Privacy Policy

Last updated: 23 October 2026

This Privacy Policy explains how Trade Llama LTD ("Trade Llama", "we", "us" or "our") collects, uses, shares and protects personal data when you visit the Trade Llama website or use our trading platform, and the rights you have over your personal data. Please read it together with our Terms of Service.

1. Who we are and how to contact us

Trade Llama LTD is the controller of your personal data. This means that we decide why and how your personal data is processed, and we are responsible for it under the data-protection laws that apply to you.

• Legal name: Trade Llama LTD
• Address: 521 Fifth Avenue, 17th Floor, Office 17B, New York, NY 10175, United States
• Company registration: Entity Number 395021
• Regulator: Cayman Islands Monetary Authority (CIMA)
• Regulatory framework: Virtual Asset Service Provider (VASP) Registration #1849203
• Email: support@tradellama.com

Data protection officer: [Data Protection Officer contact]. You can also send any question about this policy to support@tradellama.com with "Privacy" in the subject line.

If you are in the European Economic Area (EEA), you can also contact our representative in the European Union: [EU representative: name and address]. If you are in the United Kingdom, you can also contact our representative there: [UK representative: name and address].

2. Scope of this policy

This policy applies to visitors to the Trade Llama website, to people who register for an account (including those who do not finish registering), to our clients during and after their relationship with us, and to anyone who contacts our support team. We provide our services through the website only; we do not offer a mobile app.

Some of our pages load content directly from other companies: TradingView's chart widget and Binance's public market prices. Sections 6 and 10 explain what those companies receive, but their own privacy policies govern what they do with it. This policy does not cover other websites that you reach through links on our website.

Where the law of the place where you live gives you additional protection, for example the General Data Protection Regulation as it applies in the EEA and the United Kingdom ("GDPR") or the privacy laws of certain US states, we apply that law as it requires.

3. The personal data we collect

We collect personal data that you give us, data that is generated when you use our services, and data that we receive from other organisations.

3.1 Account data

• your email address or phone number, depending on which one you register with;
• your first and last name;
• your password. Our systems store only a hashed form of it, not the password itself, so our staff cannot read it;
• a referral code, if you enter one when you sign up; and
• your account settings and status, including your verification status.

3.2 Verification data

• the identity documents you submit for identity verification ("know your customer" or "KYC") and the details they contain, such as your name, date of birth, nationality, document number and photograph;
• any additional details or documents we ask for to complete verification, as anti-money-laundering law requires;
• the outcome of our review and of checks carried out for us by identity-verification and compliance providers; and
• your answers to the suitability questionnaire.

We do not ask for special categories of personal data, such as information about your health or religion, although an identity document may reveal some such information indirectly (for example, through your photograph). We use identity documents only to verify your identity and meet our legal obligations. Screening against sanctions and similar official lists may involve information about criminal offences or allegations, which we process only as anti-money-laundering law permits.

3.3 Financial and transaction data

• deposits, withdrawals and transfers between your accounts, including amounts, currencies, dates and status;
• the payment method details needed to process them, such as bank account details for bank wires and card details for card payments;
• crypto wallet addresses you deposit from or withdraw to, and the related blockchain transaction identifiers;
• your account balances;
• your orders, trades and positions in spot, CFD and futures markets, including leverage, margin and liquidation details;
• conversions between coins and crypto purchases made with a bank card; and
• your Earn subscriptions and any bonus credited to your account, such as the welcome bonus.

Crypto transactions are recorded on public blockchains, where anyone can see them and the wallet addresses involved. We cannot change or delete information recorded on a blockchain.

3.4 Technical data

• your IP address, which we use for security purposes, including blocking IP addresses from which our platform is misused or attacked;
• details of your device and browser, such as browser type and version, operating system and language settings; and
• your login times.

Your sign-in session and display preferences are kept in your browser (see section 10). We do not use advertising or analytics trackers or marketing cookies.

3.5 Communications

Messages you send to our support team and our replies, including attachments and the contact details you use, and service messages we send you, such as notices about your account or changes to our terms.

3.6 Data we receive from others

• Identity-verification and compliance providers ([identity-verification provider]): the results of document checks and of screening against sanctions and other official lists.
• Payment and banking providers: confirmation and status of your card payments and bank wires, and the details needed to match a payment to your account.
• Public blockchains: information about crypto deposits to, and withdrawals from, your account.

3.7 If you do not give us your data

Some personal data is needed to provide our services or meet our legal obligations. Without it, we may not be able to open your account, complete your verification, process a payment or give you access to some products. We tell you when information is required.

4. How we use your personal data and our legal bases

We use your personal data only for the purposes below. Where the GDPR applies, we rely on these legal bases:

• Contract: the processing is necessary to provide the services you have asked for under our Terms of Service, or to take steps you request before entering into that contract.
• Legal obligation: the processing is necessary to comply with the law, including anti-money-laundering and counter-terrorist-financing law, identity-verification (KYC) and sanctions requirements, record-keeping duties, and lawful requests from regulators, courts and law enforcement.
• Legitimate interests: the processing is necessary for our legitimate interests, or those of others, and those interests are not overridden by your rights and interests. They include keeping our platform and your account secure, preventing fraud and other financial crime, and establishing or defending legal claims. You can ask us how we have balanced these interests against yours.
• Consent: where the law requires your consent, we ask for it. You can withdraw it at any time; this does not affect processing that took place before.

We do not use your personal data for advertising, and we do not build advertising or marketing profiles about you. If we want to use your personal data for a new purpose that is not compatible with those above, we will tell you first and, where the law requires it, ask for your consent.

5. Automated decision-making

Our platform applies some product rules automatically. For example, it rejects an order if your available balance is not sufficient, and it closes leveraged positions that reach their liquidation level, as described in our Terms of Service and the product information on our website. These rules apply in the same way to every client and are not assessments of you as a person.

Automated tools may also flag unusual activity, such as traffic from an IP address associated with abuse, and block access temporarily as a protective measure. We do not, however, make decisions that produce legal effects for you or similarly significant effects, such as refusing to open your account, rejecting your verification, or suspending or closing your account, based solely on automated processing without human review. Our staff review the identity documents submitted for verification.

If you disagree with a decision we have made about you, you can ask a member of our staff to review it, explain your point of view and contest the decision by writing to support@tradellama.com.

6. Who we share your personal data with

We share personal data only where we need to, and only with the recipients below. We do not sell your personal data, and we do not share it with advertisers or data brokers.

6.1 Payment and banking providers

Banks, payment service providers and card networks receive the information they need to process your card payments and bank wires, such as your name, payment details, amount and currency. If you pay with Apple Pay or Google Pay, the provider of that wallet also processes the payment under its own terms. Some of these organisations act as independent controllers of the data they receive.

6.2 Identity-verification and compliance providers

Our identity-verification and compliance providers ([identity-verification provider]) help us check identity documents and screen clients against sanctions and other official lists. They receive your account data, verification data and, where needed, technical data. Trade Llama makes the final decision on your verification.

6.3 Hosting and infrastructure providers

Our platform runs on servers and related services operated by hosting and infrastructure providers. They process personal data on our behalf, only on our instructions, and under contracts that require them to keep it confidential and secure.

6.4 TradingView (chart widget)

Our trading pages embed a chart widget provided by TradingView. When you open such a page, your browser loads the widget directly from TradingView's servers. TradingView therefore receives your IP address and the information your browser sends with any web request, such as browser type, language settings and the address of the page containing the widget. We do not send your name, contact details or account details to TradingView. TradingView's own privacy and cookie policies apply to the data it receives.

6.5 Binance (public market prices)

To show live market prices, your browser requests public price data directly from Binance's public API. Binance therefore receives your IP address and browser details. These are requests for public market data; we do not add your name, contact details or account details to them. Binance's own privacy policy applies to the data it receives.

We chose to embed TradingView's widget and to load prices from Binance, and we are responsible for that choice. Each of those companies is responsible for its own use of the data it receives.

6.6 Professional advisers

We may share personal data with our lawyers, accountants and other professional advisers where they need it to advise us. They are bound by duties of confidentiality.

6.7 Authorities

We disclose personal data to regulators (including CIMA), courts, law enforcement agencies and other public authorities where the law requires us to, for example under anti-money-laundering law or a court order, and where necessary to establish, exercise or defend legal claims. Before we respond to a request, we check that it has a proper legal basis.

7. International transfers

Your personal data may be processed in the United States, the Cayman Islands and other countries where we or our providers operate. These countries may not offer the same level of data protection as the country where you live.

If you are in the EEA or the United Kingdom, we transfer your personal data outside those areas only where:

• the receiving country is recognised as providing an adequate level of protection;
• appropriate safeguards are in place, such as the Standard Contractual Clauses approved by the European Commission and, for transfers from the United Kingdom, the UK International Data Transfer Addendum or Agreement, with additional measures where needed; or
• another condition allowed by law applies, for example where the transfer is necessary to carry out a transaction you have asked for, such as an international bank wire.

You can ask us for more information about these safeguards, including a copy of the relevant clauses (with commercially sensitive details removed), at support@tradellama.com. TradingView's widget and Binance's prices are loaded by your browser directly from those companies' servers, which may be outside your country.

8. How long we keep your personal data

We keep personal data only for as long as we need it for the purposes in this policy.

• Account, verification, financial and communications data: for as long as your account is open, and afterwards for as long as anti-money-laundering and record-keeping law requires, which is [at least 5 years after our relationship ends].
• Longer periods: where a regulator, court or law enforcement agency requires it, or where we need the data to establish, exercise or defend a legal claim, until the matter is resolved.
• Technical data used for security: for as long as it is needed to protect our platform and investigate incidents, unless it forms part of the records we must keep by law.
• Data stored in your browser: see section 10.

When we no longer need personal data, we delete it or anonymise it so that it can no longer identify you.

9. How we protect your personal data

We use technical and organisational measures designed to protect personal data against loss, misuse, unauthorised access, disclosure and alteration. These include encrypted connections between your browser and our platform, storing only a hashed form of your password, limiting access to personal data to staff and providers who need it, confidentiality duties, monitoring for suspicious activity, blocking IP addresses from which our platform is misused or attacked, and contracts that require our providers to protect the data they process for us.

No system is completely secure, and we cannot guarantee the security of data sent over the internet. You can help keep your account safe:

• use a strong password that you do not use elsewhere, and do not share it with anyone, including anyone who claims to be from Trade Llama;
• sign out when you finish, especially on a shared device, because your sign-in session is stored in your browser; and
• check wallet addresses carefully before you confirm a withdrawal, because blockchain transactions cannot be reversed.

If a personal data breach is likely to put your rights at risk, we will notify you and the relevant authorities where the law requires us to.

10. Cookies and browser storage

We do not use advertising cookies, analytics cookies or other tracking technologies. Our website stores only the following items in your browser:

These items are needed to provide the service you ask for, or simply remember choices you have made. We do not use them to track you across other websites.

Third-party widgets. TradingView's chart widget may set its own cookies or store other information in your browser under TradingView's cookie policy. Binance receives your IP address and browser details each time your browser loads live prices (see section 6).

Your choices. You can delete the items above by clearing your browser's site data for our website; you will then be signed out and your preferences reset. You can also block third-party cookies in your browser settings, although charts or live prices may then not work.

11. Your rights

11.1 If you are in the EEA or the United Kingdom

Under the GDPR you have the following rights, some of which apply only in certain circumstances:

• Access: to receive a copy of your personal data and information about how we use it.
• Rectification: to have inaccurate personal data corrected and incomplete data completed.
• Erasure: to have your personal data deleted. We may have to keep some data, for example where anti-money-laundering or record-keeping law requires it, and we will tell you if so.
• Restriction: to have us limit how we use your personal data, for example while we check whether it is accurate.
• Portability: to receive the personal data you gave us in a structured, commonly used and machine-readable format, or to have it sent to another organisation, where we process it by automated means on the basis of contract or consent.
• Objection: to object to processing based on legitimate interests. We will stop unless we have compelling legitimate grounds that override your interests, or we need the data for legal claims.
• Withdrawing consent: where we rely on your consent, at any time.
• Human review: of decisions, as described in section 5.
• Complaint: to a supervisory authority (see section 12).

11.2 If you live in a US state with a privacy law

If you live in California or another US state with a comprehensive privacy law, then, subject to the conditions and exceptions in that law, you have the right to:

• know and access the personal information we have collected about you, its sources, the purposes for which we use it and the categories of recipients to whom we disclose it;
• delete personal information we have collected from you, except where we must keep it, for example under anti-money-laundering law;
• correct inaccurate personal information;
• opt out of the sale or sharing of your personal information; and
• not be discriminated against for using these rights.

We do not sell personal information, and we do not share personal information for cross-context behavioural advertising (targeted advertising). If your browser sends a Global Privacy Control signal, we treat it as a request to opt out of sale and sharing, which matches our practice.

In the terms of California law, we collect identifiers (such as name, email address or phone number and IP address), customer records (such as identity documents and bank or card details), characteristics of protected classifications (such as date of birth and nationality shown on identity documents), commercial information (such as deposits, withdrawals, trades and Earn subscriptions), internet or network activity (such as browser details and login times), and other information you give us (such as questionnaire answers and support messages). We collect it from the sources in section 3, use it for the purposes in section 4, disclose it for business purposes to the recipients in section 6, and keep it for the periods in section 8.

Some of this is sensitive personal information, such as identity-document numbers, account log-in details and financial account details. We use it only for purposes the law permits, such as providing our services, verifying your identity, keeping accounts secure and complying with the law, and not to infer characteristics about you.

11.3 Other countries

If you live elsewhere, including the Cayman Islands, the data-protection law of your country may give you similar rights. We will respect them as that law requires.

12. How to exercise your rights and how to complain

To exercise any of your rights, email support@tradellama.com with the subject "Privacy request". Tell us which right you want to use and, if possible, write from the email address registered to your account.

• Verification: we need to confirm your identity before we act on a request, and we will ask only for the information we need for this.
• Authorised agents: where the law allows, someone else can make a request for you. We will ask for proof of their authority and may ask you to confirm your identity directly with us.
• Timing: we respond within one month under the GDPR, extendable by up to two further months for complex or numerous requests, and within 45 days under US state laws, extendable by up to a further 45 days where the law allows. We will tell you if we need more time and why.
• Cost: exercising your rights is free. Where a request is manifestly unfounded or excessive, we may charge a reasonable fee or decline to act, as the law allows.
• If we decline: we will explain why. If your US state gives you a right to appeal, reply to our decision with the subject "Privacy appeal" and we will review it and tell you the outcome and our reasons.

Complaints. If you are unhappy with how we handle your personal data, please contact us first so that we can try to put it right. You also have the right to complain to a supervisory authority at any time:

• in the EEA, to the data-protection authority of the Member State where you live, where you work or where you believe the infringement took place;
• in the United Kingdom, to the Information Commissioner's Office;
• in the Cayman Islands, to the Ombudsman, where the Cayman Islands Data Protection Act applies; and
• elsewhere, to the data-protection authority in your country, if there is one.

13. Children

Our services are not for anyone under 18, and you must be at least 18 to open an account. We do not knowingly collect personal data from anyone under 18, and our verification process checks the date of birth on identity documents. If we learn that we have collected personal data from someone under 18, we will close the account and delete the data, except for any data the law requires us to keep. If you believe that someone under 18 has given us personal data, please contact us at support@tradellama.com.

14. Changes to this policy

We may update this policy, for example when our services, our providers or the law change. The "Last updated" date at the top shows when it last changed. We will tell you about material changes before they take effect, by email or by a notice on our website or in your account, and ask for your consent where the law requires it.

15. Contact us

If you have questions about this policy or about how we handle your personal data, please contact us:

• Email: support@tradellama.com (subject "Privacy")
• Post: Trade Llama LTD, 521 Fifth Avenue, 17th Floor, Office 17B, New York, NY 10175, United States
• Data protection officer: [Data Protection Officer contact]
• EU representative: [EU representative: name and address]
• UK representative: [UK representative: name and address]