy of your correspondence as well. This will continue to

be the case even if you delete such correspondence from your account. Recipients

can copy, store and/or reshare these messages. Be constantly vigilant of this.

Security of personal data

We use technical and organizational safeguards to protect your personal data and

require third parties with whom we work to do the same.

We use Transport Layer Security (TLS) encryption technology in order to protect

certain information that you submit to us. This technology protects you from having

your information intercepted by anyone while it is being transmitted to Decode Global

or payment processor. While on a secure page, such as our order form, the "lock" icon

in the browser window is displayed, confirming that a secure and encrypted connection

has been established with the Website. We work hard to ensure that our Service is

secure and that we meet industry standards. We also use other safeguards, such as

firewalls, authentication systems (i.e. passwords, and personal identification numbers),

and access control mechanisms to control unauthorized access to systems and data.

If you have chosen to create an account, you are responsible for doing everything you

reasonably can to keep your access details secret. You must not share these details

with anyone else.

We also do our best to protect user information offline. All of our users' personal

information is restricted to our offices. Only employees who need to see the

information to perform their jobs are allowed to access it.

The servers that store personal data are located in a secure environment in a locked

facility.

We are constantly improving the ways we secure, store, and process the data we

collect, including the addition of physical security measures that help us counter

unauthorized access to our systems. However, no method of electronic transmission

or storage is 100% secure. Therefore, we cannot guarantee its absolute security.

Children and sensitive personal data

This Website is not directed towards children who are under the age of 18. We do not

knowingly contact or collect personal information from children below the age of 18

years, or sensitive personal data ("racial or ethnic origin, political opinions, religious or

philosophical beliefs, trade union membership, the processing of genetic data,

biometric data for the purpose of uniquely identifying a natural person, data concerning

health or a natural person’s sex life or sexual orientation," etc.). If you believe we have

inadvertently collected such information, please contact us immediately so that we can

either obtain special consent or delete the information.

Third Party Sites

Links to other sites

At our discretion we may add links (web links) to other websites from our Website.

These websites can be run by third parties with separate and independent privacy

policies. We, therefore, have no responsibility nor are we liable for any content,

activities or privacy policies of these linked sites. We suggest you read the privacy

policy of each and every site that you visit.

Accessing data

If prompted, we will confirm whether or not we are processing your personal data and

if so, we will provide you with a copy of that personal data along with any other

pertinent details. If you require additional copies, we may need to charge a reasonable

fee, but this can be discussed and depends on the situation.

Restricting the processing of personal data

You may ask us to restrict or ‘block’ the processing of your personal data in certain

circumstances, for example, if you contest the accuracy of the data or object to us

processing it. We will notify you before we lift any restriction on processing. If we share

your personal data with others, we will notify them of the restriction wherever possible.

If prompted, and if it is possible and lawful to do so, we will also notify you with whom

we have shared or will share your personal data so you can contact them directly.

Objections

You may:

• ask us to stop processing your personal data at any time, and we will do so.

If we are relying on a legitimate interest to process your personal data, then

it should not be a problem unless we demonstrate compelling legitimate

grounds for processing;

• object to our processing of your data for the purposes of direct marketing at

any time. This can be done by clicking the "unsubscribe" button in our

marketing emails; and

• refuse to receive service notifications via email (for example, when a user

you are subscribed to publishes a chart, idea, etc.). This can be adjusted in

the Settings.

Withdrawal of consent

If we rely on your consent to process your personal data, you have the right to withdraw

that consent at any time. This will not affect the lawfulness with which we process your

data before receiving notice of your wish to withdraw your consent. We emphasize

that we do not generally rely on your consent to allow us to process your personal data

if there is another lawful ground available. If we do rely on your consent, we will make

this clear to you at that time.

Viewing and correcting data

You have the right to have inaccurate personal data rectified or completed if it is

incomplete. In order to do so, each user can view, manage and/or update his/her

personal data in the Profile.

If we share your personal data with others, we will notify them of any corrections made

whenever possible. If prompted, and where possible and lawful to do so, we will also

notify you with whom we have shared your personal data so you can contact them

directly if need be.

Deleting data

You have the right to refuse to use our Services and may ask us to delete or remove

your personal data in certain circumstances. If we share your data with others, we will

notify them of the edits wherever possible. If prompted, and wherever possible and

lawful to do so, we will also notify you with whom we have shared your personal data

so you can contact them directly if need be.

Data retention

We will keep your personal data (1) until you decide to delete your account (upon

request), or (2) as required by law or as necessary for legitimate business purposes

(i.e. for tax, legal, accounting, fraud, or abuse prevention, and/or other purposes). This

data can be stored even after an account is deleted.

Upon expiration of the applicable retention period, we will securely destroy your

personal data in accordance with applicable laws and regulations. In some

circumstances we may anonymize your personal data so that it can no longer be

associated with you. In this case, such data is no longer considered personal.

If you consent to receive marketing communications, we will keep your data until you

unsubscribe, which is possible via the ‘unsubscribe’ button at the end of our marketing

emails. Additional methods to unsubscribe may be added in the future.

Data portability

You have the right to obtain your personal data from us, which that you consented to

give us or that was provided to us as necessary in connection with our contract with

you. We will give you your personal data in a structured, commonly used, and

machine-readable format. You may reuse it elsewhere if you so wish.

Lodge a complaint with the data protection authority

If you have concerns about our privacy practices, including the way we handle or have

your personal data, you can report it to any competent data protection. If you wish to

exercise any of these rights, please contact us. Note that we may need to ask you for

further information to verify your identity before we can respond to any request.

Contact information

If you have any questions or suggestions regarding personal data processing, please

Decode Global Limited

Lolam house, Kumul Highway

Port Vila Vanuatu

enquiries@decode-group.com