Tread Labs Corporation (“Tread”) respects your right to privacy. This Privacy Policy explains whether and how we collect personal information about you, and how you can exercise your privacy rights. It applies to personal information that we may collect via our self-hosted trading platform, inclusive of a web interface and REST API access for order management, direct connections to multiple exchanges/brokers, and transaction cost analysis tools (“Services”).

We may change the Privacy Policy from time to time. If we make changes, we will notify you as required by law, and in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review the Privacy Policy whenever you access Tread services to stay informed about our information practices and the ways you can help protect your privacy. If you have any questions or concerns about our use of your personal information, then please contact us at ops@tread.fi.

1. HOW WE COLLECT INFORMATION FROM YOU

1.1 Information You Provide To Us. The only data we collect from you is information inputted or submitted by you, or information generated through use of Services. This may include, but is not limited to, trade data, order information, Exchange API keys, and any other data or information that you generate, transmit, or store within the Services.

2. HOW WE USE THE INFORMATION WE COLLECT

2.1 Tread Use. Tread may utilize De-identified Data for lawful purposes including but not limited to the service enhancement, analytics, and research. De-identified Data refers to information that has been processed or altered to remove or obscure any personal identifiers, ensuring that individuals cannot be readily identified, directly or indirectly, by the remaining information. This process involves the elimination or modification of personal attributes, including but not limited to names, addresses, and other identifying characteristics, rendering the data anonymous. This use is conditioned upon the assurance that neither you nor any authorized user can be identified or associated with the De-identified Data without their prior written consent.

2.2 Sharing. Your data shall not be shared outside of Tread without the explicit consent of you. Your data will be handled with the utmost respect for privacy and security. At any point, you have the right to request the deletion of your data.

2.3 Legal bases for processing (for EEA users). Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. We collect and process information about you only where we have legal bases for doing so under applicable laws. The legal bases depend on the Tread 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, 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; orWe 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, subject to any exemptions provided by law, but this will not affect any processing that has already taken place. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

3. SECURITY

Tread takes commercially reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

4. YOUR CHOICES

4.1 Account Information. You may contact ops@tread.fi for help, but note that we may retain certain information as required by law or for legitimate business purposes.

4.2 Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies, but please note that if you choose to remove or reject cookies, this could affect the functionality of the Tread services, specifically the session token for authentication.

4.3 Promotional Communications. You may opt out of receiving promotional emails or text messages by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.