Legal
Proper Trades Privacy Policy
This Policy explains how Proper Trades handles information relating to website visitors, members, inquiries and broker referrals, and how to exercise your privacy rights.
Controller and contact details
Proper Trades Ltd, operating as Proper Trades, with company address at 31 Alexander Malinov Boulevard, Mladost 1A Residential Estate, 1729 Sofia, Bulgaria, is the controller responsible for the processing described in this Policy ("we", "us", "our").
Privacy requests: info@propertrades.com. Postal requests: 31 Alexander Malinov Boulevard, Mladost 1A Residential Estate, 1729 Sofia, Bulgaria.
For data-protection questions and rights requests, contact the controller directly at info@propertrades.com. The company’s Bulgarian contact details are given above.
This Policy covers our Website at https://propertrades.com, membership administration, broker-referral verification, communications, support and our operation of relevant Telegram communities. It explains our processing, not every activity undertaken independently by a broker or Telegram.
Our principal audience is in Asia, Africa and Latin America. We do not actively solicit EU customers, although eligible EU persons may request access where lawful. UK nationals, UK residents and people accessing from the United Kingdom are excluded under our Terms. These service restrictions do not extinguish privacy rights concerning information already processed, including inquiries or eligibility checks from an excluded person.
Because the company operates from Bulgaria, we apply the EU General Data Protection Regulation to personal-data processing in the context of that establishment. Our audience being principally outside the EU does not remove that responsibility. Additional mandatory privacy rights under another applicable law remain available.
Personal data and its sources
We limit collection to information relevant to the stated purposes. The categories relevant to our activities are described below. The information held about you depends on whether you only browse, contact us, join a Telegram community or use a broker referral; not every category applies to every person:
| Category | Examples and source |
|---|---|
| Contact and membership information | Name or display name, email address if supplied, residence and minimum nationality/age eligibility information, membership tier, admission and cancellation dates; supplied by you or generated during administration. We seek only the nationality information necessary to apply the UK exclusion and other verified restrictions. |
| Telegram information | User identifier, username, profile information visible to administrators, membership status, join/leave events where available, and messages or support requests you send; from you, Telegram, or any separately disclosed membership tool. |
| Referral and eligibility information | Referral code, click or campaign identifier, partner identity, a pseudonymous broker-account reference and qualifying status or dates; from referral interactions, you, or the relevant broker. The Exness affiliate report makes available client ID, qualification/status dates, country, campaign/sub-ID, platform, operating system, KYC status, tier, commission status and supported attribution IDs. PU Prime reports make available account/user identifiers, name, campaign source, deposits, withdrawals, net deposits, notional volume, lot totals and rebate amounts. A field’s availability does not mean that it is populated for every referral or that we need to export it. |
| Support and correspondence | Questions, complaint details, correspondence and necessary attachments; from you and our responses. |
| Website technical information | IP address, request timestamps, device/browser information, page requests, referring page and security/error logs; generated through Website operation and hosting. |
| Optional analytics and marketing information | Consented cookie or device identifiers, campaign parameters, usage events, communication preferences and consent records; from your interactions and the relevant tools. Any optional campaign measurement must be identified in the notice presented when it is enabled. This Policy does not claim that an advertising pixel or analytics service is active merely because such tools are commonly used. |
| Compliance and dispute information | Acceptance records, eligibility checks, records required for legal compliance and evidence relevant to a dispute; from you, our records or an identified lawful source. |
We do not need your broker password, payment-card credentials, full trading history or copies of government identity documents for routine membership administration. Do not send them to us. If a specific legal or verification need requires additional data, we will explain the reason, lawful basis and safeguards before collection.
Our current service model charges no membership fee. This Policy does not assume that we collect payment-card data or use a payment processor. Any future payment processing requires updated information identifying the data, processor, purposes and retention.
If we receive eligibility data from a broker rather than directly from you, we will identify that broker, the categories received and the purposes before the exchange where practicable, and otherwise provide the notice within the time required by applicable law. Under GDPR, this is normally no later than one month after receipt and earlier where required by the first communication or disclosure, unless a lawful exception applies. We do not treat all broker-held information as available to us.
Purposes and lawful bases
Where GDPR or a similar lawful-basis requirement applies, we rely on the basis appropriate to the particular processing:
| Purpose | Data used | Basis and limits |
|---|---|---|
| Admit members, administer channel access and deliver requested service communications | Necessary contact, membership and Telegram information | Performance of our membership contract or steps you request before it. Only objectively necessary processing falls under this basis. |
| Verify properly disclosed Premium referral eligibility | Minimum account reference, partner and qualifying-status information | Contract where the minimum qualifying-status check is necessary to provide the conditional access you request. Additional attribution reconciliation uses our legitimate interest in accurate referral accounting. Non-essential device tracking requires consent where applicable; a broker’s separate account processing is governed by its notice. |
| Answer support requests and administer complaints | Correspondence, identifiers and relevant evidence | Contract for service support; legal obligation where a specific complaints duty applies; legitimate interests in investigating and resolving other inquiries or claims. |
| Keep the Website and community secure, prevent misuse and diagnose failures | Technical logs, access events and necessary account identifiers | Legitimate interests in protecting the Service and members, following a necessity and balancing assessment; legal obligation where a specific rule applies. |
| Keep statutory records and respond to lawful regulatory requests | Required membership, disclosure, complaint or referral records | Legal obligation where Bulgarian accounting, tax or other applicable recordkeeping law requires the particular record. We retain only the information required for that duty; unrelated correspondence is not treated as a statutory financial record. |
| Administer partner accounting and investigate attribution disputes | Minimum referral identifiers, status and remuneration records | Legitimate interests in accurate commercial accounting and preventing fraud, subject to balancing and any applicable consent requirements. |
| Send optional promotional messages | Contact details and preferences | Consent where required by electronic-marketing law; otherwise a lawful exception only where its conditions are met. Contractual service notices do not authorise unrelated marketing. |
| Measure optional analytics, advertising or referral tracking using non-essential device access | Cookie/device identifiers and usage or conversion events | Prior consent where required for storing/accessing device information and the associated processing. Any different basis for subsequent processing must be separately assessed and disclosed. |
| Establish, exercise or defend legal claims | Relevant, proportionate records | Legitimate interests in protecting legal rights, or legal obligation where applicable. |
Our legitimate interests are the interests specifically described above. They do not automatically override your interests or rights. Contact us for more information about an assessment or to object.
If we rely on consent, it is optional, specific and can be withdrawn at any time by emailing info@propertrades.com, replying with an opt-out request to a promotional message, or using any relevant choice control presented with the activity. Withdrawal does not affect processing already lawfully performed. We will not make unrelated marketing consent a condition of free or Premium membership.
Whether information is required
We will identify mandatory fields at collection. Without information genuinely needed to administer requested access or verify disclosed Premium conditions, we may be unable to provide that access. Without optional analytics or marketing consent, those activities remain disabled and your membership is unaffected.
If you decline a necessary broker-status check, Premium eligibility may not be verifiable. We will explain what data is needed and offer an alternative verification method where reasonably available. We do not require unnecessary detailed trading or financial information merely because a broker can supply it.
Who receives information
We disclose personal data only for a stated lawful purpose and subject to appropriate safeguards:
- Authorised personnel and service providers: staff and providers of hosting, technical support, email delivery, databases and access administration, to the extent needed for their role. Processors act under appropriate contractual instructions; a provider may separately act as a controller for some of its own purposes.
- Telegram: Telegram operates its own platform and processes platform data under its own arrangements. We process information accessible to us as channel or group administrators, and any data collected by our own bots. Telegram should not automatically be described as our processor for every activity.
- Referral brokers: a broker may receive attribution information when you follow its referral link and may exchange the minimum agreed status information with us. Each broker's exact entity, data fields, purpose and role must be disclosed. A broker ordinarily acts independently for account opening, identity checks and trading. If a particular activity involves joint control, we will explain the allocation of responsibilities and make the required essence of the arrangement available.
- Professional advisers: legal, accounting and other advisers where necessary and subject to confidentiality.
- Authorities and other lawful recipients: where disclosure is required by law, a valid legal process, or necessary and lawful to protect rights or investigate serious misuse.
- A successor business: if a genuine business transfer occurs, limited necessary information may be disclosed subject to lawful safeguards, due diligence and appropriate notice. Information must not be repurposed incompatibly merely because ownership changes.
The intended referral partners are PU Prime for eligible EU-based applicants and Exness for eligible applicants elsewhere. This is a brand-level description; the exact receiving legal entity must be identified for each referral. CPA eligibility checks may indicate whether a referred account has made the qualifying deposit and undertaken qualifying trading. We should receive the minimum status information needed, rather than detailed transaction histories, wherever feasible. Email correspondence is principally through info@propertrades.com and service delivery through Telegram.
Identified platforms and referral counterparties
The Website is hosted on Vercel. Vercel supplies hosting infrastructure and may handle request and security information needed to serve the site. Its published privacy information is available at https://vercel.com/legal/privacy-notice. Hosting a site does not imply that every Vercel analytics product is enabled.
Telegram supplies the messaging platform used for our channels and communications. Telegram describes its platform entities, processing and international arrangements at https://telegram.org/privacy. Its independent platform activity is separate from our administration of a channel, messages and membership records.
Our identified affiliate counterparties are PU Prime Ltd in Mauritius and Exness (SC) Ltd in Seychelles. They operate independently for their broker services and provide partner reporting to us. PU Prime reports can contain account identifiers, names, campaign sources, deposits, withdrawals and trading/rebate information; Exness reports can contain client identifiers, country, attribution, platform, qualification/KYC-status and commission information. Information available to us through these reports is personal data even if we do not download it. We limit our use to the disclosed eligibility, accounting, fraud-prevention and dispute purposes. A client’s actual broker entity may differ; consult the agreement and privacy notice supplied during that broker’s onboarding. PU Prime’s legal documents are available at https://www.puprime.com/legal-documentation/ and Exness privacy information through https://www.exness.com/privacy-policy/.
Email delivery and storage necessarily involve the service operating the mailbox used for correspondence. The email address alone does not establish the identity of that provider. You may request recipient information relevant to your correspondence at info@propertrades.com. We will identify any additional membership database, email automation, bot or marketing provider through a supplementary notice before introducing a materially different data use. This Policy does not describe a payment processor as part of the current free-membership service.
Affiliate commissions compensate us for referrals. They are not a payment for unrestricted access to our membership lists or correspondence. A referral can nevertheless disclose personal information and tracking identifiers, as explained above; the commercial relationship does not remove applicable disclosure, consent or other privacy duties.
Telegram visibility and external links
Visibility differs between broadcast channels, discussion groups and direct messages. Depending on Telegram's features and your settings, information you post in a discussion group may be visible to other members, forwarded or copied. A public channel post can have a broader audience. Before posting, check who can see it and avoid sharing sensitive account or personal details.
We cannot erase copies others lawfully or unlawfully retain outside our systems. That limitation does not excuse our own duties to handle information lawfully. Review Telegram's privacy settings and policy. Following a broker or other external link takes you to a separate service with its own privacy notice.
International transfers
Information may be processed outside your country through the actual recipients identified above. When GDPR transfer rules apply, a transfer outside the EEA requires an applicable lawful mechanism, such as an adequacy decision covering the recipient or properly implemented standard contractual clauses with the required assessment and supplementary measures. UK transfers require the appropriate UK mechanism where applicable.
The identified broker counterparties are in Mauritius and Seychelles. Vercel and Telegram describe international infrastructure in their own notices. Those notices do not establish which contractual transfer mechanism has been implemented for every Proper Trades data flow. We must establish the appropriate mechanism before making a restricted transfer; this Policy does not assert that a particular adequacy certification or set of contractual clauses has been verified. For a particular transfer, contact us for the recipient, relevant destinations and applicable safeguard information. No routine transfer may rely on a generic agreement to this Policy.
Contact info@propertrades.com for information about safeguards. Copies may be appropriately redacted to protect confidential information without obscuring the substance of the protection. Any exceptional transfer based on a derogation must meet its legal conditions; generic acceptance of this Policy is not transfer consent.
Retention
We retain identifiable information only as long as needed for its stated purpose and lawful obligations. We then delete it or make it genuinely anonymous. Pseudonymisation alone does not make data anonymous.
We use the following purpose-based retention criteria rather than a single period for every category:
- Membership and access: retain the information needed while access remains active. After closure, keep only what is needed to finish administration, respect opt-outs or address an identifiable outstanding complaint or claim.
- Referral verification and commissions: retain information until qualification, broker reconciliation and any applicable reversal or attribution dispute are resolved. Retain the minimum accounting evidence for any further period required by applicable accounting or tax law; detailed broker reports are not retained indefinitely merely because they were available.
- Routine correspondence: retain while the inquiry is being handled and for the time reasonably needed to complete follow-up. Where correspondence becomes evidence for a complaint or claim, apply the separate criteria for that matter.
- Acceptance, complaints and claims: retain the relevant agreement version, acceptance evidence and necessary correspondence while rights or a concrete dispute can reasonably require proof, taking account of the applicable limitation period and any actual legal hold.
- Technical and security information: retain only for the operational or security purpose for which it is recorded. A record relevant to a specific incident may be kept until investigation and necessary remediation or proceedings conclude.
- Optional tracking and consent: apply the duration disclosed when the technology or campaign is introduced. Retain limited consent evidence for the period necessary to demonstrate compliance; withdrawal ends future consent-based activity without automatically deleting evidence of past lawful processing.
- Marketing preferences: retain the minimum suppression information needed to avoid contacting someone who has opted out. Do not retain a marketing profile solely because a suppression entry is needed.
- Backups: deleted information may remain until the applicable backup is overwritten or expires. It must not be returned to ordinary use; a restoration must preserve the deletion or restriction request. Provider-managed retention outside our control is addressed under that provider’s independent obligations.
Where a fixed period cannot reasonably be stated, we use criteria including whether the purpose continues, the sensitivity of the data, applicable recordkeeping duties, a specific dispute and the relevant legal limitation period. Legal holds are limited to relevant records and periodically reviewed. We do not retain all data indefinitely because litigation is theoretically possible.
Security and breaches
We are responsible for appropriate technical and organisational safeguards, taking account of the nature of the data and the risks of unauthorised access, loss or disclosure. Information must be available only to authorised people with a relevant need. This notice does not certify a particular encryption-at-rest system, independent security audit or technical control that has not been established. Do not send passwords, card details or identity documents through ordinary email or a public Telegram discussion. If a particular verification requires sensitive material, we will first explain a suitable method and the reason for collection.
No system is completely secure. If a personal-data breach occurs, we will assess it, take appropriate containment steps and notify the competent authority and affected people where and within the times required by applicable law. This statement does not limit our security duties or liability.
Your rights
Where GDPR applies, and subject to its conditions and lawful exceptions, you may:
- Request access to your personal data and information about its processing.
- Ask for inaccurate information to be corrected and incomplete information completed.
- Request erasure or restriction of processing in the circumstances provided by law.
- Receive data you provided in a structured, commonly used, machine-readable format, and request transfer to another controller where portability applies to consent- or contract-based automated processing.
- Object to processing based on legitimate interests on grounds relating to your situation. We will stop unless a legally sufficient overriding basis or legal-claims ground applies.
- Object at any time to direct marketing, including related profiling. We will stop that marketing processing.
- Withdraw consent without affecting the lawfulness of processing before withdrawal.
- Benefit from protections relating to solely automated decisions with legal or similarly significant effects where applicable.
Send requests to info@propertrades.com. We may request proportionate verification if there is reasonable doubt about identity; we will not routinely require unnecessary identification documents. Exercising rights is normally free. Where GDPR permits a charge or refusal for a manifestly unfounded or excessive request, we will explain the reasons and complaint options.
Under GDPR, we respond without undue delay and normally within one month of receipt. A permitted extension of up to two further months for complexity or number of requests will be explained within the initial month. Different mandatory local deadlines prevail where applicable.
Some information may need to be retained under a legal obligation or for a necessary legal claim. Where a request cannot be met fully, we will explain the lawful limitation. Leaving Telegram alone is not a request to erase every record held by us.
Automated decisions and profiling
Broker qualification and commission reports may contain statuses generated by the broker’s systems. Receiving a status does not mean that Proper Trades determines the broker’s account-opening or trading decisions. If an access decision is based on an inaccurate status, contact info@propertrades.com to request correction and review by the operator. We will provide a supplementary explanation before introducing automated processing that requires additional disclosure or safeguards; this notice does not claim that every broker decision is made manually.
If simple automated checks administer access, we will explain their inputs and offer a route to resolve inaccurate data. If we undertake solely automated decision-making producing legal or similarly significant effects, we will separately disclose meaningful information about the logic, significance and likely consequences, identify a lawful basis and provide the safeguards required by law, including human intervention and challenge rights where applicable.
Children
The Service is intended for adults aged at least 18 and any higher age required locally. We do not intentionally admit children. If you believe a child has supplied personal data, contact us so we can investigate, restrict inappropriate access and erase information where required, subject to justified legal retention.
Updates
We will revise the date when this Policy changes and provide an appropriate notice of material changes on the Website and, where necessary to reach affected members, through our Telegram channels or direct email. If a new purpose requires further notice, a compatibility assessment or fresh consent, we will complete that step before the new processing begins.
Continuing to use the Service does not constitute consent to new processing. Previously supplied information will not automatically be used for a materially different purpose merely because this Policy has been updated.