Privacy Policy

1. Who we are

Hoc-Trade Technology Pte. Ltd. ("Hoc-Trade", "we", "us", or "our") is the data controller responsible for your personal data. We are registered in Singapore (company registration number 202411346W) with our registered office at 11 Collyer Quay, #17-00 The Arcade, Singapore 049317.

EU Representative:

In accordance with Article 27 of the EU General Data Protection Regulation (GDPR), we have appointed EU-Rep Global as our representative in the European Union.

UK Representative:

In accordance with Article 27 of the UK General Data Protection Regulation (UK GDPR), we have appointed EU-Rep Global as our representative in the United Kingdom.

2. What data we collect

2.1 Account data

When you create a TradeMedic account: email address, username, and hashed password. If you connect a trading account: your broker name, server name, and account number.

2.2 Trading data

If you use TradeMedic, we access your trading history (trade entries, exits, instruments, volumes, timestamps, and profit/loss) to perform behavioral analysis. This data reaches us either directly from you (B2C) or from a broker partner. The trading data is used exclusively for generating your personalized TradeMedic report.

2.3 Usage data

Information about how you use the Website and the Service, including pages visited, features used, and interaction timestamps.

2.4 Data collected automatically

Technical data: IP address, browser type and version, operating system, device identifier, language preference, referring URL, and timestamps of your activity.

2.5 Cookies and similar technologies

Information collected through cookies, pixels, and similar technologies. For details, please see our Cookie Policy and the cookie consent banner shown on your first visit.

2.6 Data from third parties

If you use TradeMedic through a broker partner, we receive your trading data from the broker under the terms of your relationship with that broker.

3. Why we process your personal data

For users subject to Singapore's Personal Data Protection Act (PDPA), we process personal data in accordance with the consent and notification obligations under the PDPA.

3.1 Anonymized and aggregated data

We anonymize and aggregate trading data to conduct research into retail trading behavior, improve our algorithms, and produce statistical insights for publication (for example, on our blog, in research reports, or in content shared with partner brokers). Once data is fully anonymized, it is no longer personal data under the GDPR, PDPA, or other applicable data protection laws, and may be used without restriction. No individual trader can be identified from our published research or aggregated statistics.

4. Who we share data with

We do not sell personal data. We do not share personal data with advertisers.

5. International transfers

Your data is primarily processed in Singapore (DigitalOcean and Azure). Some sub-processors operate from or process data in the United States and other countries. Where data is transferred outside the EU/EEA or the United Kingdom, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Agreement or Addendum where applicable.

6. How long we keep data

7. Your rights

Under the GDPR (EU/EEA residents)

You have the right to: access your personal data, rectify inaccurate data, erase your data ("right to be forgotten"), restrict processing, data portability, object to processing based on legitimate interest, and withdraw consent at any time. To exercise these rights, contact us at privacy@hoc-trade.com or our EU representative. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection authority.

Under the UK GDPR (United Kingdom residents)

You have the same rights as EU/EEA residents listed above, as the UK GDPR provides equivalent protections. To exercise these rights, contact us at privacy@hoc-trade.com or our UK representative. We will respond within 30 days. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

Under the PDPA (Singapore residents)

You have the right to: access your personal data, correct inaccurate data, and withdraw consent for processing. Contact us at privacy@hoc-trade.com.

Under the CCPA (California residents)

You have the right to: know what personal information we collect, request deletion, and opt out of the sale of personal information. We do not sell personal information.

8. Children

Our Website and Service are not intended for anyone under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us at privacy@hoc-trade.com and we will delete it promptly.

9. Cookies

We use cookies on the Website. For full details about what cookies we use, why, and how to manage them, please see our Cookie Policy.

10. Changes to this policy

We may update this Privacy Policy from time to time. We will update the "Last updated" date at the top of this page when changes are made. For material changes, we will provide at least 30 days' notice by email or by a prominent notice on the Website.

11. Contact us