Privacy Policy

1.1 Raen Trading Inc., operating as Trader Development Desk ("Trader Development Desk", "we", "us", "our") is a Delaware C Corporation with its principal place of business at 1200 S Rogers Cir Suite 11, Boca Raton, FL 33487, USA. We are the data controller responsible for your personal data collected through this website and our assessment programme.

1.2 We operate a proprietary trading desk and run a two-phase assessment programme through which we identify and select traders for potential placement on the desk. This Privacy Policy explains how we collect, use, store, and share personal data in connection with that programme and the use of our platform.

1.3 Questions about this policy should be directed to support@developtraders.com.

2.1 Registration and Account Data. When you create an account or register for the assessment programme, we collect: your full name; email address; country of residence; date of birth (for age verification); and any other information you provide during registration.

2.2 Payment Data. When you purchase a subscription, we collect payment information including: billing name and address; card type and last four digits; and transaction reference numbers. Full payment card details are processed directly by our payment processor and are not stored by Trader Development Desk.

2.3 Assessment and Trading Activity Data. During your participation in Phase 1 and Phase 2, we collect data relating to your simulated trading activity including: trade records; performance metrics; risk and drawdown data; and assessment progress and outcomes. We collect and use your trading data solely to evaluate your trading and assess your suitability for live capital backing. We do not sell your trading data or use it for any other purpose.

2.4 Communications Data. We collect the content of communications you send to us, including: support requests; formal complaints; emails; and any messages sent via the Platform. Where you participate in mentorship sessions or group sessions on the Trader Development Desk Virtual Trading Floor, session content may be recorded or logged for quality and compliance purposes. You will be informed if sessions are recorded.

2.5 Usage and Technical Data. We automatically collect certain technical data when you use the Platform, including: IP address; browser type and version; device type and operating system; pages visited and time spent; referring URLs; and log data. This is collected through cookies and similar technologies as described in Section 9.

2.6 Identity Verification Data. We may collect identity verification documents (such as a government-issued ID or passport) where required for AML/KYC compliance purposes. Such documents are processed in accordance with applicable regulatory requirements.

2.7 Data You Provide Voluntarily. You may provide additional information to us voluntarily, such as in support tickets, survey responses, or feedback. We collect and use such data as described in this policy.

We use your personal data for the following purposes:

Creating and managing your account

— Performance of a contract (Terms of Participation)

Processing subscription payments and managing billing

— Performance of a contract

Operating and administering the assessment programme (Phase 1 and Phase 2)

— Performance of a contract

Providing access to the Trader Development Desk Virtual Trading Floor and Desk Resources

— Performance of a contract

Communicating with you about your account, assessment progress, and support queries

— Performance of a contract / Legitimate interests

Sending service-related notifications (account updates, policy changes)

— Performance of a contract / Legitimate interests

Sending marketing communications about Trader Development Desk's programme and services (where you have opted in)

— Consent

Conducting AML, KYC, and fraud prevention checks

— Legal obligation / Legitimate interests

Complying with applicable laws and regulations (including CFTC Rule 4.41, NFA and SEC rules)

— Legal obligation

Monitoring and investigating breaches of our Terms of Participation

— Legitimate interests

Improving our platform, services, and assessment processes

— Legitimate interests

Responding to legal claims and enforcing our legal rights

— Legitimate interests / Legal obligation

4.1 We do not sell your personal data. We may share your data with the following categories of third parties, strictly for the purposes set out in this policy:

• Payment processors: We use third-party payment processors (currently Stripe) to process subscription payments. Your payment data is subject to their privacy policies.
• Trading Technologies (TT): We use TT Pro / TT Desktop to operate the simulated trading environment. Your trading activity data is shared with and processed by TT in connection with the provision of their platform. TT's use of your data is governed by TT's own privacy policy.
• Email and communications service providers: We use third-party providers to send transactional and marketing emails. These providers process your email address and communications data on our behalf.
• Virtual office platform providers: Phase 2 participants access the Trader Development Desk Virtual Trading Floor through a third-party virtual office platform. Your identity and participation data is shared with the relevant platform provider as necessary to give you access.
• Professional advisers: We may share data with lawyers, accountants, and compliance advisers where necessary to obtain professional advice or to manage legal proceedings.
• Regulatory and law enforcement authorities: We may disclose your data to regulators, law enforcement bodies, or courts where required by applicable law, regulation, or legal process, including CFTC, NFA, or SEC requirements.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of our business, your data may be transferred to the relevant third party as part of that transaction. We will notify you in advance where required by law.

4.2 All third-party service providers who process personal data on our behalf are required to process such data only in accordance with our instructions and to maintain appropriate security measures.

5.1 Trader Development Desk is based in the United States. If you access the Platform from outside the United States, your personal data will be transferred to and processed in the United States. By using the Platform, you consent to this transfer.

5.2 If you are based in the United Kingdom or European Economic Area, we will ensure that any transfer of your personal data to a country that is not subject to an adequacy decision is protected by appropriate safeguards, such as standard contractual clauses approved by the relevant supervisory authority.

5.3 For UK users, transfers are made in accordance with the UK GDPR and the Data Protection Act 2018. You may contact us at support@developtraders.com for further information about the safeguards in place.

6.1 We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, and compliance obligations. The following retention periods apply:

Account and registration data

— Duration of participation + 7 years from account closure

Payment records and billing data

— 7 years from the date of transaction (for tax and accounting purposes)

Assessment and trading activity data

— 5 years from last active participation

Communications and support records

— 3 years from the date of the communication

Identity verification documents (AML/KYC)

— 5 years from the end of the business relationship, or as required by applicable law

Marketing preferences and consent records

— Until consent is withdrawn + 2 years

6.2 Where we are required by law to retain data for longer periods, we will comply with those requirements. Where data is no longer required, we will securely delete or anonymise it.

7.1 We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include: encryption of data in transit and at rest; access controls limiting data access to authorised personnel only; regular security reviews; and secure data storage with reputable cloud infrastructure providers.

7.2 Whilst we take data security seriously, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your data. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and any applicable supervisory authority as required by law.

7.3 You are responsible for keeping your account credentials confidential. You must not share your username or password with any third party. Please notify us immediately at support@developtraders.com if you suspect any unauthorised access to your account.

8.1 The Platform and assessment programme are not directed at or intended for use by individuals under the age of 18. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us at support@developtraders.com and we will delete such data promptly.

9.1 We use cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you visit the Platform.

9.2 We use the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function. These cannot be disabled without affecting your ability to use the Platform.
• Performance and analytics cookies: Help us understand how visitors interact with the Platform, including which pages are visited most often. We use this data in aggregate, anonymised form.
• Functional cookies: Allow the Platform to remember your preferences and settings.
• Marketing cookies and advertising trackers: With your consent, we may use cookies, pixels and similar technologies solely to measure the effectiveness of advertising in relation to interest in, and purchases of, our assessments or services. We do not use advertising trackers for any other purpose.

9.3 When you first visit the Platform, you will be presented with a cookie consent banner. You can manage your cookie preferences at any time through the Platform settings or your browser settings. Withdrawing consent for non-essential cookies will not affect the lawfulness of processing based on consent before withdrawal.

9.4 For more information about the specific cookies we use, please contact us at support@developtraders.com.

10.1 We may send you marketing communications about Trader Development Desk's assessment programme, services, and updates where you have given us consent to do so, or where we have a legitimate interest in contacting you as an existing participant and you have not opted out.

10.2 We use platforms to manage and send marketing and transactional emails. Your email address and engagement data (such as open and click rates) are processed by the platform on our behalf.

10.3 You can opt out of marketing communications at any time by clicking the unsubscribe link in any marketing email or by contacting us at support@developtraders.com. Opting out of marketing communications will not affect transactional communications relating to your account or participation in the programme.

11.1 Depending on where you are located, you may have the following rights in relation to your personal data:

• Right of access: You can request a copy of the personal data we hold about you.
• Right to rectification: You can ask us to correct inaccurate or incomplete data.
• Right to erasure: You can ask us to delete your personal data in certain circumstances, such as where the data is no longer necessary for the purpose for which it was collected.
• Right to restriction: You can ask us to restrict our processing of your data in certain circumstances.
• Right to data portability: You can request that we provide your data in a structured, machine-readable format for transfer to another controller, where technically feasible.
• Right to object: You can object to our processing of your data where we rely on legitimate interests as the legal basis, including for direct marketing.
• Right to withdraw consent: Where we process data on the basis of your consent, you can withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.

11.2 To exercise any of these rights, please contact us at support@developtraders.com with the subject line "Privacy Request" and include your full name, email address, and a description of your request. We will respond within 30 days. We may need to verify your identity before processing your request.

11.3 If you are located in the United Kingdom or European Economic Area, you have the right to lodge a complaint with the relevant supervisory authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk. In the EEA, it is the supervisory authority in your country of residence.

11.4 California residents: Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have additional rights, including the right to know, delete, and opt out of the sale or sharing of personal information. We do not sell or share personal information as defined under the CCPA/CPRA. To submit a request, contact us at support@developtraders.com.

12.1 The Platform may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party sites. We are not responsible for the privacy practices of third parties and encourage you to review their privacy policies before providing any personal data.

13.1 We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or the Services. We will notify you of material changes by email or by posting a notice on the Platform before the changes take effect. The updated policy will indicate the date it was last revised.

13.2 Your continued use of the Platform after any changes take effect constitutes your acceptance of the updated Privacy Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact us:

Raen Trading Inc., operating as Trader Development Desk 1200 S Rogers Cir, Suite 11 Boca Raton, FL 33487 United States support@developtraders.com

We will endeavour to respond to all privacy-related enquiries within 30 days.