Privacy Policy

The Company respects your privacy and is committed to protecting and respecting your personal information. This Privacy Policy is intended to inform you how we collect and process any personal data, namely information relating to a client (as defined below) that can be used to identify a natural person (hereinafter referred to as the “Data”), in accordance with applicable data protection laws and best practices.

We are committed to building one of the world's most secure brokerage infrastructures. In this Privacy Policy, we explain why you can trust us and confidently entrust your information to us for processing, ensuring that your data remains safe and secure.

Please be sure to read this Privacy Policy and any other privacy policies we may provide when we collect or process your data in specific situations, so you fully understand how and why we use your data.

In this Privacy Policy, unless the context otherwise requires, the terms defined herein shall have the meanings given to them in the Terms and Conditions.

Please note that this Privacy Policy applies to customers and potential customers. If you are an employee, contractor or third-party service provider of the company, your personal information will be used to perform your employment contract, contractual relationship or in accordance with our separate policies. You can contact us through the contact information listed in the "Our Contact Information" section below to obtain these separate policies.

If you participate in our affiliate program and/or referral broker program, we will process the data you provide according to the agreement we have with you, to exercise our rights and fulfill our obligations under the relevant agreement or related thereto, and the term "customer" in this Privacy Policy should be interpreted to include "affiliate" and/or "referral broker" (as applicable).

1. Who We Are

Our Trading212 is a European brand operated by SKY LADDER LLC. SKY LADDER LLC is a company registered in Antigua and Barbuda, with its registered address at 41 Nevis Street, St. John's, Antigua and Barbuda, and/or its affiliates (hereinafter referred to as "us" or "the Company"). We are the controllers and responsible parties for the data disclosed by clients when registering for trading accounts, demo accounts and/or using any other services provided through our website (hereinafter referred to as the "Website").

Our company is responsible for collecting and/or processing your data when you use our trading platform (including trading accounts or demo accounts, and their mobile/desktop versions) (hereinafter referred to as the "Services"). We respect your privacy and are committed to protecting the data we collect, use and/or access.

We take measures to implement advanced data protection policies and procedures, and will update these policies and procedures from time to time to ensure the security of client data and accounts. We take legal, administrative and technical measures to protect your data, ensuring its confidentiality, integrity and availability. To prevent security incidents involving your data, we adopt a combination of organizational and technical approaches based on our annual risk assessment results.

Unless a client agrees in writing to disclosure, or applicable law requires disclosure, or it is necessary for identity verification purposes, or it is necessary for fulfilling contractual obligations under any agreement entered into with the client, we will not disclose any private information of clients or former clients. Client information will only be processed by our employees and/or trusted third parties required for providing our services. All such information will be stored on electronic and physical storage media in accordance with applicable laws.

2. How We Use Your Data

1. We may collect, use, store and transfer various types of data about you, which are categorized as follows:

• Identity Data includes your first name, last name and father's name (if applicable), date of birth, gender, passport, national ID, driver's license number and copies of photographs.
• Contact Information includes your billing address, email address and phone number.
• Financial Data includes your bank accounts, payment card details and tax identification numbers (including but not limited to Social Security numbers, income tax identification numbers, National Insurance numbers).
• Transaction Data includes details of transactions you have executed, payment details, withdrawal details, exchange details, transaction history, profits, balances, deposit and withdrawal amounts and methods, as well as any other details related to the services you use through our website.
• Technical Data includes your Internet Protocol (IP) address, login information, browser type and version, time zone settings and location information, browser plugin types and versions, operating system and platform information, as well as other technical information about the device you use to access the website and the usage of cookies stored on your device.
• Personal Data includes your client account details, username and password, transactions you have made, your interests, preferences,
• Usage Data includes information about how you use the website, products and services, registration date, account type, transaction clusters, number of complaints, number of requests submitted and IP history.
• Marketing and Communication Data includes your preferences for receiving our marketing communications and your communication preferences.
• Special Category Data / "Sensitive" Data includes information about your religious beliefs, annual income, biometric data and/or criminal convictions and crimes.
• Eligibility Data includes your educational background, employment status, trading experience, self-assessment tests and other relevant information.
• Banking Data includes detailed information about your payment wallets and/or your bank card information, including issuing bank information, card number, cardholder name, card expiry date, payment system, card verification code (CVV2 / CVC2) and photos of the front and back of your bank card.
• KYC (Know Your Customer) Data includes identification document information, including recent utility bills, national ID cards, passports and/or driver's licenses.
• Economic Profile Data includes detailed information about your profession, investment purposes, annual income, net worth, expected annual investment amount and sources of funds.
• Location Data includes your actual location details when interacting with our website (e.g., a set of parameters that determine your interface region settings, namely the country/region of residence, time zone and interface language).
• Audio Data includes complete recordings of all calls between you and us, including recordings of calls you receive or make to us. (The above are collectively referred to as "Personal Data")

2. Aggregated Data includes statistical or demographic data used for any purpose. Such data may originate from your data, but since it does not directly or indirectly reveal your identity, it may not be considered personal data under applicable law. For example, we may aggregate your usage data to calculate the percentage of users who access specific website features and/or prefer certain services/products.

Nevertheless, if we combine Aggregated Data with Data in any way that enables the identification of a data subject, we will treat such combined data in accordance with the provisions of this Policy.

We process your Data in accordance with the principles of lawfulness, fairness, and transparency and consistently adhere to the principles of purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, and accountability.

We generally collect and process personal data for one or more of the following reasons:

1. To perform our contract with you;

2. To comply with our legal obligations, including but not limited to applicable anti-money laundering and counter-terrorism financing laws (hereinafter referred to as the "AML Laws");

3. To protect our legitimate interests.

Customers acknowledge that all or part of the data related to customer accounts and associated transactions will be stored by us, and we may use such data when disputes arise with customers.

In case of any changes, customers are responsible for promptly updating the information provided to us. Although we will make every effort to ensure your data remains current and review and verify any information you provide, we may not always be able to do so without your assistance. Customers acknowledge and agree that we shall not be liable for any obligations or responsibilities regarding the review or verification of the above information.

3. How Do We Collect Your Personal Data?

We use various methods to collect Data about you, including:

Direct Interaction. You will provide your identity information, contact details, and financial data online through the website, and/or by filling out online forms and/or by contacting us via email or other means. When you wish to:

1. Register for a trading account;

2. Register for a demo account;

3. Subscribe to our publications and updates;

4. Request to receive marketing and promotional information;

5. Participate in competitions, promotions, or surveys;

6. Provide feedback or contact us, you can submit information to us.




We need to collect the above data, so that we can

(i) provide our services effectively.

(ii) fulfill our ongoing legal obligations, including but not limited to preventing fraud and money laundering.

If you fail to provide the data as required, we may not be able to fulfill the contract with you (for example, to provide services). In this case, we may have to cancel the services you have ordered, but we will notify you in a timely manner. It is important to ensure that the data we hold about you is accurate and up-to-date. If there are any changes to your information during our cooperation, please inform us promptly.

Automated Technologies or Interactions. When you use our services, your device will automatically transmit its technical characteristics to us. We use region settings (a set of parameters used to determine your interface's regional settings, including your country/region, time zone, and interface language) to provide you with the best platform experience. We will use information about IP addresses, Cookie files, browser and operating system information, website access dates and times, and requested page addresses to provide you with the best Web application, mobile version, and/or desktop version experience, and to monitor your behavior in order to improve the efficiency and availability of our services. We use web analytics tools to track the performance of our website and user marketing sources in order to optimize our marketing costs and provide users with a better experience. You can request at any time that we stop any such transmissions (within feasible limits and in compliance with our legal obligations), by using the email address you disclosed and registered through your account, and by sending your request to the Data Protection Officer (DPO) through the detailed information provided under "Our Contact Information". We will process your request within 30 working days.




4. For What Purposes Do We Use Your Data and Based On What Legal Grounds?

We process the above data in accordance with applicable laws from time to time, so as (i) to fulfill our contractual obligations to customers and provide them with the best service, (ii) to provide our services efficiently, (iii) to comply with our legal obligations, including but not limited to preventing fraud and money laundering, and (iv) to protect our legitimate interests and your vital interests.

We process all data based on the following legal grounds:

1. To fulfill our legal obligations;

2. To fulfill our contractual obligations to customers;

3. To maintain our legitimate interests, while your interests and fundamental rights do not override these interests;

4. Based on your consent.

If you are an existing customer of this website and we have legitimate interests in contacting you or you have agreed to our collection and processing of your personal data, we will collect and process your personal data so that we can provide support when needed, and/or send you newsletters, push notifications, and calls, allowing you to stay updated on our new features, news, and events, and provide our comprehensive services efficiently. We will also use your data to send you marketing information about our services that we believe you may be interested in via email or other means.

5. Opting Out

If you do not wish to receive any marketing information or have your data transferred to third parties for marketing purposes, you can set your preferences. You can set these preferences in the following three scenarios: (i) when opening an account; (ii) when receiving such advertising content; (iii) after logging in by going to "My Account" > "Personal Information" > "Notification Settings". You can also request at any time that we stop sending such advertising content or stop transferring your data to third parties for marketing purposes.

6. Data Disclosure

We may share your data with relevant parties for the purposes mentioned above.

We will take all reasonable measures to ensure that our third-party service providers do not use your personal data for their own purposes, and only allow them to process your data for specific purposes and in accordance with our instructions.

Generally, your data will be used by our data processors. Additionally, as part of our business or its part transfer, for example, through reorganization, asset sale, merger, consolidation or similar forms, your data may be transferred to other legal entities.

Regarding the transfer of data to recipients other than associated entities and/or affiliates, we hereby state that we strive to be cautious about customer-related matters and the evaluations we have. We will only disclose information related to you under the following circumstances: (i) when required by law; (ii) when you explicitly instruct us to handle transactions or any other services, we will disclose your data; (iii) when necessary to fulfill our contractual relationship with customers; (iv) when necessary to protect our legitimate interests and comply with applicable laws and regulations.

Chatbot: Our chatbot services may be provided through platforms of third-party service providers. These service providers may process the information you share according to their own privacy policies. We recommend that you read the privacy policies of third-party service providers carefully before sharing any information or details, so as to understand how they handle your data. Using the chatbot indicates your explicit agreement that we are not responsible for any improper management, misuse or improper handling of your data caused by using the chatbot.

Please do not share personal, sensitive or confidential information with the chatbot. Using the chatbot and/or services does not require disclosure of such data. If you disclose personal or confidential data, the risk is at your own expense.

You acknowledge that we are not responsible for any damage and/or loss and/or injury you may suffer due to the following reasons and/or related reasons: (a) any inaccuracy, defect, error or omission in the data and/or information and/or output provided by the chatbot; (b) any error and/or omission in the information provided by the chatbot, as well as/and any action taken based on reliance on such information.

External Third Parties. Your data will be shared with third-party organizations/entities, including but not limited to:

A. Service Providers We may share your data with trusted third-party service providers, who represent us in operating, maintaining and/or supporting our IT systems and IT infrastructure, our website, managing our payment solutions, conducting statistical analysis, marketing and advertising, sending newsletters, providing customer support, and offering other important services.

B. Other Associated Entities or Affiliates. We may also disclose your data to other Trading212 associated companies to enable them to provide related services.

C. Governmental Authorities. The detailed information you provide during your use of this website may be disclosed to governmental authorities. We will only disclose such information when required by applicable laws or court orders, and within the minimum scope necessary.

D. Other Disclosures. Except for cases where you have consented to the disclosure of data or where disclosure is necessary to achieve the collection purpose, we may also disclose data in special circumstances, for example, when we have reason to believe that disclosing the data is necessary for identifying, contacting or taking legal action against any damage, harm or interference (whether intentional or not) to our rights or property, users or any other persons who may be harmed by such activities, or under other circumstances where it is necessary to protect the data.

Within reasonable limits, management should ensure that third parties representing us in collecting, storing or processing personal information meet the following conditions:

a. Have signed agreements compliant with this Privacy Policy and information security practices or have implemented applicable legal requirements for protecting personal information;

b. Have signed confidentiality agreements or non-disclosure agreements, which include privacy clauses in the contract;

c. Have established procedures to fulfill the terms of the agreements for protecting personal information signed with third parties.

For any misuse or unauthorized disclosure of personal information by third parties representing Trading212 in collecting, storing or processing personal information, remedial measures should be taken.

If you wish to obtain more information about any of the above data transfers, please contact us through our customer service.

7. Data Retention

We will retain your Data for as long as is reasonably necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation in relation to our relationship with you.

To determine the appropriate retention period for your Data, we consider the amount, nature, and sensitivity of the Data, the potential risk of harm from unauthorized use or disclosure of your Data, the purposes for which we process your Data and whether those purposes can be achieved through other means, as well as the applicable legal, tax, accounting, and other requirements.

We will retain your Data (including call recordings) throughout the duration of our contractual relationship and for a period of at least seven (7) years from the date you cease using our Services.

As a general rule, unless there is another legal basis requiring retention, all other Data will be retained for thirty (30) business days following the termination of our Services.

Upon the expiration of the applicable retention period, the Data will be irreversibly destroyed. We will also notify all third parties that have received such Data of the deletion and require them to take similar actions.

8. Your Rights and How to Exercise Them

We require you to provide true, accurate, and up-to-date identification information and not to impersonate any individual or legal entity. If any of your identification information changes, you must notify us immediately and no later than seven (7) days after such change occurs. If your information is inaccurate or incomplete, please contact us using the contact details provided in the "Contact Information" section below so that we can correct your information.

Under certain circumstances, you have specific rights under applicable laws and our policies, as amended from time to time. Some of these rights are complex and subject to exceptions; therefore, we strongly recommend that you contact us.

A. Access Right. You have the right to confirm whether we are processing your data. Additionally, you have the right to obtain more detailed information about the data we have stored and the processing we have conducted, and you may have the right to receive a copy of the data in certain circumstances.

B. Rectification Right. You have the right to request that we correct inaccurate or incomplete data, and considering the purposes of processing, you have the right to request supplementation of incomplete data.

C. Deletion Right. In certain circumstances, you have the right to request that we delete your personal data, provided that we do not have a legitimate reason to continue processing such data. To delete your account and all personal data currently stored in our systems, please contact us through our customer service.

D. Restriction of Processing Right. You have the right to request restriction of processing your personal data if: (a) the data is inaccurate; (b) the processing may be unlawful, but you do not wish for us to delete your data; (c) we no longer need your data, but you require us to retain it; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate reasons for using such data.

E. Data Portability Right. If the legal basis for data processing is your consent and such processing is carried out through automated means, you have the right to receive your data in a structured, commonly used and machine-readable format. However, this right does not apply if doing so would adversely affect the rights and freedoms of others or if it is technically impossible.

F. Objection Right. Within the scope of legal grounds for processing activities, you have the right to object to the processing of your personal data. Please note that in certain circumstances, we may have overriding legitimate reasons for processing your information.

G. Right to Withdraw ConsentWhere the legal basis for processing your personal data is your consent, you have the right to withdraw such consent at any time. This may apply to marketing purposes and/or the transfer of your data to third parties.If you withdraw your consent, we will stop processing your data unless and only to the extent that applicable data protection laws or other applicable laws and regulations permit or require continued processing.Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

If you wish to exercise any of the above rights or learn more about your rights and our practices, please contact us via Customer Support. Please also provide the necessary information to help us process your request, including your full name, telephone number, and email address, so that we can verify your identity. We will respond to your request as soon as possible.

We aim to respond to all reasonable requests within one month. However, if your request is particularly complex or if you have submitted multiple requests, it may take longer than one month. In such cases, we will notify you and keep you updated on the progress.

For any unreasonable or excessive requests, as well as any additional copies of your data that you may request, we may charge a reasonable administrative fee.

9. Data Security

We have implemented appropriate security measures to prevent your Data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Data to employees, agents, contractors, and other third parties who have a business need to know. They will only process your Data on our instructions and are subject to a duty of confidentiality.

Your cooperation is essential to ensuring the security of your Data. When registering on the Website (or its mobile version), clients will be required to choose a username and password for each login, transaction, and use of services. To protect client privacy and operations on the Website, clients are strictly prohibited from sharing their registration credentials (including but not limited to username and password) with any other person or business entity. We shall not be responsible for any loss or damage arising from improper or unprotected use of such credentials, including use by any third party, whether or not authorized or known by the client.

The Company's online chat feature is not an official communication channel. We will never privately communicate with you through the online chat feature, nor request any information, including personal data. We shall not be liable for any data leakage resulting from you sharing private information with others.

All actions performed by clients using their username and password to access the Website are the sole responsibility of the client. We accept no liability for such use, including verifying whether the client has actually logged into their account.

If you suspect that your client account has been accessed without authorization, you are obligated to notify us immediately. You may contact us at any time via Customer Support.

Data Encryption in TransitEncryption technology provides a high level of security and privacy for your Data. When you enter data on our platform, we use strong encryption technologies (such as Transport Layer Security, TLS) to protect your Data from being compromised while it is transmitted from your device to our servers.

To provide a higher level of trust and security, we use digital certificates issued by trusted certificate authorities to confirm that all transmitted data is secure.

We are committed to protecting the security of your Data within our infrastructure. We consistently prioritize “Security by Design” as a core principle in the development of our services. “Security by Design” means that all new services and features are designed and developed in strict compliance with security requirements from the outset. This is essential to ensuring that once services or features are launched, all Data processed and stored by us is fully protected and kept private.

To safeguard your Data, we employ anonymization techniques that allow most of our services to operate without using your real identity data. Our services use system-generated IDs that cannot be traced back to your identity in place of real personal data.

We take the security of your Data stored within our infrastructure very seriously. For this purpose, all equipment used to process your Data is hosted in secure data centers. These systems are physically and logically isolated from direct internet access. We apply network segmentation to separate services with different security levels. In addition, we strictly limit employees’ logical access to your Data on a need-to-know basis. As a result, only employees who genuinely require access to your Data in order to provide the best service are granted such access.

Threat ProtectionWe have a deep understanding of modern data security and privacy threats and are fully prepared to respond to them. We continuously monitor, analyze, and respond to all events occurring within our infrastructure to ensure your Data is protected against threats, vulnerabilities, and malware.

In the event of a failure affecting data access, we have implemented data backup and recovery procedures that allow data restoration within a short period of time. To ensure rapid recovery, we have enabled high-availability modes for most critical databases, minimizing downtime.

If you choose not to provide personal data, in our business relationship, we may need to collect your data according to legal requirements or the terms of the contract you have signed.In principle, without this data, we will be unable to enter into or perform a contract with you.

If you choose not to provide these data, it may delay or hinder our performance of obligations. This may also mean that we cannot provide the necessary services for operating your account or policy.

How extensively do we engage in automated decision-making and user profiling? In the process of establishing and developing business relationships, we typically do not use automated decision-making. If we use automated decision-making in individual cases, we will notify you separately. In some cases, we may conduct user profiling to assess certain personal characteristics. If we carry out any user profiling, we will notify you accordingly. Generally speaking, any optional data collection will be clearly informed to you at the time of collection.

10. Links to Other Websites

We may provide links to third-party websites on our site. These linked websites are not under our control, and therefore we are not responsible for the actions of third parties linking to our site, including but not limited to collecting or disclosing your data. Before disclosing your data on any other website, we recommend that you read the terms of use and privacy policy of that website.

11. Changes to This Privacy Policy

This Privacy Policy was published by Trading212. We reserve the right to add, modify, or delete parts of this Privacy Policy in the future, to ensure that the information provided here regarding our collection and processing of your data is up-to-date and comprehensive. This Privacy Policy may include other information we receive from you and other terms and conditions applicable to this website, or other terms and conditions you agree to during your interaction with us.