TradeRings Privacy Policy

1. Introduction

TradeRings, Inc. ("TradeRings", "we", "us", "our") respects your privacy and is committed to protecting the personal and organisational information of users of the TradeRings trading platform, website, mobile applications, integrations, and related services (collectively, the "Platform").

This Privacy Policy explains what information we collect, how we use it, who we share it with, how we keep it secure, and the rights available to you in relation to it. It is incorporated by reference into the TradeRings Platform Terms of Use (the "Terms").

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. Where you act on behalf of an organisation (an "Organisation"), you represent that you have authority to bind the Organisation to it.

Defined terms used in this Privacy Policy that are not defined here have the meanings given in the Terms.

2. Information We Collect

2.1 Personal information

We collect personal information that identifies, relates to, or could reasonably be associated with an individual User, including:

1. Full name.
2. Email address.
3. Mobile and other phone numbers.
4. Profile information.
5. Login credentials and authentication factors.
6. Payment information (held by our payment processor where applicable).
7. Records of communications with TradeRings and through the Platform.
8. Usage data within the Platform.
9. Device information and IP address.

2.2 Organisation information

We collect information about Organisations that register on the Platform, including:

1. Legal name.
2. Entity type.
3. Registration number.
4. Tax identification number.
5. Registered and trading addresses.
6. Contact details for the Organisation and its Account Owner.
7. Financial information necessary for billing.
8. Trading history and patterns on the Platform.
9. Authorised representatives and their roles.

2.3 Market and Transaction information

We collect detailed information about Markets and Confirmed Orders on the Platform, including:

1. Product details (identifiers, descriptions, units, attachments).
2. Pricing information.
3. Volume and inventory information.
4. Delivery terms (date, location, instructions).
5. Payment terms.
6. The Organisations and Users party to each Confirmed Order.
7. Negotiation and confirmation history.

2.4 Communications and messaging-channel information

The Platform ingests order signals from inbound communication channels including chat (WhatsApp), email, and integrated channels. We may collect, process, and store:

1. The content of messages, including text, images (photographs of handwritten notes, product references, attachments), voice messages, and documents (PDFs, spreadsheets) supplied by your customers or by you.
2. Channel metadata, including sender identifiers (mobile number, email address), timestamps, and the inbound channel through which a message was received.
3. The interpreted intent extracted by the Trading Engine and the structured order draft produced from it.

We collect this information solely to operate the order capture, pricing, confirmation, and handover functions of the Platform, and to keep an audit trail of how each Confirmed Order was produced from the underlying signal.

2.5 Integration and ERP-sourced information

Where an Organisation connects an ERP system or other Partner service to the Platform, we collect data routed through that integration, which may include:

1. Customer master data (organisation names, contact persons, addresses, payment terms, account balances).
2. Product master data (SKUs, descriptions, units of measure, tax codes, images, specification documents).
3. Pricing data (price lists, customer-specific pricing, promotions).
4. Inventory data (stock levels, available-for-sale quantities).
5. Order and order-status data flowing between the Platform and the ERP.

The direction and cadence of these data flows are configured in the integration specification agreed with the Organisation. We process integration data only to the extent necessary to provide the integration and the dependent Platform services.

2.6 Technical information

We automatically collect certain technical information when you use the Platform, including IP address, browser type and version, operating system, access times and dates, pages viewed, features used, device identifiers, and error logs.

3. How We Collect Information

We collect information from you when you:

1. Register for an Account on the Platform.
2. Complete your profile.
3. Create or join a Market.
4. List products or configure pricing, inventory, or fees.
5. Engage in trading activity.
6. Confirm orders.
7. Communicate through the Platform.
8. Contact our support team.
9. Connect an ERP or other Partner integration.
10. Upload documents or other Content to the Platform.

We may also collect information about you from third-party sources, including business partners (such as referring partners), public databases and registries, verification services, and Partners where you have connected an integration.

4. How We Use Your Information

We use the information we collect for the following purposes.

4.1 Providing and operating the Platform

1. Operating and maintaining the Platform.
2. Interpreting inbound order signals through the Trading Engine, matching them to your catalogue, applying pricing, validating inventory and trading rules, and producing structured orders for confirmation.
3. Processing Confirmed Orders and posting them to your ERP where an integration is configured.
4. Facilitating communications between Users.
5. Authenticating Users and Organisations.
6. Personalising User experience.
7. Developing new features and services.
8. Analysing aggregated usage to improve the Platform.
9. Technical troubleshooting.

4.2 Business operations

1. Calculating and invoicing Platform fees.
2. Processing payments where applicable.
3. Verifying User and Organisation identity.
4. Enforcing the Terms and our policies.
5. Detecting, investigating, and preventing fraud, abuse, and security incidents.
6. Managing affiliate and partner relationships.
7. Measuring the effectiveness of Platform features.

4.3 Communications

1. Sending administrative and transactional notifications.
2. Providing order status updates.
3. Responding to enquiries and support requests.
4. Sending service updates and announcements.
5. Marketing our services (subject to your preferences and to applicable law).

4.4 Legal and compliance

1. Complying with legal obligations.
2. Resolving disputes.
3. Enforcing our agreements.
4. Protecting the rights, property, and safety of TradeRings, our Users, and others.

5. Automated Processing by the Trading Engine

The Platform includes automated processing components (collectively, the "Trading Engine") that interpret inbound order signals, match products and customers, apply pricing, validate orders against inventory and other Platform rules, and surface results for confirmation. The output of the Trading Engine is presented to a User (the buyer, the seller, or both) for explicit confirmation. No Confirmed Order is produced without that explicit confirmation; the Trading Engine does not unilaterally bind any Organisation to a Transaction.

Where you believe the Trading Engine has produced an incorrect interpretation or pricing on a specific order, you may request a review by contacting support@traderings.io with the order reference. A human reviewer will examine the underlying signal and the produced output and act on legitimate corrections.

6. Information Sharing and Disclosure

We share your information only as described below.

6.1 Trading counterparties

To facilitate Transactions, we share necessary information with trading counterparties within the same Market, including the Organisation name and contact details of authorised representatives, the relevant Transaction details, and the credit and payment information needed to complete the Transaction.

6.2 Market participants

When an Organisation joins a Market, certain information is visible to other participants in that Market, as configured by the Market Owner. This may include the Organisation name and details, User names and roles, trading activity, and product listings.

6.3 Service providers

We share information with third-party service providers that help us operate the Platform. The categories include hosting providers, payment processors, analytics providers, customer support tools, communications providers, messaging-channel providers (for example WhatsApp Business Platform and email gateways), authentication providers, and security services. We require those providers to handle your information in accordance with this Privacy Policy and applicable law, and only for the purposes for which we engage them.

6.4 Affiliate partners

Where an Organisation was referred to the Platform by an affiliate, we may disclose to that affiliate the value of Confirmed Orders concluded by the referred Organisation so the affiliate can verify referral commission. The disclosure is limited to what is necessary for that purpose and is subject to confidentiality obligations on the affiliate.

6.5 Partner integrations selected by the Organisation

Where you connect a Partner integration (for example an ERP, trade finance provider, credit insurance provider, logistics provider, foreign exchange provider, or analytics service), we share the relevant Transaction and master data with that Partner as required to provide the integration. You control which Partner integrations are enabled.

6.6 Aggregated and anonymised data

We may share aggregated and anonymised data derived from Platform usage for the purpose of improving the Platform, generating industry insights, and benchmarking. Aggregated and anonymised data does not identify any Organisation, User, customer, or Transaction.

6.7 Legal and regulatory authorities

We may disclose your information where required to do so by law or in response to a valid request from a public authority such as a court or government agency. Where lawful and practicable, we will notify the affected Organisation before disclosure.

6.8 Business transfers

If TradeRings is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you and, where required, give you a choice before your information becomes subject to a different privacy policy.

6.9 Notification of non-payment or breach

Where an Organisation fails to settle undisputed Platform fees, or materially breaches the Terms in a manner that affects other participants in a Market, we may notify the affected Market Members of the fact and the reason, so they can make informed decisions about continuing to trade with that Organisation. We do not publish details of non-payment or breach on our public website or other public channels. Disclosure is limited to Market Members with a legitimate interest and is made in accordance with applicable law.

6.10 Consent

We may share your information with other third parties where you have provided your explicit consent.

7. Verification, Credit, and Reference Checks

Where required to operate the Platform safely and lawfully, we may verify Organisation and User identity and, in future, may carry out credit and reference checks. By using the Platform, you consent to:

1. Verification of business registration, tax registration, and authorised-representative information against public registries and verification services.
2. Verification of identity documents you submit as part of any Know Your Customer process.
3. Where credit checks are introduced and you opt in or are notified, the receipt of credit reports from credit reporting agencies.

We use the information collected through these checks to verify your identity, assess fitness to operate on the Platform, manage risk, prevent fraud, and protect Platform integrity.

8. Data Security

We implement technical and organisational measures to protect information from unauthorised access, disclosure, alteration, and destruction. These include encryption of data in transit and at rest where appropriate, access controls and authentication, regular security assessments, employee training on data protection, and incident-response procedures.

No method of transmission over the internet or electronic storage is fully secure. While we use commercially reasonable measures to protect your information, we cannot guarantee absolute security.

We will notify the affected Organisation and, where required by applicable law, the relevant supervisory authority and affected individuals, of personal data breaches within the timeframes set by that law.

9. Data Retention

We retain your information for as long as necessary to fulfil the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria we use to determine retention periods include:

1. The duration of our relationship with you.
2. Legal obligations to which we are subject (including tax record-keeping).
3. The duration of any limitation period applicable to potential legal claims.
4. The need for evidence of Confirmed Orders, Platform actions, and acceptance events.

On termination of your Account, Confirmed Orders and the audit trail necessary to evidence them are retained for the period required by law. Other personal information is deleted or anonymised in accordance with our retention schedule.

10. Your Rights and Choices

Depending on your location and applicable law, you may have rights in relation to your personal information, which may include:

1. Access to your information.
2. Correction of inaccurate or incomplete information.
3. Deletion of your information, subject to legal and operational retention requirements.
4. Restriction or objection to processing.
5. Portability of your information in a structured, commonly used format.
6. Withdrawal of consent, where processing is based on consent.
7. Lodging a complaint with a supervisory authority.

To exercise any of these rights, contact privacy@traderings.io. We will respond within the period required by applicable law.

11. International Data Transfers

TradeRings operates internationally, and your information may be transferred to, stored, and processed in countries other than the one in which you reside, including the United States and any other country in which our hosting providers or service providers operate.

Where we transfer personal information out of jurisdictions with restrictions on cross-border data transfer (including the European Economic Area, the United Kingdom, and South Africa), we put in place appropriate safeguards, which may include the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or transfer mechanisms recognised under POPIA, as relevant.

12. Children's Privacy

The Platform is intended for use by businesses and their authorised personnel. It is not intended for individuals under the age of 18, and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will delete it.

13. Cookies and Similar Technologies

We use cookies and similar technologies to operate and improve the Platform. We use the following broad categories:

1. Strictly necessary cookies. Required for the Platform to function, including session management and security. These cookies cannot be disabled without breaking the Platform.
2. Functional cookies. Remember your preferences (for example language, layout) so the Platform can be tailored to you.
3. Analytics cookies. Help us understand how the Platform is used so we can improve it. Used in aggregate.
4. Marketing cookies. Used on the public website only, to measure the effectiveness of our marketing.

You may set your browser to refuse some or all cookies. Disabling strictly necessary cookies will break parts of the Platform. Where required by applicable law, we display a consent banner that lets you choose which categories to allow.

14. Third-Party Links and Services

The Platform may contain links to third-party websites and services. This Privacy Policy does not apply to that third-party content. We recommend reviewing the privacy policies of any third-party site or service before providing it with your information.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates take effect when posted, with the "Last updated" date at the top revised accordingly. Where a change is material, we will give prominent notice on the Platform and, where required, ask you to acknowledge the updated policy before continuing to use fee-bearing functions.

16. Contact Us

Questions about this Privacy Policy or our privacy practices may be directed to:

17. Jurisdiction-Specific Provisions

17.1 South Africa (POPIA)

If you are located in South Africa, or your personal information is processed in connection with activities carried out in South Africa, the Protection of Personal Information Act, 2013 (POPIA) applies. TradeRings processes personal information in accordance with the conditions for lawful processing set out in Chapter 3 of POPIA, including accountability, processing limitation, purpose specification, further processing limitation, information quality, openness, security safeguards, and data-subject participation.

Operator details for the purposes of POPIA: TradeRings, Inc. acts as the responsible party in respect of the information described in section 2 above, except where it acts as an operator on behalf of an Organisation in relation to that Organisation's customer master data, product master data, pricing, or messaging-channel content (section 2.4 and 2.5). In those cases the Organisation remains the responsible party and TradeRings processes the data on its behalf in accordance with the Terms.

Data subjects in South Africa may contact the Information Regulator at inforeg@justice.gov.za with concerns that have not been resolved through privacy@traderings.io.

17.2 European Union and United Kingdom (GDPR / UK GDPR)

If you are located in the European Union or the United Kingdom, we process your personal information in accordance with the General Data Protection Regulation (EU 2016/679) or the UK GDPR, as applicable. Lawful bases on which we rely include performance of a contract (Article 6(1)(b)), our legitimate interests in operating, securing, and improving the Platform (Article 6(1)(f)), compliance with legal obligations (Article 6(1)(c)), and your consent where required (Article 6(1)(a)). You may exercise the rights listed in section 10 and lodge a complaint with your local supervisory authority.

17.3 California (CCPA / CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to delete personal information we have collected, the right to correct inaccurate personal information, the right to opt out of the sale or sharing of personal information, and the right to limit use of sensitive personal information. TradeRings does not sell personal information for monetary consideration.

17.4 Other jurisdictions

We comply with applicable data-protection laws in the jurisdictions in which we operate. Specific supplementary provisions may apply based on your location and will be provided on request to privacy@traderings.io.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.