Privacy Notice

Of The Trading Pit Challenge GmbH

 

October 31, 2025

When you use our services, we process personal data about our customers ("you," "your," or "the customer"). This privacy notice informs you about how your data is processed, in particular (but not exclusively) when you visit our websites, but also when you log in to our client area or dashboard to use our other services (accessible via these areas) or use these areas (hereinafter referred to individually or collectively as "services").

This privacy notice provides information on the following points:

·       Who is responsible for processing your personal data and who can you contact?

·       What information do we collect about you and how do we obtain it?

·       For what purposes do we use your personal data?

·       How do we store your personal data and how is it secured?

·       Who do we share your personal data with?

·       Do we transfer your data to third countries and international organizations?

·       What rights do you have and how can you exercise them?

1.       WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA AND WHO SHOULD YOU CONTACT ?

The Controller responsible for processing your personal data is The Trading Pit Challenge GmbH (hereinafter referred to as "TTP") with its registered office at Heiligkreuz 6, 9490 Vaduz, Liechtenstein (hereinafter referred to as "we," "our," "our company," or "Controller").

If you have any questions or wish to exercise your rights in relation to the processing of your personal data, you can contact The Trading Pit Challenge GmbH at Heiligkreuz 6, 9490 Vaduz, Liechtenstein, or at [email protected] or [email protected].

2.       WHAT DATA DO WE COLLECT ABOUT YOU AND HOW DO WE OBTAIN IT?

In this section, you will find general information about which of your personal data we collect and how we collect it. Detailed information about the purposes for which we process personal data can be found in section 3 of this privacy notice.

Most of the data we collect about you is obtained directly from you in connection with your use of our services. This includes, in particular:

Data that you provide to us yourself, in particular when you register on the website or other services, enter information in your client area, dashboard, or user account, order services, participate in our projects, or when you communicate with us via customer support or social networks.

This includes identification and contact details, in particular your first name, last name, telephone number, email address, postal address, date of birth, username, and password, as well as your business or tax number if you are an entrepreneur, payment data such as bank details, and other data such as records of communication between you and our company or information about any warranty claims.

In addition this includes , data that we collect automatically when you use our services (e.g., when you visit our website). This includes data about your device (e.g., IP address, device type, operating system, browser used, connection provider), Data about the use of the website (e.g., date, time, and duration of the visit, country from which you are visiting the website, amount of data sent in bytes, source/reference from which you accessed the site) data, and data about the use of the services (e.g., login and logout information, your account settings, data related to the fictitious trading transactions, the value of your fictitious capital, your account currency, trading strategy).

Some data about you is provided to us by third parties, e.g. by providers of trading platforms that you select when using our services, or by social network operators if you decide to link your social network accounts to an account on our services.

This data includes:

Data about the simulated transactions you have made (e.g., type of financial instrument, time of opening and closing the position, amount of the investment, profit and loss) and data from social networks (username, profile picture, email address associated with the social network account).

We process this data in particular in order to provide you with our services in connection with the simulated transactions you have made on the trading platforms you have selected, i.e. within the framework of our contractual relationship.

Information on how your personal data is processed by the providers of the trading platforms and operators of social networks for their own purposes can be found in the privacy policies of these providers. When registering or logging in to demo accounts and other accounts on the trading platforms you will be notified of the privacy policies there and can accept them. Data processing on the trading platforms and social networks themselves (in particular for the providers' own purposes) is generally the responsibility of the respective providers, meaning that the providers, not us, are responsible for the corresponding data processing.

3. FOR WHAT PURPOSES DO WE USE YOUR PERSONAL DATA  ?

We use personal data for the following purposes:

-        In cases where the respective data processing falls under the General Data Protection Regulation ("GDPR"), the specific legal basis of the GDPR is stated below. If the respective data processing does not fall under the GDPR, the specific legal basis of the GDPR is not relevant and can be disregarded. -

Visiting the website

When you visit our website, we process your data in order to provide you with a functional website. Legal basis for processing: Data processing is based on your use of our website (Art. 6 (1) (b) GDPR) and our interest in improving the stability and functionality of our website (Art. 6 (1) (f) GDPR).

Registration and user account

In order to use the services (with the exception of purely informational visits to our website), you must register on the website and set up a user account, and we process your personal data for this purpose. This includes in particular identification and contact details, and, where necessary, authentication data (such as ID card details, image data) we may also process your data in connection with your user account settings.

Legal basis for processing: Processing is necessary for the performance of the contract, and the provision of this personal data is necessary because we cannot register your user account without this data (Art. 6 (1) (b) GDPR).

Provision of services and exercise of rights and obligations arising from the contract between us and the customer

In order to provide our services to you, i.e. in particular to provide you with the appropriate access, tools, and support and to process transactions, and for the services related to simulated transactions, we need to process your personal data. For this purpose, the following applies:

Personal data: Identification and contact details, as well as communication data and, in the case of paid services, payment data (such as bank details, etc. ), authentication data (such as ID data, image data, etc. ), data about the use of the services, data about the simulated transactions and, if you decide to link your social network accounts to your account on the website, also data from social networks.

Legal basis for processing: Processing is necessary for the performance of the contract on the basis of which we provide our services (Art. 6(1)(b) GDPR) or (to the extent permitted) on the basis of our legitimate interest (Art. 6(1)(f) GDPR). After we have ceased providing our services to you, we process personal data for a limited period of time, insofar as this is necessary for the exercise and protection of our rights on the basis of our legitimate interests.

Marketing communications about our services and products or about events in which we participate

If you are a current or former customer  , we will send you marketing communications about our services from time to time. We may send you these or commercial communications if you give us your consent orwe are otherwise legally entitled to do so.  Each email sent will be marked as a business communication and will contain a link that allows you to easily unsubscribe from business communications. For this purpose, the following applies:

Personal data: Identification and contact details.

Legal basis for processing: If you give us your consent to process your data for marketing purposes, we will process your data on the basis of this consent (Art. 6 (1) (a) GDPR). You can revoke your consent at any time with effect for the future by clicking on the unsubscribe link in the respective email or by sending an email to our contact address specified in this privacy notice. To the extent permitted by law, the legal basis may also be our legitimate interest (Art. 6 (1) (f) GDPR).

Customer service and communication (e.g., by email)

If you use our customer support, we process your personal data in order to help you. For this ,purpose the following provisions apply:

Personal data: Identification data, contact data, communication data, other data that you provide in the course of communication, other data and data from social networks if you contact us via social networks.

Legal basis for processing: Processing is based on the contractual relationship (Art. 6 (1) (b) GDPR) or, where applicable, on our legitimate interest (Art. 6 (1) (f) GDPR), namely maintaining customer satisfaction and providing support in the use of our services.

Newsletter

With your consent, you can subscribe to our newsletter, which allows us to send you interesting information about our services. You can revoke your consent to receive the newsletter at any time. You can revoke your consent by clicking on the link at the end of the newsletter or by sending an email to [email protected].

To register for our newsletter, we process your name, if you provide it, and your email address. We use the so-called double opt-in procedure : After you register, we send an email to the email address you provided. In this email, we ask you to confirm that you wish to receive the newsletter. If you confirm your registration for our newsletter, we will store your email address, IP address, and the time of registration and confirmation. The purpose of this processing is to verify your registration and, if necessary, to investigate any possible misuse of your personal data. The legal basis for the processing is your consent in accordance with Art. 6 (1) (a) and Art. 49 (1) (a) GDPR. After successful registration, you will receive a discount code, if offered; we process information about the redemption of the discount for verification purposes in accordance with Art. 6 (1) (b) GDPR.

In order to send you our newsletters, we use the services of external service providers, some of which are located outside the EU, including the service providers HubSpot, Inc., 25 First Street, Cambridge, MA 02141 USA, and Twilio Inc., 101 Spear St, San Francisco, CA 94105-1558, USA. Data transfer to the USA is based on the Data Privacy Framework, under which HubSpot, Inc. and Twilio Inc are certified, and alternatively on the EU standard contractual clauses. Details of the regulations can be found here https://www.dataprivacyframework.gov/s/program-overview.

Improvement of services

When you use some of our services, we will (to the extent permitted) process your personal data to develop, test, and improve the services and increase their security. The following provisions apply for this purpose:

Personal data: Identification and contact details, data about your device, data about your use of the website, data about your use of the services, and data about simulated transactions.

Legal basis for processing: Processing is based on our legitimate interest, namely the improvement of our services, but only to the extent that this is permissible in the context of weighing up your rights (Art. 6 (1) (f) GDPR).

Orders and payments

If you place orders via our website, in addition to the above-mentioned automatically collected data, we also process data relating to the goods or services ordered and your name, address, email address, telephone number (if applicable), the purchase price and payment details, and the timestamp of the purchase.

In addition to our employees who are responsible for processing the order, external service providers involved in order processing also have access to your personal data, insofar as this is necessary for the provision of the respective service.

If your payment details are collected by us and not directly by the payment service provider, they will be passed on to the payment service provider you have selected for payment processing. In doing so, we pass on the data that you provide to us and that is necessary for processing the payment. Depending on the payment service provider selected, this may include: name, address, account number, bank code, credit card number (if applicable), invoice amount, currency and transaction number, email address, IP address, mobile phone number. You can see which data is transmitted by looking at the categories requested during the payment process.

Legal basis for processing: Data processing is carried out on the basis of Art. 6 (1) (b) GDPR. Data is transferred solely for the purpose of payment processing; the data is deleted after delivery, unless our service providers are themselves obliged to store the data for legal reasons. Please refer to the relevant websites of the payment service provider with whom you have concluded your contract for information on data processing by that provider.

In order to be able to offer you the payment services of the respective payment service providers, we transfer personal data, such as contact details and order data, to the respective payment service provider, who processes your personal data for the purpose of executing the payment transaction. Information on data processing in this regard can be found at the website of the respective payment service provider that you select.

Analytics

In order to obtain information about how our website and services are used, we may analyze ,  (however, if the GDPR applies, only to the extent that you have given your consent)customer behavior . The following provisions apply for this purpose:

Personal data: Identification data, contact data, payment data, data about your device, data about the use of the website, data about the use of other services, and data about simulated transactions.

Legal basis for processing: Where the GDPR applies (e.g., if you are located in an EU/EEA country), this analysis is carried out in relation to the website , but only if you have given your consent. You can revoke this consent at any time with future effect, e.g. by sending us an email to the email address provided in this privacy policy. With regard to analytics when using our other services (beyond the purely informational use of our website), analytics may be carried out on the basis of a separate agreement concluded with you for this purpose, so that the legal basis in this regard is Art. 6 (1) (b) GDPR.

4. HOW DO WE STORE PERSONAL DATA AND HOW IS IT SECURED?

We process your personal data in an encrypted database on computers and other devices. In order to protect the data we process  from unauthorized access or unauthorized modification, disclosure, or destruction, we have taken organizational and technical measures to secure it, which we strictly adhere to.

5. HOW LONG DO WE PROCESS YOUR DATA?

Personal data is processed to the extent necessary to fulfill the purposes described above and for the period necessary to achieve these purposes, or for a period directly prescribed by law. After that, the personal data is generally deleted .

6. RECIPIENTS AND DISCLOSURE AND TRANSFER OF DATA TO THIRD PARTIES

Unless otherwise specified, only employees of ours or third parties entrusted with the execution of the corresponding functionality will have access to your personal data.

We make some of your data available or transfer it to third parties who help us provide our services, in particular to the following :

The providers of the trading platforms you select (in particular for the provision of demo accounts) to enable you to carry out simulated transactions.

Other third parties who assist us in operating our website and providing our services to you (e.g., other companies in our group, hosting and cloud service providers, payment system operators and financial institutions, customer support tool and service providers, IT companies and system administrators, marketing and communications agencies, consultants, and postal service providers);

In addition, we may share your data with persons to whom you have given your consent, as well as in cases where we are required to do so by law or by a court or other legally binding decision. Each of these entities to which personal data is disclosed is contractually obligated to protect your personal data in accordance with legal requirements and to process the data exclusively in accordance with our instructions.

Insofar as personal data is transferred to third parties or other entities outside the EU or outside the European Economic Area to countries for which the European Commission has not issued an adequacy decision (https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en), we have secured the transfer via so-called EU standard contractual clauses, which ensure that the processing of personal data is subject to a level of security that complies with the GDPR . If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent will be obtained in advance in accordance with Art. 49 (1) (a) GDPR as part of the consent management system. Data transfers to the USA are also based in part on the Data Privacy Framework, , provided that the third parties used are certified there . Details of the regulations can be found here https://www.dataprivacyframework.gov/s/program-overview.

Certain third parties, as controllers, collect personal data for their own purposes. In such cases, their own rules for the processing of personal data as described above apply.

7. YOUR RIGHTS

You may exercise all of the rights listed below, including your right to erasure of personal data and to withdraw your consent, by sending us a request by email to [email protected] or using our contact details in section 1 of this privacy notice. There is no specific wording you must use in your request, but please be as specific as possible so that we can assist you with your request (e.g., identify yourself, specify the right you wish to exercise, what action you want us to take, what personal data you want deleted, etc.).

In connection with the processing of personal data, you have the following rights:

Right of access to personal data

You may request confirmation from us at any time as to whether or not your personal data is being processed. If we are processing your data, we will provide you with further details about the processing. Upon request, we will also provide you with a copy of the personal data being processed. Please note that the first copy is free of charge, but subsequent copies will be provided for a small fee.

Right to rectification of personal data

If we process your personal data incorrectly, you can notify us and we will correct the incorrect personal data immediately. When you register on the website, you can correct and change your personal data yourself by editing your user account.

Right to erasure of personal data ("right to be forgotten")

You have the right to request that we erase personal data concerning you without undue delay in the following cases:

If the data is no longer necessary in relation to the purposes for which we collected it or otherwise processed it;

if you withdraw your consent to its processing and there is no other legal basis for its processing (this only applies to cases where we process personal data based on your consent);

if you object and there are no overriding legitimate grounds for the processing, or if you object to the processing for direct marketing purposes; or

if your personal data is being processed unlawfully.

We cannot comply with the request to delete personal data if its processing is necessary for the exercise of the right of freedom of expression and information, for the fulfillment of one of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise, or defense of our legal claims, or for other reasons provided for by law.

Right to restriction of processing

In the cases specified in Art. 18 of the GDPR, you have the right to request that we restrict the processing of your personal data for a certain period of time.

Right to data portability and to the provision of data in a machine-readable format

In the case of automated processing based on your consent or the performance of the contract, you have the right to receive the data in a structured, commonly used, and machine-readable format and to have us transfer it to another controller responsible for processing personal data.

Right to object

If we process personal data on the basis of our legitimate interest, you have the right to object to this processing. If you object, we will no longer be able to process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.

If we process your personal data for marketing purposes for our products and services, we will stop processing immediately upon receipt of your objection. In such a case, we will no longer be able to send you offers about our products and services.

Right to withdraw consent

If the processing is based on your consent, you have the right to withdraw this consent at any time. Withdrawing your consent does not affect the lawfulness of the processing carried out on the basis of your consent prior to withdrawal.

Right to lodge a complaint with the supervisory authority

If you believe that we are processing your data in violation of the relevant legal provisions, you can lodge a complaint with the competent supervisory authority. This may also be the supervisory authority in your country of residence.  Our competent supervisory authority is the Data Protection Authority of the Principality of Liechtenstein ("Data Protection Authority") based in Vaduz, Städtle 38, P.O. Box 684, FL-9490 Vaduz, Tel: +423 236 60 90, Email: [email protected]. Further information about the office can be found on the following website: www.datenschutzstelle.li

8. CHANGES

We may change this privacy notice at any time to adapt it to new technological or regulatory aspects, or for other reasons . The latest version of this privacy notice can be found on our website.