CHASING RETURNS LIMITED PRIVACY POLICY

Thank you for using www.chasingreturns.com (the “Website”). It is the policy of Chasing Returns Limited (the “Company”, “we” or “us”) to comply with the Data Protection Acts, 1988 and 2003. The purpose of this privacy policy is to outline how we deal with any personal data we have access to while you use the Service (as defined below). Here we describe how we collect, use and handle your information when you use the Website and/or any of the services provided to you by the Company (the together, the “Service”).

What & Why

We collect and use the following information to provide, improve and protect our Service:

Account. We collect, and associate with your account, information like your name, email address, phone number, payment information, and physical address / geographical region. As of May 25th 2018, we ask all new users for their preferences relating to contacting them for support, tips and marketing opportunities as per the GDPR framework.

Service. When you use our Service, we store, process and transmit your files (including your personal trading records and other investment information).

Usage. We collect information from and about the devices you use to access the Service. This includes things like IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Service.

Cookies and other technologies. We use technologies like cookies and pixel tags to provide, improve, protect and promote our Service. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Service, and improving the Service based on that information. You can set your browser to not accept cookies, but this may limit your ability to use the Service.

With whom

We may share information as discussed below, but we won't sell it to advertisers or other third parties.

Others working for The Company. The Company may use certain trusted third parties (for example providers of customer support and IT services) to help us provide, improve, protect and promote the Service. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we'll remain responsible for their handling of your information in accordance with our instructions.

Other users. From time to time, in order to promote the Service and for other similar reasons, we may use your information in an aggregated and anonymised way to general publicly available high-level insights.

Other applications. We can also give third parties access to your information and account - for example, via the Company’s APIs. Please note that their use of your information will be governed by their privacy policies and terms.

Law & Compliance. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of the Company or our users; or (d) protect the Company's property rights.

Chasing Returns is working to learn about trader behaviour and how to improve traders. From time to time we will use anonymised aggregate data to analyse traders performance. One such initiative is the measurement of trading success for clients of PlayMaker. We are taking part in Cohort 4 of the FCA’s regulatory Sandbox from 1st July 2018 to 31st December 2018. The regulatory sandbox allows firms to test innovative offerings in a live environment. More information on the FCA’s regulatory sandbox can be found on www.fca.org.uk/firms/regulatory-sandbox/regulatory-sandbox-cohort-4-businesses. We may use your performance information as part of this initiative.

Any published reports will be available on our website.

We'll abide by the following principles when receiving, scrutinising and responding to government requests (including national security requests) for our users' data:

• Be transparent,

• Fight blanket requests,

• Protect all users and

• Provide a trusted service.

How

Security. We are always working to keep your information secure and testing for vulnerabilities. We also continue to work on features to keep your information safe in addition to things like two-factor authentication. We employ industry standard security measures to protect against unauthorised persons unlawfully accessing, processing, altering, destructing or damaging the data as well as to protect against accidental loss. We accept no liability whatsoever with respect to third party service providers.

Data Requests / Retention: To find out what personal data we hold in respect of you or to have your personal data updated, amended or removed from our database, please contact us at support@chasingreturns.com. We'll retain information you store on our Service for as long as we need to do so to provide you the Service. If you unsubscribe from the Service, we will delete such personal data if requested, if not we will retain such data on an anonymised basis. But please note: (1) there might be some latency in deleting this information from our servers and backup storage (please allow 30 days from the date of the request); and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes or enforce our agreements. You can access the details of your personal information by logging in to your account.

Where

Around the world. To provide you with the Service, we may store, process and transmit information in the European Union and locations around the world - including locations outside your country. Information may also be stored locally on the devices you use to access the Service.

Changes

If we are involved in a reorganisation, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event. We may revise this Privacy Policy from time to time, and will post the most current version on the Website. If a revision meaningfully reduces your rights, we will notify you.

Contact

Have questions or concerns about the Company, the Service and privacy? Contact us at support@chasingreturns.com.