Privacy Policy & Legal

7th Feb 2018

Backup Policy Privacy Policy

Tradefeedr Backup Policy

Overview

It is important that the Tradefeedr system code, system data and client data be secure and be backed up on a regular basis so that it can be sufficiently recovered in the event of a loss of data and/or code for any reason (hard disk fails for any reason, disaster in the data centre, data becomes corrupted on disk etc. Industry best practice is applied in all cases for system security and system backup by the Tradefeedr development team.

Codebase Backup and Security

The codebase for the Tradefeedr system is stored on GitHub. GitHub is a web-based hosting service for version control using git. It is mostly used for computer code. It offers all of the distributed version control and source code management functionality of Git as well as adding its own features. GitHub has become one of the de facto standard repositories for storage of code. For more information on GitHub Physical Security, System Security, Operational Security, Software Security, File System and Backups, please refer to https://help.github.com/articles/github-security/

Data Backup and Security

The Tradefeedr System is a cloud based Software as a Service. It runs on the Microsoft Azure cloud platform. Microsoft Azure is a cloud computing service created by Microsoft for building, testing, deploying, and managing applications and services through a global network of Microsoft-managed data centers (for more information see https://azure.microsoft.com/en-gb/ )

Users access the service via the Tradefeedr website – to the HTTPS frontend and the SFTP upload area where the user uploads their daily client data. This is accessed via userid and password which is unique to each user.

A client will load up their data onto the Tradefeedr service on a daily basis via SFTP. SSH File Transfer Protocol (SFTP) is a network protocol that provides for secure file access, file transfer, and file management over a reliable data stream. A userid and password is required to access the Client specific SFTP site. Through the userid and password, a user only ever has access to their own Client data, for both the SFTP site, and the Tradefeedr Service. A separate instance of the service and a separate instance of the backend database exists for each distinct client.

Once a client has uploaded their raw daily data files, these are retained for 7 days in compressed data format before being overwritten. In so doing, they can be used to reload data into the Tradefeedr Service at a later point if necessary. They are also retained for the 7 days for investigation purposes, in case the operations team needs to ascertain if a data related problem stems from the original raw client daily data files.

Upon receipt of the client daily data file onto the SFTP site, the daily data file is uploaded into the Tradefeedr System. The data from that point onwards is stored in the database backend. The raw data file for that day is then compressed and stored in zip format.

A snapshot backup of the live Tradefeedr system and the backend database is performed on Azure on a daily basis. A backup of the machine image holding the raw daily client data files, the system code and the client data that sits in the backend database is taken. All Virtual Machines run as an image which can be pushed onto any of the Azure Virtual Machines, so they backup a snapshot of that. Where possible, the Backup procedure kicks off at 4am UK time daily. Each incremental backup snapshot is retained for 7 days before being overwritten.

A limited number of Tradefeedr staff have access to the raw daily data files, the zipped daily data files and backed up versions of the Tradefeedr Service and its backend database data.

For more information on the azure backup procedures, please see https://docs.microsoft.com/en-us/azure/backup/backup-azure-arm-restore-vms

The IT Backup systems have been designed to ensure that routine backup operations require no manual intervention The IT department monitor backup operations and the status for backup jobs is checked on a daily basis during the working week. Any failed backups are re‐run immediately the next working day.

Requests for data recovery or reversion to a stored incremental Tradefeedr System backup should be submitted to the Tradefeedr IT Service desk.

Tradefeedr Privacy Policy

Overview

Tradefeedr Limited is committed to protecting your personal information and respecting your privacy.

In general, you can visit Tradefeedr on the Web without telling us who you are or revealing any information about yourself. To the extent that you do provide information to Tradefeedr, Tradefeedr will never sell, rent or disclose your personally identifiable information to outside parties for their own marketing purposes without your consent.

With your permission, Tradefeedr may send you e-mail regarding our new products, upgrades, and blog posts.

Information That We Gather and Track

Tradefeedr only collects personal information which is reasonably necessary for its dealings with the individuals to whom the information relates. The types of personal information Tradefeedr collects will depend on the particular dealings we have with you. However, generally, we collect and hold personal information about existing and prospective customers, our third party service providers and suppliers, and employment applicants.

The types of personal information that we collect and hold about these individuals includes, but is not limited to:

· Personal identifiers, such as names, contact details (e.g. email address), job description and, if applicable, language spoken
· A customer’s payment details for the purpose of processing the purchase of our products and services

Tradefeedr may also collect personal information about individuals indirectly from third parties, such as from our business partners, from third party providers of marketing lists, and through various other methods, including:

· Cookies
· Referrers
· IP addresses
· System information

None of these methods can be used to identify, or reasonably identify, you with the exception of cookies, which can optionally store information that you may enter in forms on our Web Sites, as described below.

A "cookie" is an element of data that a Web Site can send to your browser, which may then store it on your system. It can be used to provide you with a tailored user experience. Some Tradefeedr pages may use cookies. Cookies are used to better personalize the content, banners and promotions that you and other users may see. We may use the information to research and understand how our users’ habits in the aggregate are similar or different so that we can enhance your experience on Tradefeedr sites and with our products. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. Tradefeedr does not require that you accept cookies.

A "referrer" is the information passed along by a web browser that references the Web URL you linked from, and is may be collected by our Web server. This information may be collected and used by Tradefeedr to understand the web sites referring traffic to our web pages and to present appropriate content to our potential customers. Referrer information may be tabulated by Tradefeedr on an aggregated basis to identify general trends and traffic patterns.

IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer so that data (such as the Web pages you request) can be sent to you. They may be automatically gathered by our Web server. Tradefeedr will not use your IP address to attempt to identify your personal information.

System information we gather includes time, type of Web browser being used, the operating system/platform, and CPU speed. This information is sent automatically by your Web browser when you are connected to a Web Site and is used by Tradefeedr only for broad demographic statistics. This information may be used by Tradefeedr in identifying broad demographic trends and may be used to provide information appropriate for your computer system. You will not be personally identified from this information. What We Do With the Information

We Gather and Track

The personally identifiable information gathered is used in one of five ways:

· To provide you with information about our products and services, including product alerts, releases, upgrades and patches
· To aggregate broad demographic information in order to understand general user trends, and
· To ensure our compliance with export control and other applicable laws and regulations.

At times Tradefeedr retains contractors to perform services for Tradefeedr internally in the course of our business. Consequently, they may have access to information about our customers in providing those services. Such limited access would be available only to the extent needed to perform the services, under the terms of an executed confidentiality and non-disclosure agreement with Tradefeedr, with the requirement that such contractors keep the information strictly confidential and use the information solely on Tradefeedr’s behalf. Tradefeedr does not collect sensitive personal information regarding customers.

In addition, Tradefeedr discloses the personal information it collects to the following entities:

· Third parties where disclosure is required or authorised by law

Tradefeedr takes reasonable steps to ensure that the personal information it discloses to third parties, including to its related entities, is protected from misuse and unauthorised disclosure. Disclosure to any unrelated third party is subject to an executed confidentiality and non-disclosure agreement with Tradefeedr.

The Tradefeedr Web Sites may contain links to other web sites. However, Tradefeedr is not responsible for the privacy practices or the content of such web sites. Communications to our Users In addition to product updates, promotional and informational e-mails that Tradefeedr sends to its users from time to time, we may, on occasion, invite you to participate in a focus group, phone survey or send you postal mail.

You may always opt-out of receiving marketing communications through our subscription center or, for e-mail communications, by clicking on the link provided at the bottom of our e-mail to you.

Once you supply us with personal information, such as an e-mail address, Tradefeedr does not change the manner of usage of such information from its original purpose, unless we first obtain your informed consent.

Access and correction of your personal information

You may access and correct the personal information we hold about you by contacting us.

Tradefeedr will generally provide individuals with access to the personal information we hold about them. However, in some circumstances, there may be legal, regulatory or administrative reasons to deny access to the requested information. If access is denied, Tradefeedr will provide reasons for the denial (unless it would be unreasonable to do so).

Changes to our Privacy Policies

We revise our Web Site Privacy policy to keep it up to date with Tradefeedr products, services and web pages. We will notify you of any changes we make by posting an updated version of this policy on our Web Sites. Any changes will take effect when they are so posted.

Tradefeedr will use reasonable efforts to comply with this privacy statement and will take prompt corrective action when it learns of any failure to comply with its privacy statement. Because of the complex and constantly changing nature of our technology and business, Tradefeedr does not guarantee error-free performance under this privacy statement. Tradefeedr shall not be liable for any incidental, consequential or punitive damages relating to this privacy statement.

Contacting Us about Privacy

If you have any questions about this privacy statement, the practices of our software or Web Sites, or wish to make a complaint about our handling practices, you may contact:

Tradefeedr Privacy Officer
Suite 5, 9-15 Queen Street,
Belfast BT16EA, UK.

We will investigate any complaints received in writing and do our best to resolve them with you as soon as possible.