Privacy Policy: Butter

Privacy Policy

This policy has been prepared in English and where it is translated into other languages, such translation(s) are for convenience only. In the event of any conflict, discrepancy or ambiguity between the English version and any translated version, the English version shall prevail.

Effective Date: September 8th, 2023

Summary of how we use your data

  • We respect your privacy and are committed to protecting it as described in this policy.
  • We use your personal data to provide, improve and administer the Butter product(s), to enter into and perform the terms of service with our users, and to comply with legal and regulatory requirements.
  • Data is shared with our vendors and partners, and when we have a good faith belief that doing so is necessary to comply with legal and regulatory enquiries or requirements.
  • Our privacy policy sets out more details of this processing, including information in relation to your data protection options, and your right to object to certain processing.

What does this policy cover?

This policy describes how Antidilutive Limited and its affiliates (referred to as “Butter”, the “Butter Group”, “we”, or “us” in this policy) will collect, make use of, and share (i.e. “process”) your personal data in connection with the Butter website, apps and services (including API services). For the purposes of this policy, the term “affiliate” shall mean any entity, individual, firm, or corporation, directly or indirectly, through one or more intermediaries, controlling, controlled by, or under common control with Antidilutive Limited.

This policy also describes data protection rights you may have (depending on applicable law), such as a right to object to some of the processing which the Butter Group carries out. More information about your rights, and how to exercise them, is set out in the “Your rights” section.

What personal data do we process?

We process personal data about you when you interact with us, our websites, our applications or our services (including API services). This may include:

  • your name, email address, username, password, and other login and/or security details (e.g. application passcode or other identifier, two-factor authentication token seed record, public PGP key), and login records;
  • payment details, including wallet address(es);
  • your account and portfolio details, such as live and historical orders, trades and positions, and balances (including with respect to accounts on third party platforms);
  • your site and account preferences, including alerts and site notification, and sounds and confirmation dialogs;
  • any personal data you submit for verification purposes, and your self-reported location (including browser location and other proof of address information) plus the geolocation of the IP address you connect from;
  • your social media contact details (e.g. telegram) for the purposes of enabling product services;
  • your marketing and other communication preferences, and a record of any consents you have given us;
  • information related to the browser or device you use to access our website or apps, as well as data that tells us which features of the website or app are popular, or suffer from issues we need to fix;
  • the content and details (e.g. date) of messages you post or that you send us (e.g. customer support queries); and
  • customer service notes and other records.

We will aim to mark data fields as optional or mandatory when collecting personal data from you via forms. Note, in particular, that to create an account, engage in transactions, and, where necessary, prove your identity, the provision of personal data is typically mandatory: if relevant data is not provided, then we will not be able to do these things and provide the services you expect.

We do not collect fingerprints, facial recognition data, or other biometrics, other than any photos and/or videos of yourself and/or your identification documents that you may voluntarily submit (for example during an account verification or recovery process and which may be processed by facial recognition software for that purpose). Where you enable biometric security (such as fingerprint or Face ID login), your biometrics will be handled by your device, not by us.

What personal data do we receive from third parties?

We may receive personal data from our payment partners where you use their services to make payments to us. We receive personal data from partners when they refer you to us (for example, we receive data about the service you used, and that referred you). Third parties may monitor the Web on our behalf, for example looking for stolen usernames and passwords. Our communications service provider may also enable us to learn more about your social media presence, in order for us to send you more personalised communications. We receive records of trades and transactions from exchanges and trading platforms that are integrated with our services. Finally, some authorities or other persons seeking access to information about users may provide information about the circumstances of their request, and about the individuals of interest.

How do we use this personal data, and what is the legal basis for this use?

We process this personal data for the following purposes:

  • To fulfil (or take steps linked to) a service agreement with you. This includes:
  • creating your account;
  • verifying your identity;
  • taking payments (and making refunds);
  • allowing you to configure and operate the services, integrate third party platforms, create and monitor trade instructions and information, implement algorithms and execute trading instructions, maintain your account and history, and monitoring positions, in each case in accordance with our policies and terms of service;
  • communicating with you; and
  • providing customer services.
  • As required by the Butter Group or third parties to conduct their business and pursue their other legitimate interests, in particular:
  • to provide services you have requested;
  • to monitor, improve and protect the services we provide (on our own or with others), in particular by looking at how they are used, testing alternatives, and by learning from feedback and comments you provide;
  • to personalise our services and user interfaces;
  • by maintaining and sharing de-identified records of market data, including trading records, for monitoring and research purposes (including by third parties);
  • to monitor customer accounts to prevent, investigate and/or report misconduct such as spam, misrepresentation, security incidents, market manipulation, or crime (such as fraud), in accordance with applicable law, and to cooperate with authorities seeking to do the same;
  • to investigate any complaints received from you or from others;
  • in connection with legal claims, compliance, regulatory, or investigative purposes (including disclosure in connection with legal process or litigation); and
  • to invite individuals to take part in market research and beta tests.
  • Where you give us consent (so far as that consent is required):
  • we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us and carefully selected partners;
  • we place cookies, monitor email engagement, and use other similar technologies in accordance with our cookies policy and the information provided to you when those technologies are used;
  • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
  • For purposes which are required by law, in particular:
  • in response to requests by relevant courts and public authorities, such as those conducting an investigation.

Fully-automated decision-making

Our platform applies certain automatic processes based on your account configuration, requests and input, trading positions and account resources, in accordance with the services that you use. For example, if you have a leveraged position, your position may be automatically affected by your risk parameters, market status, and your collateral value, or you may set up certain automated orders or execution requests that are triggered by certain variable values.

Automated decision-making that uses your personal data may also be employed, to protect accounts and to uphold our terms of service. In particular, if you attempt to access our services from a jurisdiction in respect of which our services are restricted, your account may be automatically restricted.

Relying on our legitimate interests

To the extent required by law, we aim to carry out balancing tests when significant data processing activities are justified on the basis of our “legitimate interests”, as described above.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send or display marketing without your consent. You may have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time, in accordance with applicable law. Where you do have such a right, you can exercise it by following the instructions in the communication where this is an electronic message, changing your account settings, or by contacting us using the details set out below.

Who will we share this data with, and where?

We will share your personal data between Butter Group companies so they can help deliver and improve our services, run our business, and comply with our legal obligations and related third party requests.

Personal data may be shared with third party participants in any affiliate programme (or any other successor or parallel programme of a similar nature) who referred you to our site (so they can track successful referrals), and partners for promotions or service integrations. Information on historical trades may also be shared with other trading platforms, exchanges, and associated trading tool platforms. Personal data may be shared with partners or other users of the service where you elect to replicate, follow, or otherwise be directed by their account, trading, or third party service activity. Personal data may be shared with courts or public authorities if required as described above, mandated by law or regulation, or required for the legal protection of our or third party legitimate interests, in compliance with applicable laws and regulations, and relevant / competent public authorities’ requests.

Personal data will also be accessed by employees or contractors, or shared with third party service providers, who will process it on our behalf for the purposes identified above. In particular, we use third party website and database hosting; web and app analytics; account verification; and customer services and support.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s advisers, and to the new owners of the business.

Your rights

Depending on applicable law, you may have the right to ask us for a copy of personal data about you; to correct or delete that personal data; restrict the processing of that personal data; and to obtain a copy of personal data about you that you provided to us (in connection with our agreement with you, or with your consent), in a structured, machine readable format, and to ask us to port this data to (i.e. share that data with) another organisation.

In addition, applicable law may provide the right to object to the processing of personal data about you, in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

You have the right to appeal the result of significant fully automated decisions. This should be done by emailing us within 3 working days from the date of the decision, which we will then review.

If these rights apply, they may however be limited, for example if fulfilling your request would reveal personal data about another person, would infringe the rights of another person or legal entity (including our rights), or if you ask us to delete or change data which we are required by law to keep (or have other compelling legitimate interests in keeping). We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch using the details set out below. If you have unresolved concerns, you typically have the right to complain to regulators, depending on applicable law.

How long does the Butter Group retain data?

Where we process personal data in connection with performing an agreement with you, we keep the data for 6 years from your last interaction with us.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of that request indefinitely, so that we can continue to respect your request in future.

Where we process personal data for site security purposes, we retain it for 3 years.

Longer retention periods may apply, such as where ongoing access to records continues to be important to our defence of legal claims or where we are required by law or regulation to retain information for specific periods.

Cookies and related technologies

We use cookies (and local storage objects, but we refer to these collectively as “cookies” in this policy), web beacons/tags, and other related approaches to collect information about your use of our website. Cookies are small pieces of information sent by a web server to a web browser, to allow certain functionality or analytics. In particular, we use the following:

  • Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the website and use its features.

Without these cookies, things you have asked for such as remembering your login details, alert details or trade details cannot be provided.

We also use these cookies to balance traffic over multiple servers, so we can keep it responsive and capable of dealing with high traffic from all users.

  • Performance Cookies

These cookies collect information on how people use our website. For example, we use these to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, trading, customer support, and marketing.

  • Functionality Cookies

These cookies remember choices you make such as the country you visit from, and language and search parameters. These can then be used to provide you with an experience more appropriate to your selections.

  • Targeting cookies or advertising cookies

These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. These cookies are usually placed by third party advertising networks. They remember the websites you visit, and that information is shared with other parties such as advertisers.

  • Social Media Cookies

These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and X (formerly known as Twitter). Please refer to their respective privacy policies to learn how their cookies work and can be controlled.

  • Web beacons, tags

Some of our web pages, emails, or parts of our apps may contain electronic images, or computer code, that allow us to learn more about how our website and apps are used (just like performance cookies, mentioned above). These “web beacons” and “tags” collect only limited information. In our app, we may use pieces of code provided by third-parties, which also help analyse the data. We may also carry web beacons placed by third party advertisers.

Controlling these technologies

If you want to delete any cookies, please check your browser or device settings (and help pages) for instructions on how to delete them. Your browser or device may also offer tracking controls for things other than cookies, such as beacons and tags.

Please note that by deleting our cookies or disabling future cookies, in particular the “strictly necessary” cookies described above, you may not be able to access certain areas or features of our site.

External links

Although our website and apps only look to include quality, safe and relevant external links, users should always adopt a policy of caution before clicking any links to non-Butter Group websites or apps. We cannot control, guarantee or verify their contents. They will have their own policies and practices, for example with regard to privacy and personal data, and you should acquaint yourselves with those before further engaging with those third party websites or apps.

Changes to this Policy

We may revise this Privacy Policy from time to time. If we make a change to this policy that we consider material, we will take steps to notify users by a notice on the website and/or app. Your continued use of the Butter website, applications and services (including API services) will be subject to the updated Privacy Policy.

Getting in touch with us

If you have any questions or concerns about how we process your data, including if you would like to exercise any rights (e.g. to opt out of direct marketing), you can get in touch with our contact point for privacy queries at [email protected]

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