PRIVACY POLICY

We at realcommoditytrading.com are committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the personal data we collect from users of our Website (the “Platform”).

We provide a platform which lets the users to create profile, view the website and trade commodities. (“Services”).

By using the Services, users consent to the collection and use of their Personal Data by us. You also represent to us that you have any and all authorizations necessary to use these Services including using them to process Personal Data. We collect and use the information you provide to us, including information obtained from your use of the Services. Also, we may use the information that we collect for our internal purposes to develop, tune, enhance, provide and improve our Services, and for advertising and marketing consistent with this Privacy Policy.

This privacy policy has been compiled to better serve those who are concerned with how their 'Personal Data’ is being used online. Personal data means data which relate to a living individual who can be identified – (a) from those data, or (b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

Please read our privacy policy carefully to get a clear understanding of how our Platformcollects, uses, protects or otherwise handles users’ Personal Data.

This Privacy Policy is intended to inform users about how our Platformtreats Personal Data that it processes about users. If users do not agree to any part of this Privacy Policy, then we cannot provide its Services to users and users should stop accessing our services.

By using the Services, You acknowledge, consent and agree that we may collect, process, and use the information that you provide to us and that such information shall only be used by us or third parties acting under our direction, pursuant to confidentiality agreements, to develop, tune, enhance, and improve the Services.

Although we may attempt to notify you when changes are made to this Privacy Policy, you are responsible for periodically reviewing any changes which may be made to the Policy. We may, in our sole discretion, modify or revise the Policy at any time, and you agree to be bound by such modifications or revisions.

1. INFORMATION WE COLLECT:

• 1.1. When you register with us, you provide us information about yourself – your full name email address, mobile number and password. If you correspond with us by e-mail, we may retain the content of your e-mail messages, your e-mail address, and our responses. We also collect general information about your use of our services such as documents like POP, POF etc. provided by the member and shall be securely stored offline. We also collect your location details when you book the services to be delivered at a certain location.
• 1.2. By using our site, you acknowledge and agree that you may be transferring your personal data outside of the country in which you have contributed it (“your country”), and that you consent to any transfer of information outside of your country. These countries may not have similar data protection laws to those that apply in your country. However, if we transfer your personal data outside of your country in this way, we will take steps to try to ensure that your privacy rights are protected in compliance with applicable data protection law and this Privacy Policy.

2. INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE OUR SERVICES:

• 2.1. When you access or use our Services, we automatically collect information about you, including:
• 2.1.1. Device Information: We may collect information about the device you use to access our Services, including the hardware model, operating system and version, unique device identifier, phone number, International Mobile Equipment Identity ("IMEI") and mobile network information.
• 2.1.2. Geo-location Information- Upon using the site, you will be asked to turn on location services. If you turn these features on, we may collect your device's geo-location data and save your device's coordinates to offer certain features to you. We may also use your device's geo-location information to personalize the site. You can control your location information settings in your Account settings and switch them off if you want to. Even if you have disabled location services, we may still determine your general location based on your IP address (but not your exact location).
• 2.1.3. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to you. Accepting a cookie does not provide us access to your device or any Personal Data about you, other than the information you choose to share. Other servers cannot read them, nor can they be used to deliver a virus. Most browsers automatically accept cookies, but you can usually adjust yours (Microsoft Internet Explorer, Firefox or Google Chrome) to notify you of cookie placement requests, refuse certain cookies, or decline cookies completely.
• 2.1.4. “Web beacons” or clear .gifs are small pieces of code placed on a Web page to monitor behavior and collect data about the visitors viewing a Web page. For example, Web beacons or similar technology can be used to count the users who visit aPlatformor to deliver a cookie to the browser of a visitor viewing that page. We may use Web beacons or similar technology on our Services from time to time for this and other purposes.
• 2.1.5.We gather certain information automatically and store it in log files. This information includes internet protocol addresses as well as browser, internet service provider, referring/exit pages, search terms, operating system, date/time stamp, and click stream data. Occasionally, we may connect Personal Information to information gathered in our log files, as necessary to improve the Service for individual customers. Otherwise, we generally use this information as we would any Usage Data, to analyze trends, administer and maintain the Service, or track usage of various features within the Service.

3. HOW WE USE YOUR INFORMATION:

• 3.1. We use the personal information we collect to fulfill your requests for services, improve our services and contact you.
• 3.2. By providing us your e-mail address, you consent to us using the e-mail address to send you our Platform and services related notices, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send notifications of activity on our Platformto the e-mail address you give us, in accordance with any applicable privacy settings. We may use your e-mail address to send you other messages, such as newsletters, changes to our features, or other information. If you do not want to receive optional e-mail messages, you may modify your settings to opt out.
• 3.3. Our settings may also allow you to adjust your communications preferences. If you do not wish to receive promotional email messages from us, you may opt out by following the unsubscribe instructions in those emails. If you opt out, you will still receive non-promotional emails from us about your account and our Services.
• 3.4. Following termination or deactivation of your services, we may (but are under no obligation to) retain your information for archival purposes. We will not publicly disclose any of your personal data other than as described in this Privacy Policy.
• 3.5. At our sole discretion, for any reason or no reason at all, we reserve the right to remove any content or messages, if we believe that such action is necessary (a) to conform to the law, comply with legal process served on us, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce this policy, to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our Platform; or (c) to exercise or protect the rights, property, or personal safety of the Platform, our users, or others.
• 3.6. To send other messages that help us provide our services on the Site;
• 3.7. By deactivating your account, you can permanently delete all data, for which you, or we, cannot gain access again
• 3.8. In-House Promotions: We may on occasion combine information we receive through our Services with outside records to enhance our ability to market our products and services that may be of interest to you. If you have signed up to receive our e-mails and prefer not to receive marketing information in connection with our Services, please follow the “unsubscribe” instructions provided on any marketing e-mail you receive in connection with our Services or by following the instructions in our Email Opt Out Form, as described below under “Unsubscribe Requests”.
• 3.9. Business Transfers: As our businesses continue to evolve, we might sell one or more of our companies, subsidiaries or business units. In such transactions, personally identifiable information generally is one of the transferred business assets. In such event, this Privacy Policy may be amended as set forth below or the collection and uses of your personally identifiable information may be governed by a different privacy policy.
• 3.10. Protection of Our Services and Others: We reserve the right to release personally identifiable information to unaffiliated third parties when we believe its release is appropriate to comply with the law, enforce or apply our Terms and Conditions and other agreements, or protect the rights, property or safety of us, our users or others. This includes exchanging information with other unaffiliated third parties in connection with fraud protection and credit risk reduction.
• 3.11. With Your Consent: Other than as set out above, you will receive notice and have the opportunity to withhold consent when personally identifiable information about you might be shared with unaffiliated third parties.
• 3.12. We may transmit the user data across the various platforms of the Company.
• 3.13. User Submissions: If you participate in any online forum/communities, chat sessions and/or blogs, or otherwise post in any user comment field visible to other users of our Services, any information that you submit or post will be visible to and may be read, collected or used by others who use our Services. We are not responsible for any information, including personally identifiable information, you choose to submit in any such user comment field.

4.INFORMATION SHARED DURING TRANSACTION

• 4.1. You agree that you will enter into transactions with third parties through our site and will share your Personal Information with them for easy completion of the transaction. You hereby expressly agree that we shall not be involved or held liable for any breach of the privacy or security of that data. The said breach, if any, shall be a matter of dispute between you and the third party and we shall not be held liable or be issued a notice for the same.
• 4.2. We STRONGLY recommend that you should be careful and vigilant while disclosing your Personal Information with your transaction partner. Please do not disclose your bank and account details to anyone through our site or to any individual whom you have met through our site.
• 4.3. We do not take credit card/debit card or other bank details on our site. For payment you will be directed to sign in through the respective payment gateways integrated on our site and the transaction would be completed therein. It is to be noted that we will not be storing any Bank related information on our records and none of our staffs will hold or be exposed to this information.

5.HOW WE SHARE YOUR INFORMATION:

• 5.1. As a matter of policy, we will not sell or rent information about you and we will not disclose information about you in a manner inconsistent with this Privacy Policy except as required by law or government regulation. We cooperate with law enforcement inquiries, as well as other third parties, to enforce laws such as those regarding intellectual property rights, fraud and other personal rights.
• 5.2. We will not share the personal information we collect about you with any third party for their own marketing purposes without your consent. We have contract with third parties prohibiting them from sharing your personal data.
• 5.3. We collate statistics about site traffic, sales and other commercial information which we pass onto third parties to assist us with improving the services we provide to you. We also use demographic information to tailor the Site and we share that information with third parties so that they can build up a better picture of our customer base and general consumer trends.
• 5.4. If you do not agree with our Privacy Policy, Terms of Service or Cookie Policy, please discontinue use of our Service; your continued usage of the Service will signify your assent to and acceptance of our Privacy Policy and Terms of Use.
• 5.5. WE CAN (AND YOU AUTHORIZE US TO) DISCLOSE ANY INFORMATION ABOUT YOU TO LAW ENFORCEMENT, OTHER GOVERNMENT OFFICIALS, ANY LAWSUIT OR ANY OTHER THIRD PARTY THAT WE, IN OUR SOLE DISCRETION, BELIEVE NECESSARY OR APPROPRIATE IN CONNECTION WITH AN INVESTIGATION OF FRAUD, INTELLECTUAL PROPERTY INFRINGEMENT, OR OTHER ACTIVITY THAT IS ILLEGAL OR MAY EXPOSE US, OR YOU, TO LIABILITY.

6.ENSURING INFORMATION IS ACCURATE AND UP-TO-DATE

• 6.1. We take reasonable precautions to ensure that the Personal Data we Collect, Use and Disclose is complete, relevant and up-to-date. However, the accuracy of that information depends to a large extent on the information you provide. That's why we recommend that you:
• 6.2. Let us know if there are any errors in your Personal Data; and
• 6.3. Keep us up-to-date with changes to your Personal Data such as your name or address.

7.RIGHT TO ACCESS SPECIFIC INFORMATION AND DATA PORTABILITY RIGHT

• 7.1. You may have the right under the CCPA (California Consumer Privacy Act, 2018) to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
  • i. The categories of Personal Information that we have collected about you.
  • ii. The categories of sources for the Personal Information that we have collected about you.
  • iii. Our business or commercial purpose for collecting or making available that Personal Information.
  • iv. The categories of third parties with whom we share that Personal Information.
  • v.The specific pieces of Personal Information that we have collected about you (also called a data portability request).
  • vi. If we disclosed your Personal Information for a Business Purpose, the Business Purpose for which such Personal Information was disclosed, and the Personal Information categories that each category of recipient obtained.
  • vii. If applicable, (1) the categories of your Personal Information that we have made available for valuable consideration; (2) the categories of third parties to whom such Personal Information was made available; and (3) the category or categories of Personal Information that we have made available to each category of third parties.
• 7.2. Right to Delete
  • i.You may have the right under the CCPA to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
  • ii.We may deny your deletion request if retaining the information is necessary for us or our service provider(s) or vendor(s) to:
    • a. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • b. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • c.Debug products to identify and repair errors that impair existing intended functionality.
  • iii.Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • iv.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • v.Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • vi.Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • vii.Comply with a legal obligation or legal order.
  • viii.Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• 7.3.Right to Opt-Out
  • i.If you are 16 years of age or older, you may have the right under the CCPA to direct us not to make your Personal Information available for valuable consideration at any time (the “right to opt-out”). We do not make available the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in may opt-out at any time.
  • ii. To exercise the right to opt-out or right to opt-in, you (or your authorized representative) may submit a request to us by sending us an e-mail at webmaster@realcommoditytrading.com . Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize certain information sharing practices. However, you may change your mind and opt back in at any time by sending us an e-mail webmaster@realcommoditytrading.com. We will only use Personal Information provided in an opt-out request to review and comply with the request.
• 7.4.Exercising Your Rights
  • i. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
    • Sending us an e-mail at webmaster@realcommoditytrading.com.
  • ii. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
  • iii. You may only make such a request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • iv. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
  • v. We will respond to verifiable requests received from California residents as required by law. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
  • vi. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request
• 7.5.Non-Discrimination
  • i. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
    • a. Deny you goods or services.
    • b. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • c. Provide you a different level or quality of goods or services.
    • d. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  • ii. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

8.HOW WE PROTECT YOUR INFORMATION:

• 8.1. We are very concerned about safeguarding the confidentiality of your personal data. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access.
• 8.2. By using this Platformor the Services or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this Platformor Services.
• 8.3. We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Information. We cannot, however, ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps.
• 8.4. Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property. However, nothing in this Policy is intended to limit any legal defenses or objections that you may have to a third party, including a government’s, request to disclose your information.

9.YOUR CHOICES ABOUT YOUR INFORMATION:

• 9.1.You have several choices regarding use of information on our Services:
  • 9.1.1.Email Communications: We will periodically send you free newsletters and e- mails that directly promote the use of our Platform, or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly. Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
  • 9.1.2.Changing or Deleting Your Personal Data: You may change any of your personal information by visiting the Platformand following the directions therein or by emailing us webmaster@realcommoditytrading.com. You may request deletion of your personal data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.
• 9.2. You may, of course, decline to submit personal data through the Platform, in which case, we may not be able to provide our services to you. You can review and correct the information about you that we keep on file by editing your account settings or by contacting us directly at webmaster@realcommoditytrading.com .

10.CHILDREN’S PRIVACY:

Protecting the privacy of young children is especially important. Thus, we do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register. If you are under 18, please do not attempt to register for the Service or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 may provide any personal data for accessing the Service. In the event that we learn that we have collected personal data from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

11.MERGER AND ACQUISITIONS:

In case of a merger or acquisition, we reserve the right to transfer all the information, including personal data, stored with us to the new entity or company thus formed. Any change in thePlatform’s policies and standing will be notified to you through email.

12.LINKS TO THIRD PARTY PLATFORMS:

Our Platform contains links to other websites and Platforms. The fact that we provide links to websites and Platform is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party Applications and Platforms. These other Applications and Platforms may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other Applications and Platforms you visit.

13.NOTIFICATION PROCEDURES:

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via e-mail notice, written or hard copy notice, or through conspicuous posting of such notice on the Platform, as determined by us in our sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

14.STORING PERSONAL DATA:

We retain your information only for as long as is necessary for the purposes for which we process the information as set out in this policy. However, we may retain your Personal Data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

15.STORING PERSONAL DATA:

• 15.1.Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform Platformand services that they do not want certain information about their webpage visits collected over time and across Platformor online services.
• 15.2. We are committed to providing you with meaningful choices about the information collected on our Platformfor third party purposes, and that is why we provide the opt-out links. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

16. OPTING OUT OF INFORMATION SHARING:

• 16.1.We understand and respect that not all users may want to allow us to share their information. If you do not want us to share your information, please contact us through the Platformand we will remove your information as soon as reasonably practicable. When contacting us, please clearly state your request, including your name, mailing address, email address and phone number.
• 16.2. However, under the following circumstances, we may still be required to share your personal information:
  • a if we are responding to court orders or legal process, or if we need to establish or exercise our legal rights or defend against legal claims.
  • b If we believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use or as otherwise required by law.
  • c If we believe it is necessary to restrict or inhibit any user from using any of our site, including, without limitation, by means of "hacking" or defacing any portion thereof.

17. PHISHING OR FALSE EMAILS:

If you receive an unsolicited email that appears to be from us or one of our members that requests personal data (such as your credit card, login, or password), or that asks you to verify or confirm your account or other personal information by clicking on a link, or to provide your personal information to any other user that email was likely to have been sent by someone trying to unlawfully obtain your information, sometimes referred to as a "phisher" or "spoofer." We do not ask for this type of information in an email. Do not provide the information or click on the link. Please contact us on the contact details provided on the Platformif you get an email like this.

18. CHANGES TO OUR PRIVACY POLICY:

• 18.1.We may update this Privacy Policy and information security procedures from time to time. If these privacy and/or information security procedures materially change at any time in the future, we will post the new changes conspicuously on the Platformto notify you and provide you with the ability to opt out in accordance with the provisions set forth above.
• 18.2. Continued use of our Platform and Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

19. BREACH OF PRIVACY POLICY:

We reserve the right to terminate or suspend any account or delete certain contents from any profile or public domain within the ambit of this Platformif the said account or content is found to be in violation of our privacy policy. We sincerely request you to respect privacy and secrecy concerns of others. The jurisdiction of any breach or dispute shall be determined in accordance with the terms of use of the Platform.

20. NO RESERVATIONS:

We do not accept any reservation or any type of limited acceptance of our privacy policy. You expressly agree to each and every term and condition as stipulated in this policy without any exception whatsoever.

21. NO CONFLICT:

The policy constitutes a part of the user terms. We have taken utmost care to avoid any inconsistency or conflict of this policy with any other terms, agreements or guidelines available on our Platform. In case there exists a conflict, we request you to kindly contact us for the final provision and interpretation.

22. CONTACT US:

If you have any questions about this Privacy Policy, our practices relating to the Platform, or your dealings with us, please contact us at webmaster@realcommoditytrading.com.