Privacy Policy – HyperTrade

1. Introduction & Commitment to Privacy

HyperTrade Network LLC (“HyperTrade,” “we,” “us,” or “our”), a California Limited Liability Company located at 2417 E Bliss St, Compton, CA 90222, is dedicated to protecting the privacy and security of your personal information. We provide advanced services involving the design, development, deployment, and integration of financial trading platforms, Business-to-Business (B2B) commerce platforms, and data networks across Desktop and Mobile environments (our “Services”).

This Privacy Policy explains how we collect, use, disclose, secure, and otherwise process Personal Information in connection with our website (hypertradenetwork.com or any successor site – the “Website”), our Services, and our business operations. It also describes your privacy rights and how you can exercise them.

We understand the importance of data protection, especially given the nature of the platforms we build. We are committed to processing Personal Information responsibly and in compliance with applicable data protection laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and other relevant regulations.

By using our Website or engaging our Services, you acknowledge that you have read and understood this Privacy Policy.

2. Scope and Our Role (Controller vs. Processor)

This Policy applies to Personal Information we process. It’s important to understand our role:

As a Data Controller: HyperTrade acts as a “Data Controller” when we collect and process Personal Information for our own purposes. This includes information collected from visitors to our Website, information from our prospective and current clients (business contact details, billing information), and information used for our marketing and operations.
As a Data Processor: When our clients use the Platforms we deploy for them, they upload or process their own data (“Client Data”). In many cases, this Client Data may contain Personal Information. When we handle this Client Data on behalf of and as instructed by our clients as part of providing our Services (e.g., hosting, maintenance, support for the deployed platforms), we typically act as a “Data Processor” (or “Service Provider” under CCPA). Our processing of Client Data is governed primarily by our agreements (Service Agreements, SOWs, Data Processing Addendums) with our clients. This Policy provides a general overview, but clients (as Data Controllers) are primarily responsible for their Client Data.

3. Information We Collect

We collect different types of information depending on your interaction with us:

a. Information We Collect as a Data Controller:

Website Visitors:
- Contact Information: If you fill out a contact form, request a demo, or subscribe to our newsletter, we collect your name, email address, phone number, company name, and any message you provide.
- Technical & Usage Data: We automatically collect information when you visit our Website, such as your IP address, browser type and version, operating system, device type, referring/exit pages, pages viewed, time spent, and other standard log and analytics data. We use cookies and similar technologies for this (see Section 7).
Prospective & Current Clients (Business Contacts):
- Contact & Business Information: Name, job title, company name, email address, phone number, business address, industry.
- Contract & Billing Information: Service Agreement details, SOWs, billing address, payment history (we typically use third-party processors for payment card data and do not store it ourselves).
- Communication Records: Records of calls, emails, meetings, and support requests.
- Platform Account Information (if applicable): Usernames and credentials for accessing any HyperTrade support portals or management consoles.

b. Information We Process as a Data Processor (Client Data):

When providing Services, we may process Client Data on behalf of our clients. The types of Personal Information within Client Data vary greatly depending on the client and the platform but may include:

Financial Trading Platform Users (End-Users of our Clients): User profile information (name, contact details), account numbers, trading history, positions, orders, financial data, IP addresses, device identifiers. We process this only as directed by our Client.
B2B Platform Users (End-Users or Business Partners of our Clients): User profile information, business contact details, order history, transaction details, communication records, product/service interests, usage data. We process this only as directed by our Client.
Data Network Users/Sources: Depending on the network’s purpose, this could include any of the above or other specific datasets as defined by the Client. We process this only as directed by our Client.

It is our Client’s responsibility (as the Data Controller) to ensure they have a lawful basis to collect and instruct us to process this Client Data.

4. How We Use Your Information

a. As a Data Controller:

To Provide & Improve Our Website: Operate, maintain, and enhance the user experience.
To Respond to Inquiries: Address your comments, questions, and requests for information or quotes.
To Manage Client Relationships: Establish accounts, process contracts and SOWs, handle billing and payments.
To Provide Services & Support: Deliver the contracted Services and provide technical support.
For Marketing & Communications: Send you updates, newsletters, and promotional materials (with your consent where required, and always with an opt-out option).
For Analytics & Research: Understand how our Website and Services are used to improve them.
For Security & Fraud Prevention: Protect our Website, Services, and users from threats.
To Comply with Legal Obligations: Meet legal, regulatory, and contractual requirements.

b. As a Data Processor:

Our only purpose for processing Client Data is to provide the Services to our Clients in accordance with their instructions and our contractual agreements. We do not use Client Data for our own marketing, advertising, or any other purpose unless explicitly instructed by the Client or required by law.

5. Legal Basis for Processing (Primarily for GDPR relevance)

If GDPR applies to our processing of your data as a Controller, our legal bases include:

Consent: Where you have given us explicit consent (e.g., for marketing).
Contractual Necessity: To perform our contractual obligations to you or take steps at your request before entering into a contract.
Legitimate Interests: For our legitimate business interests (e.g., improving our services, security), provided they do not override your fundamental rights and freedoms.
Legal Obligation: To comply with our legal and regulatory duties.

6. How We Share Your Information

We do not sell your Personal Information. We may share information under the following circumstances:

Service Providers & Sub-processors: We engage third-party companies and individuals to perform services on our behalf (e.g., cloud hosting providers like AWS/Azure/GCP, CRM platforms, analytics providers, support tools, payment processors). We share information only as necessary for them to perform these services and require them to maintain confidentiality and security, and to act as our “Service Providers” under CCPA. When they process Client Data, they act as our sub-processors and are bound by stringent data processing agreements.
As Directed by Clients: We share Client Data as instructed by the respective Client, who is the Data Controller.
Business Transfers: If HyperTrade is involved in a merger, acquisition, financing, or sale of all or a portion of its assets, information may be transferred as part of that transaction, subject to confidentiality agreements.
Legal Compliance & Protection: We may disclose information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.
With Your Consent: We may share information with third parties when we have your explicit consent to do so.

7. Cookies and Tracking Technologies

We use cookies and similar technologies (web beacons, pixels) on our Website to:

Operate and secure the Website.
Understand how visitors use our Website.
Analyze the effectiveness of our marketing.
Remember your preferences.

You can control cookies through your browser settings. Please note that disabling cookies may affect the functionality of our Website. For more details, please refer to a separate Cookie Policy if we implement one, or manage settings via available browser tools or consent management platforms.

8. Data Security

We implement a range of technical, administrative, and physical security measures designed to protect the Personal Information we process against unauthorized access, disclosure, alteration, or destruction. These measures include:

Encryption of data in transit (TLS/SSL) and at rest (where feasible).
Strict access controls based on the principle of least privilege.
Regular security assessments and vulnerability scanning.
Secure software development practices.
Employee training on data security and privacy.
Incident response plans.

Despite these efforts, no security system is impenetrable. We cannot guarantee the absolute security of your information. If we process Client Data, we will implement security measures as agreed upon in our contract with the Client.

9. Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, including providing our Services, complying with our legal obligations, resolving disputes, and enforcing our agreements.

As Controller: We retain client contact and billing data for the duration of the relationship and for a period afterward as required by law (e.g., tax/audit requirements). Website data and marketing data are retained based on their utility and your consent.
As Processor: We retain Client Data according to the terms of our agreement with the Client. Upon termination, we will return or delete Client Data as instructed by the Client.

10. Your Privacy Rights

Depending on your location (especially if you are a California resident), you may have certain rights regarding your Personal Information. These may include:

Right to Know/Access: Request information about the categories and specific pieces of Personal Information we have collected, used, disclosed, and “sold”/”shared” about you.
Right to Delete: Request the deletion of your Personal Information, subject to certain legal exceptions.
Right to Correct: Request the correction of inaccurate Personal Information.
Right to Opt-Out of Sale/Sharing: Request that we do not “sell” or “share” your Personal Information (as defined under CCPA/CPRA, which can include certain analytics/ad-tech cookies). We do not sell data for money, but you can opt out of potential “sharing” via our contact methods or cookie controls.
Right to Limit Use of Sensitive Personal Information: Request limitations on how we use sensitive data (if applicable).
Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights.
Right to Data Portability (GDPR): Request a copy of your data in a machine-readable format.
Right to Object/Restrict Processing (GDPR): Object to or request restrictions on certain processing activities.

Exercising Your Rights: To exercise these rights, please contact us using the information in Section 14. We will need to verify your identity before processing your request. We aim to respond within the timeframes required by law (e.g., 45 days for CCPA requests). If you are an end-user of one of our Clients’ Platforms, please direct your privacy requests to that Client (the Data Controller).

11. Children’s Privacy

Our Website and Services are not directed to individuals under the age of 16. We do not knowingly collect Personal Information from children under 16. If you believe we have inadvertently collected such information, please contact us immediately so we can delete it.

12. International Data Transfers

HyperTrade is based in the United States. If you access our Website or Services from other regions (like the EU, UK, or Kenya), your information will be transferred to and processed in the United States. We will take appropriate steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and applicable laws. For transfers from regions like the EU/UK, we may rely on mechanisms like Standard Contractual Clauses (SCCs) when applicable, particularly in our role as a Processor.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will post the updated policy on our Website and change the “Effective Date” at the top. We encourage you to review this Policy regularly.

14. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy, or if you wish to exercise your privacy rights, please contact our Privacy Team at:

HyperTrade Network LLC Attn: Privacy Officer 2417 E Bliss St Compton, CA 90222 Email: privacy@hypertradenetwork.com