Privacy Policy, Trading House Online

1. Introduction

This Privacy Policy explains how Exclusive Vision L.L.C-FZ, operating as Bills Trading ("Bills Trading", "we", "us", "our") collects, uses, discloses, and protects personal information when you visit bills-trading.com, register for the Trading House Online live event (the "Event"), take part in the Trading House Online Challenge that follows it (the "Challenge") and its live sessions, use our Telegram bot or our groups on messaging apps, interact with our marketing, or communicate with us.

We are based in the Meydan Free Zone, Dubai, United Arab Emirates, and we are responsible for your personal information as described in this Policy (the law calls us the "controller"). As a company established in the United Arab Emirates, our handling of personal information is governed by UAE law, in particular the Personal Data Protection Law (Federal Decree-Law No. 45 of 2021). Where you live in the European Economic Area, the United Kingdom, Canada or Québec, we also give you the rights the privacy laws of those places provide, and this Policy explains them.

We have designated a Privacy Officer responsible for ensuring compliance with applicable privacy laws. Contact information is provided at the end of this Policy. If you do not agree with this Policy, please do not use our Services. Words defined in our Terms of Use mean the same here.

We are not a broker. We organise and promote the Event and the Challenge. We are not a broker: we do not hold your money, run trading accounts or execute trades. People who join the Challenge open a trading account with our partner broker, RaiseFX, operated by Raise Global SA (Pty) Ltd in South Africa and its affiliated companies (the "Broker"), an independent company with its own terms and privacy policy. The Broker is responsible for its platform and services and for the information you give it there. We work with it to run the Challenge.

2. Information We Collect

We collect personal information in three main ways:

2.1 Information You Provide

We collect information you voluntarily provide, including:

Contact information: name, email address, phone number, country.
Challenge registration data: the details the Broker needs to open your trading account (name, email address, phone number, date of birth, street address, postal code, city and country).
Account information: username, preferences.
Transaction information: purchase history and billing details, if you buy something from us (payment card details are processed by our payment processors; we do not store full card numbers).
Communications: messages you send us (email, chat, SMS, Telegram, WhatsApp, social media), support requests, feedback.
Registration and participation data: event registrations, your answers to our short questions after you register (for example how much time and money you have for trading), draw entries, including free entries.
Telegram data: your Telegram user ID, username and display name when you use our bot or join our groups, and your phone number if you share it with the bot.
User content you choose to share: testimonials, video answers, comments or other submissions (content you submit for publication may become public).
Consent records and marketing preferences: what you accepted and when, your cookie choice, and your opt-ins and opt-outs.

You must give the Challenge registration data to join the Challenge; without it the Broker cannot open your account. Everything else is optional unless we say otherwise.

2.2 Information Collected Automatically

When you use our website, our bot or our groups, we may automatically collect:

Device information: IP address, browser type, operating system, browser language, device identifiers.
Usage data: pages visited, links clicked, time spent, referring URLs, the campaign parameters (UTM) in the link you clicked, and the steps you complete in our bot.
Location data: general geographic location based on IP address.
Cookie and pixel data: online identifiers and browsing activity collected through cookies and similar technologies.

2.3 Information from Third Parties

We may receive information from social media platforms (when you interact with us there), advertising and analytics partners and payment processors.

If you join the Challenge, the Broker sends us an identifier for your account and tells us whether you already had an account with it and whether your account is linked to the Challenge. Once you agree on the Broker's platform to share your activity with the Challenge, it also sends us:

About your account: your first name, country, account status, your first deposit (amount, currency and date) and the status of your identity and address checks.
About your trading: your closed trades (instrument, buy or sell, size, result and time), and your balance and equity over time.

The Broker never sends us your last name, your password, your identity documents or your payment details. If you ask the Broker to stop sharing, it stops sending us new information.

3. How We Use Your Information

We only collect and use your information when we have a valid reason to do so, such as to fulfill a contract with you, comply with legal obligations, pursue legitimate business interests, or with your consent. Specifically, we use your information to:

Deliver the Event: send you the confirmation, the access link and reminders.
Open your trading account: when you join the Challenge, send your Challenge registration data to the Broker.
Run the Challenge: check eligibility, tell you your next registration step, compute scores and the leaderboard, run draws, choose and announce winners, deliver prizes, and detect cheating.
Provide products and services: provide access, offer support, manage accounts.
Communicate with you: answer your questions, send service messages and important updates, and use your answers to our short questions to decide how we follow up with you. Some answers in our bot are written automatically by software, and a member of our team may also reply to you through the bot.
Send marketing: news about the Challenge and our future events, if you asked for it or where the law allows it, always with a way to stop.
Process payments and prevent fraud: billing, verification, security.
Improve our website and services: analytics, testing, performance monitoring.
Run advertising and measure results: measure and show our ads, including sending scrambled (hashed) email addresses and phone numbers to Meta from our website through its Conversions API, together with whether your answers to our short questions show the Event is a good fit for you, with your consent where the law requires it. We never send Meta or any advertising platform your deposit, verification or trading information.
Show your results and image: show your first name, country and score on the leaderboard and your result in winner announcements, and use recordings in which you appear.
Meet legal obligations: tax, accounting, keeping records of your consent, answering lawful requests, enforcing our terms.

If you are in the European Economic Area or the United Kingdom, our legal bases are:

Contract: delivering the Event, opening your trading account and running the Challenge.
Consent: marketing where the law requires consent, non-essential cookies, sending Meta your visit, your registration and whether your answers to our short questions show the Event is a good fit for you, and using your image, voice, name or results in our marketing.
Legitimate interests: security and fraud prevention, improving our Services, checking the commissions the Broker owes us, defending legal claims, marketing to registrants where the law allows it, and showing first names on the leaderboard and in winner announcements.
Legal obligations: tax, accounting and lawful requests.

You can object at any time to our use of your information based on legitimate interests, including direct marketing and showing your name on the leaderboard.

4. Cookies and Tracking Technologies

This section is our cookie policy. We use cookies, pixels, and similar technologies to keep the website working, remember preferences, understand traffic and performance, measure advertising, and (where enabled) show relevant ads. These may be first-party (set by us) or third-party (set by service providers).

4.1 Types of Cookies

Essential cookies: required for basic site functionality (security, navigation) and to remember your cookie choice. These cannot be disabled.
Analytics cookies: help us understand how visitors use our site.
Functional cookies: remember your preferences and settings.
Marketing cookies: measure and show our ads. This includes the Meta pixel (the _fbp and _fbc cookies, kept up to 90 days), which reports page views and registrations to Meta, and a first-party identifier that links your visit to your registration and remembers the campaign that brought you. If we advertise on Google, YouTube or TikTok, their tags may also be present.

Where the law requires it, including for visitors in the European Economic Area, the United Kingdom and Québec, we ask for your consent before we load any non-essential cookie or tag or send Conversions API events. You can change your choice at any time through the Cookie settings link at the bottom of every page.

4.3 Third-Party Technologies

We may use third-party analytics and advertising tools that place their own cookies on your device. These third parties have their own privacy policies governing their use of your information.

4.4 Your Choices

You can control cookies through your browser settings (block, delete, or limit cookies), device settings, or industry opt-out tools for interest-based advertising. You can also limit Meta's use of your data in your Meta ad preferences. Blocking cookies may affect site functionality.

Do Not Track: our site does not currently respond to "Do Not Track" browser signals.

5. Email and Messaging Communications

We send marketing messages by email, SMS or messaging apps only if you asked for them or where the law allows it without consent. We never use pre-ticked boxes. We follow the electronic marketing rules where you live, including Canada's Anti-Spam Legislation (CASL), the UK Privacy and Electronic Communications Regulations and the EU ePrivacy rules. We identify ourselves in every message and provide a clear way to unsubscribe.

5.2 SMS and Messaging Apps

If you give us your mobile number or contact us on Telegram or WhatsApp, we use it to send you messages about the Event or the Challenge: confirmations, reminders, updates and, where allowed, promotional content.

Important: we do not sell, share, or disclose mobile phone numbers, messaging opt-in data, or consent records to third parties for their marketing or promotional purposes. The one exception is the Broker: when you join the Challenge, it receives your phone number and may call you about opening and funding your account.

5.3 Opting Out

You can unsubscribe from marketing emails with the "unsubscribe" link in any email. To stop SMS messages, reply STOP. To stop WhatsApp messages, block us. To stop our Telegram bot, send it /stop or block us. You can leave any of our groups at any time. You may also contact us directly. After opting out, we may still send messages needed to deliver what you requested, such as access links or messages about a registration you already started.

6. Disclosure of Your Information

We do not sell your personal information. We may share your information with:

The Broker: your Challenge registration data, when you join the Challenge, so it can open your account. The Broker then uses it under its own privacy policy, including to contact you about your account by phone, email or chat.
Service providers: companies that build, host and run our website, database, bot, messaging, CRM, analytics, advertising, support, prize delivery and travel on our instructions. They only access the information they need and must protect it.
Telegram: Telegram (Telegram Messenger Inc.) runs the platform for our bot and groups under its own privacy policy. Messages you send our bot are stored by Telegram and are not end-to-end encrypted.
Meta Platforms: advertising measurement and delivery through the Meta pixel and Conversions API, and WhatsApp messaging. Meta and we share responsibility for collecting this data and sending it to Meta (the law calls us joint controllers); Meta alone is responsible for what it does with it afterwards.
The public and other members: your first name, country, score and points appear on the leaderboard, or a nickname if you ask us for one. When you win, we announce your first name, country and result, unless you object; we stop displaying it once you do. Where the law requires it, we also publish or provide on request the surname and region of prize winners. Other group members see your Telegram name and, in the private Challenge group, that you joined the Challenge. Whatever you post in our groups or live sessions may appear on screen.
Business transfers: if we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.
Legal requirements: when required by law, court order, or government request, or to protect our rights, safety, or property.
With your consent: for any other purpose with your explicit agreement.

7. Where Your Information Is Handled

Our service providers host our website and our database for us in the European Union and the United States, and people working for us access it from the European Union, Canada and the United Arab Emirates. Our website, our registration page and our bot are delivered by a content delivery network whose servers and short-lived cache are distributed worldwide, so your request may be handled by a server close to you. The Broker handles your account in South Africa and in the other places its own privacy policy describes. Your information may therefore be handled outside your country, where the law may be different. When we send information about people in Europe or the United Kingdom to a country without equivalent protection, we use the standard contracts approved by the European Commission and the United Kingdom, or another safeguard the law allows, and you can ask us for a copy. Before we send information about people in Québec outside Québec, we check that it will be properly protected.

8. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements:

Contact information and registrations: until 24 months pass without any interaction with us. Conversations with our bot and with our support team: 3 months after the Event. If you unsubscribe, we keep only what we need to stop messaging you.
Challenge data (registration details, Telegram data, information from the Broker, scores and draw entries): until 12 months after the Challenge ends. Your date of birth, street address, postal code and city are deleted once your account is open, or within 30 days if it cannot be opened.
Recordings and content you submit: as long as we use them. If you ask us to stop using your image, voice, name or results, we stop new uses and remove them from the marketing we control.
Prize, transaction and accounting records: for the period required by tax and accounting laws (typically 5 to 7 years).
Consent records: up to 3 years after we last rely on them.
Analytics data: typically retained in anonymized or aggregated form.

When no longer needed, we securely delete or anonymize your information.

9. Data Security

We implement reasonable technical and organizational measures to protect your information, including encryption, access controls, and secure data storage. However, no method of transmission or storage is 100% secure.

If a breach creates a legal notification duty, we will notify affected individuals and regulators as required.

10. Your Rights

Depending on your location, you may have the following rights regarding your personal information:

Access: request a copy of the personal information we hold about you.
Correction: request correction of inaccurate or incomplete information.
Deletion: request deletion of your personal information, subject to legal exceptions.
Restriction: ask us to limit how we use your information in some cases, for example while we check a request.
Portability: request a copy of your data in a structured, commonly used electronic format.
Withdraw consent: withdraw consent at any time, for example to stop marketing or the use of your image, voice, name or results. This does not affect what we did before.
Object: object to certain uses, and at any time to direct marketing.
Automated decisions: our systems compute scores automatically and may refuse Challenge registrations from people under 18, from countries where the Challenge is not open, or from people who already have an account with the Broker. A person confirms every prize and disqualification, and you may ask for a person to review an eligibility refusal, a disqualification or a prize decision.
De-indexation: if your personal information is publicly available through our Services and causes you harm or is no longer necessary, you may request its removal or de-indexation.
Complaint: lodge a complaint with a supervisory authority.

To exercise these rights, contact our Privacy Officer using the information below. We will respond within the timeframes required by applicable law (typically 30 days, or one month in Europe and the United Kingdom). We may verify your identity before processing your request. For information the Broker holds, including asking it to stop sharing with us, contact the Broker; we will help you if you ask.

10.1 European and United Kingdom Residents

If you are located in the European Economic Area, the United Kingdom or Switzerland, you have rights under the GDPR, the UK GDPR or Swiss law. You may contact our representative in the European Union or the United Kingdom, and lodge a complaint with your local data protection authority.

10.2 United Arab Emirates Residents

If you are located in the United Arab Emirates, you have rights under the Personal Data Protection Law (Federal Decree-Law No. 45 of 2021). Where UAE law applies, we rely on your consent or on the performance of the contract with you, and you may object to direct marketing at any time.

11. Children's Privacy

Our services are intended for adults aged 18 or older. We do not knowingly collect personal information from anyone under 18. If we learn that we have, we delete it promptly and remove that person from the Challenge. If you believe we have information about a child, please contact us.

12. Third-Party Links

Our website, bot and groups may contain links to third-party websites or services. We are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. For important changes, we will tell you before they take effect.

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact our Privacy Officer:

Privacy Officer: [email protected], subject "Privacy"
Company: Exclusive Vision L.L.C-FZ, operating as Bills Trading (Meydan Free Zone licence 2528096.01)
Address: The Meydan Hotel, Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates

14.1 Privacy Complaints

If you are not satisfied with our response, you may file a complaint with the appropriate authority:

United Arab Emirates residents: the UAE Data Office, once it starts taking complaints.
United Kingdom residents: Information Commissioner's Office: www.ico.org.uk
European Economic Area residents: the data protection authority of your country (list at www.edpb.europa.eu).
Québec residents: Commission d'accès à l'information du Québec: www.cai.gouv.qc.ca
Canadian residents: Office of the Privacy Commissioner of Canada: www.priv.gc.ca
Swiss residents: Federal Data Protection and Information Commissioner: www.edoeb.admin.ch