Privacy Policy

Effective Date: 12 February 2025
Last Updated: 12 February 2025

Welcome to Commercial Traders Portal (the “CTP App”). This Privacy Policy explains how Commerial Traders Portal (“we,” “us,” or “our”) collect, use, disclose, and safeguard your information when you use the App. By using the App, you agree to the collection and use of your information in accordance with this Privacy Policy.

If you do not agree with the terms of this Privacy Policy, please do not use the App.

1. Scope of This Policy & Legal Compliance

We are committed to complying with:

• United States Laws: This includes relevant federal laws (e.g., FTC regulations, Children’s Online Privacy Protection Act) and applicable state privacy laws such as the California Consumer Privacy Act (CCPA), if and where applicable.
• South African Laws: Particularly the Protection of Personal Information Act, 2013 (“POPIA”), and any other applicable regulations or statutes.

This Privacy Policy outlines how we collect, use, protect, and disclose personal information in compliance with these legal frameworks.

2. Information We Collect

2.1 Personal Information

We may collect personal information that you provide directly to us, such as:

• Contact Information: Name, email address, phone number
• Account Credentials: Username, password
• Other Information: Details you provide when you contact support or submit feedback

2.2 Non-Personal Information

We may also collect non-personal information, such as:

• Device Information: Hardware model, operating system, unique device identifiers
• Usage Data: App features used, pages visited, time and date of access
• Log Files: IP addresses, browser type, clickstream data

We may use cookies, web beacons, and similar tracking technologies to collect non-personal information. You can choose to disable cookies in your browser settings; however, this may affect certain functionalities of the App.

3. How We Use Your Information

We use the information we collect for purposes including, but not limited to:

1. Providing and Maintaining the App: To create and manage your account, offer customer support, and process transactions.
2. Improving User Experience: To analyze usage patterns and enhance the App’s features, personalize content, and tailor user experiences.
3. Communications: To send you important updates or administrative messages (e.g., changes to policies, security alerts), and to respond to your inquiries.
4. Marketing and Promotions (if applicable): To send promotional materials or offers about our products or services. You can opt out of marketing communications at any time.
5. Legal Compliance: To comply with U.S. and South African laws and regulations, and to respond to lawful requests by public authorities.

4. Legal Bases for Processing (Under POPIA and U.S. Laws)

We may process your personal information under various legal bases, including:

• Your Consent (where required by law).
• Performance of a Contract (e.g., providing services you requested).
• Compliance with Legal Obligations (e.g., responding to subpoenas or lawful requests).
• Legitimate Interests, unless overridden by your data-protection interests or fundamental rights and freedoms.

5. Sharing and Disclosure of Information

We may share your personal information in the following circumstances:

1. Service Providers: With trusted third-party vendors that assist us in operating the App or providing services on our behalf. These third parties are only authorized to use your information as necessary to provide services to us.
2. Business Transfers: If we are involved in a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.
3. Legal or Regulatory Requirements: If required by law or if we believe in good faith that disclosure is necessary to protect our rights or respond to lawful requests by public authorities.

6. Your Rights and Choices

6.1 Under South African Law (POPIA)

• Right to Access: You have the right to request copies of your personal information.
• Right to Correction/Deletion: You can ask us to correct or delete personal information that is inaccurate, irrelevant, or no longer necessary.
• Right to Object to Processing: In certain circumstances, you may object to the processing of your personal information.

6.2 Under U.S. Laws (e.g., CCPA where applicable)

• Right to Know: Request disclosure of the categories and specific pieces of personal information we collect.
• Right to Delete: Ask us to delete your personal information, subject to certain exceptions.
• Right to Non-Discrimination: You will not receive discriminatory treatment for exercising your privacy rights.

6.3 How to Exercise These Rights

To exercise any of the above rights, you can contact us using the information provided in the Contact Us section below. We may ask you to verify your identity before responding to such requests.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations under POPIA and applicable U.S. laws, resolve disputes, and enforce our agreements. When your information is no longer required, we will securely delete or anonymize it.

8. Security

We take reasonable measures to protect your information from unauthorized access, theft, or misuse. However, no method of electronic transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

9. Children’s Privacy

The App is not intended for individuals under the age of 18. We do not knowingly collect personal information from children without verifiable parental consent, in accordance with U.S. laws (e.g., COPPA) and relevant South African regulations. If you believe we have collected information from a child without proper consent, please contact us so we can take the necessary steps to delete such information.

10. International Data Transfers

Your information may be transferred to, stored, and processed in countries other than the one in which it was originally collected, including the United States or South Africa, where our servers or central database may be located. By using the App or providing us with any information, you consent to the transfer of your information to these countries in accordance with this Privacy Policy and subject to applicable data protection laws.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make changes, we will revise the “Last Updated” date at the top of this Privacy Policy. Your continued use of the App after any changes indicates your acceptance of the updated Privacy Policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: