GigaTrade Brokerage, LLC

GigaTrade Trading, LLC (“GigaTrade,” “we,” “us,” or “our”) respects your right to privacy and is committed to protecting the confidentiality and integrity of your personal information.

This Privacy Policy explains how we access, collect, use, disclose, retain, and protect information when current or prospective customers use the GigaTrader mobile application (the “App”), the GigaTrade website, or related products and services.

Additional financial privacy notices, customer agreements, and regulatory disclosures may apply to GigaTrade customers.

Why We Collect Information

We collect and process information to:

• Identify and authenticate users;
• Prevent unauthorized access, fraud, and other unlawful activity;
• Process account applications and provide account services;
• Provide trading, account-management, and related financial services;
• Process and maintain records of orders, transactions, deposits, withdrawals, and other account activity;
• Provide customer service and technical support;
• Operate, secure, maintain, and improve the App and our services;
• Communicate with customers regarding their accounts and services;
• Provide information about products, services, or educational materials that may be of interest; and
• Comply with legal, regulatory, supervisory, reporting, and recordkeeping obligations.

Information We Collect

Depending on how you use the App and our services, we may collect the following categories of information.

Identity and Contact Information

This may include:

• Name;
• Residential and mailing address;
• Email address;
• Telephone number;
• Date of birth;
• Social Security number or taxpayer identification number;
• Citizenship and residency information;
• Government-issued identification information; and
• Other information necessary to verify your identity.

Application and Financial-Profile Information

This may include information provided on applications, agreements, forms, or questionnaires, including:

• Employment and occupation;
• Income, assets, net worth, and source of funds;
• Investment objectives, investment experience, and risk tolerance;
• Tax information;
• Beneficiaries;
• Trusted contacts;
• Authorized persons; and
• Other information required to evaluate or administer an account.

Account and Transaction Information

This may include:

• Account number and account type;
• Account balances and buying power;
• Securities and other financial positions;
• Orders, executions, cancellations, and transaction history;
• Deposits, withdrawals, and funding instructions;
• Margin and risk information;
• Statements, confirmations, and tax documents; and
• Communications and customer-service records relating to an account.

Login and Security Information

This may include:

• Username or other user identifier;
• Authentication credentials;
• Multifactor-authentication information;
• Login history and session information;
• Security alerts; and
• Information used to detect unauthorized access or suspicious activity.

We use appropriate security controls to protect authentication information. Users are responsible for maintaining the confidentiality of their login credentials.

Device, Application, and Technical Information

When you access or use the App, GigaTrade and its service providers may automatically receive:

• Internet Protocol address;
• Device type and operating system;
• App version;
• Browser type and language settings;
• Device, application, or session identifiers;
• Network and connectivity information;
• Dates and times of App access;
• App interactions and features used;
• Crash logs, error reports, and diagnostic information;
• Performance and security information; and
• Information used for authentication, fraud prevention, and troubleshooting.

We use this information to operate and secure the App, authenticate users, prevent fraud, diagnose technical problems, understand App performance, and improve our services.

Cookies and Similar Technologies

Our website, the App, and App-based webpages may use cookies, session tokens, software development kits, pixels, or similar technologies. These technologies may be used to:

• Authenticate users and maintain sessions;
• Remember user preferences;
• Protect accounts and prevent fraud;
• Measure performance;
• Diagnose technical issues; and
• Understand how our services are used.

Device Permissions

The App may request permission to access particular device functions when necessary to provide a feature requested by the user. Depending on the features available in the App, these permissions may include:

• Notifications: To provide account, order, transaction, security, service, or other App notifications;
• Camera or photo library: To capture or upload identity documents, account documents, or other requested materials;
• Files or storage: To upload or download statements, confirmations, tax documents, or other account materials; and
• Biometric authentication: To enable device-supported login authentication. Biometric templates are generally controlled by the device’s operating system and are not received or stored by GigaTrade.

The App will request permission before accessing device functions where required. Users may manage most permissions through their device settings, although disabling a permission may prevent the associated feature from functioning.

GigaTrade does not access a user’s contacts, precise location, microphone, photographs, or other sensitive device information unless the App offers a feature requiring that information, the access is disclosed, and the user provides the required permission.

Sources of Information

We may collect information from:

• Information you provide through the App, our website, applications, agreements, forms, or communications;
• Information generated through your accounts and transactions;
• GigaTrade affiliates;
• Clearing firms, executing brokers, custodians, banks, exchanges, market centers, and other financial institutions;
• Identity-verification, authentication, credit-reporting, fraud-prevention, and regulatory-compliance providers;
• Trading-platform, market-data, and technology providers;
• Government agencies, regulators, self-regulatory organizations, and public records; and
• Cookies, software development kits, servers, and other technology used to operate the App and website.

How We Use Information

We may use information to:

• Establish, review, approve, and maintain accounts;
• Verify identity and account eligibility;
• Authenticate users;
• Display account balances, positions, market information, and transaction history;
• Receive, process, route, execute, clear, and settle orders and transactions;
• Process deposits, withdrawals, and account instructions;
• Provide customer service and technical support;
• Send account, transaction, security, regulatory, and service communications;
• Detect, investigate, and prevent fraud, unauthorized access, cybersecurity threats, and other prohibited activity;
• Monitor, troubleshoot, analyze, and improve the App;
• Maintain required business, supervisory, and regulatory records;
• Enforce agreements and protect legal rights; and
• Comply with applicable laws, regulations, court orders, governmental requests, and regulatory obligations.

We do not sell personal or sensitive user data collected through the App.

How We Disclose Information

We do not disclose nonpublic personal information except as permitted or required by law, as authorized by the customer, or as reasonably necessary to provide and support our services.

Information may be disclosed to:

• Clearing firms, custodians, executing brokers, exchanges, market centers, and other financial institutions;
• Trading-platform, order-routing, market-data, and account-technology providers;
• Banks, payment processors, and money-movement providers;
• Identity-verification, authentication, fraud-prevention, cybersecurity, and anti-money-laundering providers;
• Cloud-hosting, data-storage, communications, analytics, diagnostic, and technical-support providers;
• Auditors, attorneys, accountants, insurers, consultants, and other professional advisers;
• Regulators, self-regulatory organizations, law-enforcement agencies, courts, and governmental authorities;
• A user or the user’s authorized representative;
• Parties involved in a merger, acquisition, reorganization, financing, sale of assets, or similar business transaction; and
• Other parties when the user directs us or provides consent.

Service providers are authorized to receive information only as reasonably necessary to provide services to GigaTrade and are expected to maintain appropriate privacy and information-security protections.

Analytics and Third-Party Technology

The App may contain technology supplied by third-party service providers, including software development kits, market-data services, authentication tools, analytics tools, security services, and crash-reporting technology.

Depending on the services enabled in the App, these providers may process device information, application identifiers, Internet Protocol addresses, App interactions, performance information, diagnostic information, or other information necessary to provide their services.

GigaTrade uses these technologies for App functionality, market-data delivery, authentication, security, fraud prevention, performance monitoring, troubleshooting, and service improvement. We do not authorize providers to use personal or sensitive information obtained through the App for their own targeted advertising.

Confidentiality and Security

We maintain administrative, technical, electronic, procedural, and physical safeguards designed to protect personal information. These safeguards may include:

• Encryption of information in transit;
• Usernames, passwords, and multifactor authentication;
• Access controls;
• Security monitoring;
• Fraud-detection measures;
• Employee training; and
• Restrictions limiting access to authorized personnel and service providers with a legitimate business need.

No electronic system can be guaranteed to be completely secure. Users should protect their login credentials and promptly notify GigaTrade of suspected unauthorized access.

Data Retention

We retain information for as long as reasonably necessary to:

• Provide and administer accounts and services;
• Maintain business and transaction records;
• Prevent and investigate fraud;
• Resolve disputes;
• Enforce agreements; and
• Satisfy legal, tax, securities, commodities, anti-money-laundering, supervisory, and regulatory requirements.

Because GigaTrade operates in a regulated financial-services industry, certain account, identity, transaction, order, and communication records may be retained after an account is closed or a deletion request is received.

When information is no longer required, it will be deleted, anonymized, or otherwise disposed of in accordance with GigaTrade’s record-management procedures and applicable law.

Account Closure and Data-Deletion Requests

Users may request closure of their GigaTrader account and deletion of eligible personal information by contacting GigaTrade.

A deletion request will not require GigaTrade to delete information that must be retained for legal or regulatory compliance, fraud prevention, security, dispute resolution, taxation, litigation holds, or the establishment or defense of legal claims.

Information retained for one of these purposes will be limited to the information reasonably necessary and maintained for the applicable retention period.

Children’s Privacy

The App and GigaTrade’s services are not directed to children under 13. We do not knowingly collect personal information from children under 13 through the App.

Brokerage and trading services are available only to persons who satisfy GigaTrade’s account-eligibility requirements.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the App, our services, our information practices, applicable law, or our service providers.

The updated policy will be posted at this location with a revised “Last Updated” date. When required, we will provide additional notice through the App or obtain consent.