Privacy Policy

Last Updated: August 27, 2025

Etoile Trade ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your information when you access our Preview Solution (the "Demo"), a demonstration environment for evaluating our software. This policy complies with the UK Data Protection Act 2018 (incorporating GDPR), Australia's Privacy Act 1988 (Australian Privacy Principles, APPs), and similar global data protection laws.

1. Information We Collect

We collect minimal personal information necessary to provide access to the Demo. This may include:

  • Contact Information: Email address provided during login to create a temporary demo account.
  • Usage Data: Non-personal information such as session duration, pages visited, and interactions with the Demo, collected to improve its functionality.
  • Device Information: IP address, browser type, and device identifiers, collected automatically to ensure secure access.

If you do not provide the required information (e.g., email), you may not be able to access the Demo. Under GDPR, the lawful basis for collecting this data is your consent, provided via the login checkbox. Under the APPs, we collect data only as necessary for the Demo's function.

2. How We Use Your Information

We use your information solely for the following purposes:

  • To provide and manage access to the Demo.
  • To analyze usage patterns to improve the Demo's functionality and user experience.
  • To ensure security and prevent unauthorized access.

We do not use your information for marketing, profiling, or any purpose other than operating the Demo, unless you provide explicit consent (e.g., for future contact about our services).

3. Hardcoded Demo Data

All data, figures, and content displayed in the Demo (e.g., dashboards, reports) are fictional, hardcoded, and provided for illustrative purposes only. No personal data is generated, stored, or processed within the Demo's content. You have no ownership or rights to this data.

4. Data Sharing and Disclosure

We do not sell, trade, or share your personal information with third parties, except:

  • With service providers (e.g., hosting providers) who assist in operating the Demo, bound by confidentiality obligations and compliant with GDPR and APPs.
  • As required by law, such as to comply with a subpoena, court order, or request from regulators (e.g., UK Information Commissioner's Office, Australian Office of the Information Commissioner).
  • To protect our rights, property, or safety, or that of others.

5. Data Retention

  • Personal Information: We retain your email and related login data only for the duration of your demo session or as needed to comply with legal obligations (e.g., audit trails). Data is deleted promptly after your session ends or upon your request, unless required by law.
  • Usage/Device Data: Anonymized usage data may be retained for analytical purposes but cannot be linked to you.

6. Your Rights

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

  • UK (GDPR): Right to access, rectify, erase, restrict processing, object to processing, data portability, and withdraw consent. You may also lodge a complaint with the UK Information Commissioner's Office (ICO).
  • Australia (APPs): Right to access, correct, and request deletion of your personal information, and to complain to the Office of the Australian Information Commissioner (OAIC).
  • Other Jurisdictions: Similar rights may apply (e.g., under California's CCPA or Canada's PIPEDA).

To exercise these rights, contact us at [your-contact-email@example.com]. We will respond within 30 days (GDPR) or a reasonable timeframe (APPs, typically 30 days).

7. International Data Transfers

The Demo is hosted in [Your Hosting Location, e.g., UK or Australia]. If you access the Demo from another jurisdiction, your information may be transferred to and processed in [Your Hosting Location]. We ensure appropriate safeguards:

  • UK (GDPR): Transfers outside the UK/EEA comply with Standard Contractual Clauses or other GDPR-approved mechanisms.
  • Australia (APP 8): Cross-border disclosures are made only if the recipient complies with the APPs or equivalent standards, or with your consent.

8. Security

We implement reasonable technical and organizational measures (e.g., encryption, access controls) to protect your information from unauthorized access, loss, or alteration, in line with GDPR and APP requirements. However, no system is completely secure, and you use the Demo at your own risk.

9. Children's Privacy

The Demo is not intended for individuals under 16 (UK) or 18 (Australia). We do not knowingly collect personal information from children. If you believe we have such data, contact us to request deletion.

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated policy on our website with a new "Last Updated" date. Your continued use of the Demo after such changes constitutes acceptance.

11. Contact

For questions, to exercise your rights, or to lodge a complaint, contact us at [your-contact-email@example.com]. For UK users, we are the data controller under GDPR. For Australian users, complaints may also be directed to the OAIC (oaic.gov.au).

By checking the box and accessing the Preview Solution, you confirm that you have read, understood, and agree to this Privacy Policy.