1. Introduction

Trade T Capital Markets Ltd, a company duly incorporated and registered under the laws of the Republic of Mauritius, operating under the registered brand name Trillion Trades, is committed to protecting personal data in accordance with the Data Protection Act 2017 of Mauritius, the regulations issued thereunder, and applicable Financial Services Commission (“FSC”) requirements.

Trade T Capital Markets Ltd (“TT”, “we”, “us”, or “our”) acts as a Data Controller in respect of the personal data it processes, unless otherwise stated.

As a financial services provider, we recognize that safeguarding personal data is a legal, regulatory, and ethical obligation. This Privacy Notice explains how we collect, use, disclose, store, and protect personal data, and outlines your rights under applicable data protection laws.

2. Scope of This Privacy Notice

This Privacy Notice applies to:

• Personal data you provide directly to Trade T Capital Markets;
• Personal data collected automatically through our website and digital platforms; and
• Subject to applicable laws, personal data obtained from third parties and public sources.

For the purposes of this Notice, “Trade T Capital Markets” includes its affiliates and subsidiaries, where applicable.

3. Our Privacy Principles

• Personal data is processed lawfully, fairly, and transparently;
• Data is collected for specified, explicit, and legitimate purposes;
• Data collection is adequate, relevant, and limited to what is necessary;
• Reasonable steps are taken to ensure data accuracy and currency;
• Personal data is retained no longer than necessary for legal or business purposes;
• Appropriate technical and organizational measures are implemented to ensure data security and confidentiality;
• Access to personal data is restricted to authorized personnel with a legitimate business need.

4. Lawful Basis for Processing Personal Data

We process personal data only where permitted under the Data Protection Act 2017, including:

• Contractual necessity – to perform or enter into a contract with you;
• Legal or regulatory obligation – to comply with FSC rules, AML/CFT laws, tax laws, and other applicable regulations;
• Legitimate interests – where necessary for our business operations, risk management, or fraud prevention, provided such interests do not override your rights;
• Consent – where required by law, obtained explicitly and documented.

5. Consent

Where consent is required, it will be obtained clearly and expressly through account documentation, digital platforms, or other lawful means.

You may withdraw consent at any time; however, this may affect our ability to provide certain services.

Personal data may be disclosed without consent where disclosure is required or authorized by law; necessary for compliance with FSC or other regulatory authorities; required for legal proceedings or enforcement of legal rights; or necessary to protect vital interests.

6. Change of Purpose

Personal data will only be used for the purposes for which it was collected. Where processing for a new purpose is compatible and lawful, we will inform you as required by law.

7. Categories of Personal Data We Collect

• Identification Data: Passport, national ID, date of birth;
• Contact Information: Address, telephone number, email;
• Socio-Demographic Data: Employment, nationality, education;
• Financial Information: Income range, financial history, source of funds;
• Transactional Data: Account details, payments, trading activity;
• Technical and Usage Data: IP address, device identifiers, login data;
• Communication Records: Emails, calls, chat logs;
• Compliance Data: KYC, AML, sanctions screening results;
• Publicly Available Data: Information from lawful public sources.

8. Special Categories of Personal Data

Where permitted and required by law, we may process special categories of personal data (as defined under the Data Protection Act 2017), including health or biometric data, strictly for lawful purposes and with appropriate safeguards.

Criminal conviction data is processed only for regulatory compliance, including AML/CFT obligations.

9. Purpose of Processing

• Provide financial, trading, investment, and advisory services;
• Conduct identity verification and due diligence (KYC/AML);
• Comply with FSC, tax, and legal obligations;
• Manage risk, fraud prevention, and internal controls;
• Improve services, systems, and customer experience;
• Respond to legal claims, audits, and regulatory requests.

10. Contact Details

Data Protection Officer
Trade T Capital Markets Ltd
FSC House
54 Cybercity
Ebene, Republic of Mauritius
Email: legal@trilliontrades.com

Last updated: January 2026

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