Privacy notice
This notice explains what personal data COE holds about you, why we hold it, who sees it and what you can ask us to do with it.
1. Who is responsible for your data
COE is the controller of your personal data. The client agreement you signed says who runs COE.
For anything about your data, contact Hamilton on +44 7539 715331.
2. What we hold
- Your COE account: your name, your email address and when you joined. Your password for this website is stored only as a one-way hash, so we cannot read it.
- Your TradeQuo account: the MT5 login and server, and your MT5 trading password, which is stored encrypted (section 7).
- What your terminal reports: the account holder's name at TradeQuo, the account currency and leverage, its balance, equity and margin, its open positions, and its trade history, including trades you place yourself.
- Records we create: equity readings, daily results, profit-share statements and payments, and a history of what happened to your account.
- Sign-in protection: after a failed sign-in, a one-way hash of the email address and of the IP address used, to slow down password guessing. In the same way, a one-way hash of the IP address (and of the email address or COE account concerned) for each sign-up, account connection and password reset request, so that these cannot be made in bulk.
- Server logs: the IP address, page, time and browser of each request to this website.
- Messages: anything you send us, such as a question or a complaint.
3. Where it comes from
From you, when you join and connect an account. From your MT5 terminal, while it is logged in to TradeQuo on our server. From your browser, when you use this website.
4. Why we use it
| Purpose | Lawful basis |
|---|---|
| Running your account and copying trades to it | Our contract with you |
| Working out and issuing profit-share statements, and recording payments | Our contract with you, and our legal duty to keep accounting records |
| Keeping the service and your account secure | Our legitimate interest in protecting members and the service |
| Answering questions and complaints | Our contract with you, and our legitimate interest in resolving problems |
| Meeting other legal duties | Legal obligation |
We do not use your data for advertising or profiling, and we do not sell it.
6. Data outside your country
Some of the services above may handle data outside the country where you live. Where the law requires safeguards for such a transfer, we rely on them.
7. How we protect it
This website is only reached over an encrypted connection. Your password for this website is stored as a one-way hash. Your MT5 trading password is encrypted the moment you submit it: the website itself cannot read it back, and only the separate part of our server that runs the terminals holds the key.
8. How long we keep it
- Your MT5 trading password: until you disconnect, when we delete it.
- Your terminal's files: when you disconnect we keep an archive of them (its trade export, status reports and logs) with your account records, so that we can answer questions about past statements.
- Account, trade and statement records: while you have a COE account, then for as long as tax and accounting law requires and as long as we need them to deal with a claim. After that we delete them.
- Sign-in protection: up to 15 minutes after a failed sign-in, and up to an hour after a sign-up, account connection or password reset request.
- Server logs: 30 days, then deleted automatically.
- Backups of our database: 14 days on our server, then deleted automatically as newer ones replace them.
9. Your rights
You can ask us for a copy of your data, to correct it, to delete it, to restrict or object to how we use it, and to receive it in a form you can take elsewhere. Some rights have limits: for example, we must keep accounting records even if you ask us to delete them. Contact Hamilton on +44 7539 715331 and we will reply within one month.
If you are unhappy with how we handle your data, you can complain to the data protection regulator. In the UK this is the Information Commissioner's Office (ico.org.uk).
11. Changes to this notice
We update this notice when what we do with your data changes. The date at the top shows the current version.