COOKIES POLICY AND DISCLOSURE
Original Issue Date:
Approver(s):Owner(s):December 2018
Board of Directors

Contact Person:
Operational Applicability:

TTCM TRADERS CAPITAL LIMITED
Chief Executive Officer
All personnel & Clients

Last Revision Date:

December 2019

Last Reviewed Date:
Next Review Date:
Version:December 2019
December 2022
2

Other Languages:

N/A

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

TABLE OF CONTENTS
SUBJECT

Contents
INTRODUCTION ..................................................................................................................................................................... 3
RIGHT TO PRIVACY ................................................................................................................................................................ 3
WHAT ARE COOKIES? ............................................................................................................................................................ 3
WHAT ARE COOKIES GENERALLY USED FOR? ....................................................................................................................... 4
WHAT ARE THE DIFFERENT TYPES OF COOKIES? .................................................................................................................. 4
LEGAL AND REGULATORY PROVISIONS REGARDING THE USE OF COOKIES ......................................................................... 5
USE OF COOKIES ON THE COMPANY’S WEBSITE(S) .............................................................................................................. 6
CATEGORIES OF COOKIES STORED ON YOUR DEVICE WHEN BROWSING THE COMPANY’S WEBSITES ............................... 6
GOOGLE ANALYTICS .............................................................................................................................................................. 7
USE OF FLASH FILES .............................................................................................................................................................. 7
SOCIAL MEDIA ....................................................................................................................................................................... 7
ADVERTISING ........................................................................................................................................................................ 8
EXAMPLES OF COOKIES USED BY THE COMPANY’S WEBSITES ............................................................................................. 8
HOW TO CONTROL COOKIES ................................................................................................................................................ 8
HOW TO DELETE COOKIES .................................................................................................................................................... 9
USEFUL INFORMATION ABOUT COOKIES ............................................................................................................................. 9
MONITORING AND REVIEW .................................................................................................................................................. 9
CONSENT............................................................................................................................................................................... 9
MISCELLANEOUS ................................................................................................................................................................. 10
APPENDIX A......................................................................................................................................................................... 13

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

COOKIES POLICY AND DISCLOSURE
INTRODUCTION
1.1.

‘TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14
and 6/132C(1) of the Companies Act 1981, registered with the Registrar of Companies underCompany number 54135 and with registered address 5th Floor, Andrew’s Place, 51 Church Street
Hamilton HM 12 Bermuda.

1.2. The Company is operating in accordance with the above mentioned Laws.

RIGHT TO PRIVACY
2.1.

We respect each individual's right to privacy, we value our relationship with you, and we take pride inmaintaining loyalty and respect with each individual client by providing you with privacy and security.

2.2.

The provisions of this Cookies Policy and Disclosure apply to all Websites operated by the Company,(including the client area and all other panels and dashboards available under any of the domains
operated by the Company) and explains how Cookies are placed on your computer, tablet and/or
mobile telephone (a "device") in order to log information.

2.3.

By using the Company’s Website(s) you agree that ‘Cookies’ will be placed on your computer or devicein accordance with the terms of this Cookies Policy and Disclosure. The Company’s Cookies Policy andDisclosure provides users of the Company’s Website(s) with information on which Cookies are set
when you visit the Company’s Website(s) and how to reject or delete those Cookies.

2.4.

Users of the Company’s Website(s) should also be familiar with the Company’s Privacy Policy, in which
this Cookies Policy and Disclosure is incorporated by reference.

2.5.

PLEASE CAREFULLY READ THE COMPANY’S PRIVACY POLICY AND THIS COOKIES POLICY ANDDISCLOSURE BEFORE USING ANY OF OUR WEBSITES.

WHAT ARE COOKIES?
3.1.

Cookies are small text files of information that are stored in the Cookie file of the browser on yourcomputer’s hard disk when you first visit certain pages or perform certain actions on a website, or
when you open certain e-mails. They can include any specific information you have entered into forms
and the time and date of your visit. These Cookies cannot harm your computer or device, areanonymous and unique to the browser. Cookies are used to improve user experience, make thewebsite work, enable Website security and provide the business with marketing information about theWebsite’s visitors.

3.2.

The Cookie text files comprise numbers and letters. The Cookie files are saved into special areas in thememory of your computer or mobile device. Cookies stored here are called ‘session Cookies’ with
Cookiesplaced
into
the
hard
drive
called‘persistent
Cookies’.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

WHAT ARE COOKIES GENERALLY USED FOR?
4.1.

Websites mainly use Cookies to:••

identify users;
remember users' custom preferences;•help users complete tasks without having to re‑enter information when browsing fromone page to another or when visiting the Website(s) later.

4.2.

Cookies can also be used for online behavioral target advertising and to show adverts relevant tosomething that the user searched for in the past.

WHAT ARE THE DIFFERENT TYPES OF COOKIES?
5.1.

5.2.

5.3.

A Cookie can be classified by its lifespan and the domain to which it belongs. By lifespan, a Cookie iseither:•A ‘session Cookie’, which is erased when the user closes the browser; these are temporary
Cookies stored in your computer’s memory only during your browsing sections. They areautomatically deleted from your computer when the browser is closed and can also become nolonger accessible after the session has not been active for a specified length of time; or•A ‘persistent Cookie’, which remains on the user's computer/device for a pre-defined period oftime; these are Cookies that are stored on your equipment between browsing sessions and are
not deleted when the browser is closed. In contrast to session Cookies, permanent Cookies canretain your preferences for a specific website, allowing those preferences to be used in yourfuture browsing sessions.

As for the domain to which a Cookie belongs, there are either:•‘first-party Cookies’, which are set by the web server of the visited page and share the same
domain;•‘third-party Cookies’ stored by a different domain to the visited page's domain; these are Cookies
that belong to domains, different from the one shown the address bar. The web pages on thatdomain may feature content from a third-party domain (banners, adverts). This can happen
when the webpage references a file, such as JavaScript, located outside its domain. Third-party
Cookies are often allowed by a Web browser; however, they can be blocked if you wish to do so.

In addition to session Cookies, permanent, first-party and third-party Cookies, there may be otherCookies which are set by our Websites, in order to provide us or third-parties with important
information. A description of such other Cookies is provided further in this Cookies Policy andDisclosure.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

LEGAL AND REGULATORY PROVISIONS REGARDING THE USE OF
COOKIES
6.1.

All of the Company’s Websites must follow the guidelines on privacy and data protection set out in the
Personal Data Protection Legislation, which requires prior informed consent for storage of/or access to
information stored on the terminal equipment (computer, tablet and/or mobile telephone) of any userof the Company’s Website(s) and imposes an obligation on the Company to ask users of its Website(s)if they agree to most Cookies and similar technologies (e.g. web beacons, Flash Cookies, etc.) before
its Website(s) start(s) to use them and to inform them that Cookies are not being used to gather
information unnecessarily.

6.2.

For such consent of the users of the Company’s Website(s) regarding the use of Cookies to be valid, it
must be informed, specific, freely given and must constitute a real indication of the individual's wishes.

6.3.

However, some Cookies are exempt from this requirement. Consent is not required if the Cookie is:

6.4.

•

used for the sole purpose of carrying out the transmission of a communication; and•strictly necessary in order for the provider of an information society service explicitly requiredby the user to provide that service.

Cookies that are clearly exempt from consent according to the EU Advisory Body on Data Protection(Opinion 04/2012 on Cookie Consent Exemption, adopted on 7 June 2012) include the following:•‘user‑input Cookies’ (session-id) such as first‑party Cookies to keep track of the user's input
when filling online forms, shopping carts, etc., for the duration of a session or persistent Cookies
limited to a few hours in some cases;•‘authentication Cookies’, to identify the user once he has logged in, for the duration of a session;•‘user‑centric security Cookies’, used to detect authentication abuses, for a limited persistent
duration;•‘multimedia content player Cookies’, used to store technical data to play back video or audio
content, for the duration of a session;•‘load‑balancing Cookies’, for the duration of session;•‘user‑interface customisation Cookies’ such as language or font preferences, for the durationof a session (or slightly longer);•‘third‑party social plug‑in content‑sharing Cookies’, for logged‑in members of a social network.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

USE OF COOKIES ON THE COMPANY’S WEBSITE(S)7.1.

The Company’s Website(s) use(s) Cookies to provide the functionality you need to browse ourWebsite(s) correctly. We use Cookies to enable you to improve your user experience when using our
Website(s). The use of Cookies helps us maintain security and verify your details, which enables you to
avoid re-entering your details each time you visit our Website(s). Cookies do not only help us
recognise and remember you as a unique user when you return to our Website(s), but they also collectanonymous information for evaluation purposes to help us improve the structure of our website.

7.2.

The Company’s Website(s) issue Cookies upon landing on our Website(s), unless the user has changed
Cookie settings in their browser to refuse Cookies. Please note that with Cookies switched off, someareas of our Website(s) and services may not be available to you and that you may not be able to login
with Cookies disabled. The Company supports social bookmarking and with Cookies disabled thisfunctionality may not be available.

7.3.

Other than as expressly disclosed in this Cookies Policy and Disclosure, the Company does not use
Cookies to collect personally identifiable information about you; other than as expressly disclosed inthis Cookies Policy and Disclosure, the Cookies we use only collect anonymous information to optimise
our services and do not collect personal information.

7.4.

Please note, however, that not all the Cookies on our Website(s) are set by us. Please see the Section
above on ‘third party Cookies’.

CATEGORIES OF COOKIES STORED ON YOUR DEVICE WHENBROWSING THE COMPANY’S WEBSITES
8.1.

The categories of Cookies stored on your device when browsing the Company’s Website(s) include thefollowing:•

Essential Cookies: These Cookies are essential for the operation of our Website(s) (such asfeatures and accessing secure areas of the Website9s)). Without these Cookies, certain options
on our Website(s) may not be available. The essential Cookies are vital for us to use for thequality of our services to you.

•

Performance Cookies: We utilise Cookies to analyse how our visitors use our websites and also
to monitor website performance. These Cookies do not collect any information that identifies
our visitors, but it is collected anonymously.

•

Functionality Cookies/ Traffic Log Cookies: We use functionality/traffic log Cookies to identify
which pages are being used and to allow us to remember your preferences and to provide
enhanced or more personal features. These Cookies remember choices you make to improveyour experience. This helps us analyse data about web page traffic and improve our website inorder to tailor it to customer needs. We only use this information for statistical analysis
purposes and then the data is removed from the system. We use this information tounderstand, for example, the effectiveness of our advertising and marketing.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

•Behavioural advertising Cookies (third party): We and third party advertisers use Cookies toserve you with advertisements that we believe are relevant to you and your interests. They also
limit the number of times you see an advertisement and they help measure the effectiveness ofan advertising campaign. These Cookies are used by targeted advertisings services to collectinformation about your browser habits and to deliver advertisements more relevant to you. We
may also use such Cookies to track campaigns from banner advertisements and opt-in emails.
We may use third-party providers to help us determine which of our advertisements are most
likely to be of interest to you. These providers may use behavioural information, such as how
you navigate the internet, to provide relevant advertisements to you. We may also allow someof these companies to use tracking pixels. Tracking pixels may be used to collect and store
information about visits to our Website(s), such as which pages you viewed and how long you
spent on our Website(s), as well as the specific advertisement that you clicked to visit our
Website(s). No personally identifiable information is stored on these Cookies or web pixels. The
information reported to us is aggregated and anonymous. Where applicable, you can opt out ofthese behavioural advertising Cookies and continue your browsing on our Website(s).

GOOGLE ANALYTICS
9.1.

We use Google Analytics that uses Cookies to count the numbers of visitors and their consumer
behaviour. In this way, we can tailor the content of our website to correspond to your interests andpreferences. The information generated by the Cookies is stored by Google and it is later used by it toevaluate the use of our website, and to conduct reports on the activity of the website or the internet.

9.2.

To opt out of being tracked by Google Analytics please visit http://tools.google.com/dlpage/gaoptout.

USE OF FLASH FILES
10.1. We make use of flash files, which present information, allow integration with 3rd parties (such as
YouTube) and can offer a richer online experience.
10.2. Currently technology is limited in its ability to review the 'inner workings' of flash files. We have strived
to identify any flash elements that are likely to set Cookies but, at this point in time, we cannot
guarantee the status of every flash file.
10.3. Adobe offers a tool to monitor, opt out and remove 'flash Cookies' - for more information visit
http://www.adobe.com/.

SOCIAL MEDIA
11.1. Social media can place Cookies through our Website(s) to integrate social media (i.e. LinkedIn, Twitter,
Google+ and Facebook). You agree to place these Cookies on your device by clicking on the social
media buttons to activate them.
11.2. These social media have their own privacy and Cookie policies, which the Company does not control.
11.3. Please check the social media websites for more information about their Cookies and how to manage
them.
TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

ADVERTISING
12.1. The Company’s Website(s) use(s) the advertising services of Google AdWords. Google AdWords canplace Cookies on your device to serve ads based on your prior visits to the Company’s Website(s).
12.2. More information on the use of Cookies by Google AdWords can be found on the Google websites.
12.3. You may refuse the use of Cookies by selecting the appropriate settings on your browser. Please note that
if you do so, you may not be able to use the full functionality of the Company’s Website(s) features.

EXAMPLES OF COOKIES USED BY THE COMPANY’S WEBSITES
13.1. The details about the Cookies that are used on our Website(s) are set out in Appendix A hereto.
13.2. To ensure that you are fully informed of all the Cookies we are using on our Website(s), you can audit
the Cookies used on our website(s) and automatically generate Cookie information by installing the
Cookieaudit
tool
providedby‘AttacatResources’atthefollowing
URL:
http://www.attacat.co.uk/resources/Cookies; It’s free and no registration is required.

HOW TO CONTROL COOKIES
14.1. Many browsers are set to accept Cookies; however, you can prevent new Cookies from being installed
on your computer. If you wish to disable or block Cookies, you can do it through changing yourinternet software browsing settings, or you can either choose specific website that you will accept
Cookies from. You can configure your browser setting to inform you each time a new Cookie is about
to be stored on your computer, giving you the chance to decide if you want to accept or reject it.
14.2. All recent versions of popular browsers give users a level of control over Cookies. Users can set theirbrowsers to accept or reject all, or certain, Cookies. Users can also set their browser to prompt themeach time a Cookie is offered. For details, see: www.aboutCookies.org.
14.3. You can also control Adobe Local Shared Objects on your computer, also known as LSOs or Flash
Cookies, but not with your browser. Instead, Adobe's website offers tools to control Flash Cookies on
your computer. For details, see: http://www.macromedia.com/support/documentation/
en/flashplayer/help/settings_manager07.html.
14.4. Users of the Firefox browser can also get an add-on to detect and delete Flash Cookies. For details,
see: https://addons.mozilla.org/en-US/firefox/addon/betterprivacy/.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

HOW TO DELETE COOKIES
15.1. You can control and/or delete Cookies as you wish. You can delete all Cookies that are already on yourcomputer and you can set most browsers to prevent them from being placed. If you do this, however,
you may have to manually adjust some preferences every time you visit our Website(s) and some
services and functionalities may not work.
15.2. Most Cookies are easy to delete. Just pick your browser from the choices below and follow the
instructions. For details, see: www.aboutCookies.org.
15.3. You probably have Adobe Local Shared Objects on your computer, also known as LSOs or Flash
Cookies. Generally, you can't delete them with browsers controls, but Adobe's website offers tools tocontrol Flash Cookies on your computer. For details, see: http://www.macromedia.com/
support/documentation/en/flashplayer/help/settings_manager07.html.
15.4. Users of the Firefox browser can also get an add-on to detect and delete Flash Cookies. For details,
see: https://addons.mozilla.org/en-US/firefox/addon/betterprivacy/
15.5. We recommend you that you leave Cookies enabled, as they allow you to access some of our website’s
essential features. If you wish to disable Cookies, please be aware that the functionality of yourexperience will be reduced.

USEFUL INFORMATION ABOUT COOKIES
16.1. Further information about Cookies can be found on the following websites:▪

www.youronlinechoices.com▪

www.allaboutCookies.org

MONITORING AND REVIEW
17.1. We will monitor on a regular basis the effectiveness of this Cookies Policy and Disclosure and, inparticular, the execution quality of the procedures explained in the Policy and, where appropriate, we
reserve the right to correct any deficiencies.
17.2. We will inform our clients of any material change to this Cookies Policy and Disclosure by posting an
updated version of this Cookies Policy and Disclosure on our Website(s).

CONSENT
18.1. By accessing and/or using our Website(s) and/or our services, you are consenting to our placing Cookies on
your computer in accordance with this Cookies Policy and Disclosure. Please read this Cookies Policy andDisclosure carefully for more details about the information we collect when you use our Website(s).

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

18.2. If you do not wish to accept Cookies pursuant to this Cookies Policy and Disclosure in connection withyour use of our Website(s), you must stop using our Website(s).

MISCELLANEOUS
19.1. We reserve the right to review and/or amend this Cookies Policy and Disclosure, at our sole discretion,
whenever we deem fit or appropriate.
19.2. The Board of Directors will review and approve/ratify this Cookies Policy and Disclosure at least
annually.
19.3. Should you have a question about our Cookies Policy and Disclosure, please direct your questions to
our Compliance Department: compliance@traders-trust.com.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

APPENDIX A(DETAILS ABOUT THE COOKIES THAT ARE USED ON OUR WEBSITE(S))
PERFORMANCE COOKIES
These cookies allow us to count visits and traffic sources so we can measure and improve the performanceof our site. They help us to know which pages are the most and least popular and see how visitors movearound the site.
We use Google Analytics to provide this service, which uses 5 first party cookies. The data collected is notshared with any other party.
The information obtained with these cookies anonymized and we make no attempt to use it identify
individual visitors, or influence your experience of the site while you are visiting it. If you do not allow thesecookies, we will not be able to include your visit in our statistics.
If you have used a ‘Do Not Track browser setting’, we take this as a sign that you do not want to allow thesecookies, and they will be blocked.
•
•
•
•
•

__utma__utmc__utmz__utmt__utmbSYSTEM COOKIES
These cookies are used by our website to store anonymous session and login tokens. They may identify
you as a single user when you move between pages, but carry no personally identifiable information andare destroyed when you close your browser, unless you actively choose to be remembered for easier login
on your next visit.
••__RequestVerificationToken_SessionId

FUCTIONALITY COOKIES
These cookies are used by our LiveChat software to store temporary user information to improved user
experience in our website, but are destroyed when you close your browser.
•

Liveagent

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.

TARGETING COOKIES
These cookies collect information about your browsing habits to make advertising relevant to you andyour interests. These cookies collect the most information about users.
CookieName

PurposePersistent/Session

Demandware

dwpersonalization_xxxxx

Can be used for A/B testing

31 days

Demandware

country_data

Stores locale

Persistent

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of
the Companies Act 1981 and registered with the Registrar of Companies under Company number 54135.