Our Privacy Policy

INTRODUCTION

This Privacy Policy describes how Sequence Strategies BVI Ltd ("Company," "we," "us," or "our") collects, uses, shares, and protects your personal data when you use the Sequence Strategies website and trading automation software platform (together, the "Software").

We are committed to protecting your privacy and handling your data responsibly. This Privacy Policy applies to all visitors to our website and all users of the Software, regardless of location. If you are located in the European Economic Area ("EEA"), United Kingdom ("UK"), or Switzerland, additional rights and protections apply to you as described in this Privacy Policy.

By using the Software, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy should be read together with our Terms and Conditions, which govern your use of the Software. If you do not agree with our data practices, please do not use the Software.

1. DATA CONTROLLER

Sequence Strategies BVI Ltd

Belmont Chambers, Road Town, Tortola, VG1110. British Virgin Islands.

British Virgin Islands

Contact: support

Data Protection Contact: support@tradewithsequence.com

EU Representative (GDPR Article 27): support@tradewithsequence.com

2. PERSONAL DATA WE COLLECT

We collect the following categories of personal data:

2.1 Identity and Account Data

Data you [may] provide when creating and managing your account:

• Full name

• Email address

• [ID]

• Phone number (if provided)

• [Telegram UID]

• Username and password (password stored in hashed form only)

• [Two-factor authentication settings]

2.2 KYC Verification Data

The following data may be collected for identity verification:

• Government-issued identification documents (passport, ID card, driver's license)

• Selfie or video verification

• Date of birth

• Nationality

• For corporate users: company registration documents, director/shareholder information

2.3 Exchange Connection Data

Data relating to your connected cryptocurrency exchange accounts:

• API Keys: We receive and process API keys that you provide for your cryptocurrency exchange accounts. API keys are encrypted using industry-standard encryption both at rest and in transit.

• Exchange account identifiers

• Connected exchange platforms

Important information about API Keys:

• We only accept API keys with trade-only permissions (no withdrawal capability)

• Access to API keys is restricted to essential personnel and all access is logged

• We will not use your API keys to trade for our own benefit, access your accounts for purposes other than providing the Software, or share your API keys with third parties except as required by law

• Upon termination of your account, your API keys are permanently deleted from our systems

Self-Hosted Deployment: If you use our self-hosted deployment option, please note that your self-hosted instance transmits data back to Sequence Strategies for license validation, service delivery, and analytics purposes. This includes usage telemetry, error logs, and trading statistics. Self-hosted users are subject to the same analytics tracking as centrally-hosted users. Your API keys remain on your own server and are not transmitted to us.

2.4 Trading Data

Data generated through your use of the Software:

• Trade execution history (orders, fills, timestamps)

• Open and historical positions

• Profit and loss calculations

• Strategy configurations and settings

• Bot activity and performance metrics

2.5 Financial and Payment Data

Data relating to your subscription:

• Cryptocurrency wallet addresses used for payments

• Payment transaction records

• Subscription tier and billing history

2.6 Technical Data

Data collected automatically when you access the Software:

• IP address

• Device type and operating system

• Browser type and version

• Time zone and language settings

• Session identifiers

• Access timestamps

2.7 Usage Data

Data about how you interact with the Software:

• Features accessed and used

• Page views and navigation patterns

• Session duration

• User preferences and settings

2.8 Communication Data

Data from your interactions with us:

• Support tickets and correspondence

• Email communications

• Feedback and survey responses

3. HOW WE COLLECT YOUR DATA

We collect personal data through the following means:

Directly from you:

• When you create an account

• When you complete KYC verification

• When you connect exchange accounts

• When you configure trading strategies

• When you contact our support team

• When you make payments

Automatically:

• When you access and use the Software

• Through cookies and similar tracking technologies

• Through server logs

From third parties:

• KYC verification providers

• Cryptocurrency exchanges (via API)

• Analytics providers

4. PURPOSES AND LEGAL BASES FOR PROCESSING

We process your personal data for the following purposes and legal bases:

4.1 Contract Performance (GDPR Article 6(1)(b))

Processing necessary to provide the Software and fulfill our contractual obligations:

4.2 Legal Obligations (GDPR Article 6(1)(c))

Processing necessary to comply with legal requirements:

4.3 Legitimate Interests (GDPR Article 6(1)(f))

Processing necessary for our legitimate interests, balanced against your rights:

4.4 Consent (GDPR Article 6(1)(a))

Processing based on your explicit consent:

You may withdraw consent at any time by contacting us or updating your preferences in your account settings. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

5. DATA SHARING AND RECIPIENTS

We may share your personal data with the following categories of recipients:

5.1 Service Providers

We engage third-party service providers who process data on our behalf:

All service providers are contractually bound to process data only according to our instructions and to implement appropriate security measures.

5.2 Cryptocurrency Exchanges

When you connect an exchange account, your API keys enable the Software to interact with that exchange. The exchange receives trade instructions from the Software. Your use of any exchange is subject to that exchange's privacy policy.

5.3 Professional Advisors

We may share data with legal, accounting, and other professional advisors in connection with our business operations.

5.4 Legal and Regulatory Authorities

We may disclose data when required by law, regulation, or legal process, including:

• Law enforcement agencies

• Tax authorities

• Regulatory bodies

• Courts and tribunals

5.5 Business Transfers

In connection with any merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity.

5.6 With Your Consent

We may share data with other third parties when you have given explicit consent.

We do not sell your personal data to third parties.

6. INTERNATIONAL DATA TRANSFERS

6.1 Transfer Locations

Your personal data may be transferred to and processed in:

• The British Virgin Islands (where we are incorporated)

• The United Arab Emirates (where our Licensor is located)

• Other countries where our service providers operate

These countries may not provide the same level of data protection as your home country.

6.2 Transfer Safeguards

For transfers of personal data from the European Economic Area, United Kingdom, or Switzerland to countries without an adequacy decision, we use Standard Contractual Clauses ("SCCs") approved by the European Commission to ensure adequate protection of your data.

You may request a copy of these safeguards by contacting us at support@tradewithsequence.com.

6.3 Commitment

We will only transfer your personal data to countries or recipients that provide adequate protection or where appropriate safeguards are in place.

7. DATA RETENTION

We retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law.

7.1 Retention Periods

7.2 Deletion

After the applicable retention period, we will securely delete or anonymize your data. We may retain anonymized, aggregated data indefinitely for analytics and product improvement purposes. For information about how data is handled upon account termination, see Section 17.3 of our Terms and Conditions.

8. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data, including:

Technical Measures:

• Encryption of data in transit using TLS 1.2 or higher

• Encryption of sensitive data at rest using AES-256 or equivalent

• Multi-factor authentication for account access

• Regular security assessments and penetration testing

• Intrusion detection and monitoring systems

• Secure development practices

Organizational Measures:

• Access controls limiting data access to authorized personnel on a need-to-know basis

• Employee training on data protection and security

• Incident response procedures for potential breaches

• Vendor security assessments

• Regular policy reviews

Your Responsibilities:

While we take reasonable steps to protect your data, no method of transmission or storage is 100% secure. You are responsible for:

• Maintaining the security of your account credentials

• Keeping your API keys secure

• Enabling two-factor authentication

• Promptly reporting any suspected unauthorized access

9. COOKIES AND TRACKING TECHNOLOGIES

9.1 What We Use

We use cookies and similar technologies to operate and improve the Software:

9.2 Google Analytics

We use Google Analytics to understand how users interact with the Software. Google Analytics uses cookies to collect information about your use of the Software. This information is transmitted to and stored by Google.

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on or by adjusting your cookie preferences.

9.3 Managing Cookies

You can manage cookie preferences through:

• Your browser settings

• Our Usercentrics cookie consent platform (for EEA/UK users)

• Contacting us at support@tradewithsequence.com

Note that disabling essential cookies may affect the functionality of the Software.

We do not use social media tracking pixels or advertising/remarketing cookies.

10. YOUR PRIVACY RIGHTS

10.1 Rights for All Users

Regardless of your location, you may:

• Access your personal data through your account settings

• Update or correct your account information

• Delete your account (subject to our retention obligations)

• Contact us with privacy questions or concerns

10.2 Additional Rights for EEA, UK, and Swiss Users

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the following additional rights under GDPR:

10.3 Exercising Your Rights

To exercise your rights, contact us at:

Email: support@tradewithsequence.com

We will respond to your request within 30 days. For complex requests, we may extend this period by up to 60 days, in which case we will inform you of the extension and the reasons.

Identity Verification: Before processing your request, we will verify your identity using one or more of the following methods:

• Logged-in verification: Submitting your request while logged into your account

• Email confirmation: Responding to a confirmation link sent to your registered email address

• Security questions: Confirming account details only you would know

• ID document: For high-risk requests (such as full data deletion), we may request a copy of your government-issued ID to match against your KYC records

Data Portability Format: Where you exercise your right to data portability, we will provide your data in CSV format.

Requests are generally free, except for manifestly unfounded or excessive requests.

10.4 Limitations on Rights

Your rights are not absolute. We may need to retain or continue processing your data for:

• Compliance with legal obligations (such as financial record-keeping and AML requirements)

• Establishment, exercise, or defense of legal claims

• Legitimate business interests that override your request

• Contractual obligations that require the data

We will inform you if we cannot fully comply with your request and explain the reasons.

10.5 California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected

• Right to Delete: Request deletion of your personal information

• Right to Opt-Out: Opt out of the sale or sharing of personal information (note: we do not sell personal information)

• Right to Non-Discrimination: Not receive discriminatory treatment for exercising your rights

To exercise these rights, contact us at support@tradewithsequence.com.

11. AUTOMATED DECISION-MAKING

11.1 Our Position

We do not use your personal data for automated decision-making that produces legal or similarly significant effects on you.

11.2 Trading Decisions

The Software executes trades based on strategies and parameters that you configure. These trading decisions are made by the Software according to your instructions, not by us. You retain full control over your trading strategy settings and can modify or disable automated trading at any time.

This is distinct from automated decision-making about you—the Software executes your trading decisions; it does not make decisions about your rights or status.

12. CHILDREN'S PRIVACY

The Software is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children under 18. If you believe we have inadvertently collected data from a child under 18, please contact us immediately at support@tradewithsequence.com, and we will take steps to delete such data.

13. THIRD-PARTY LINKS AND SERVICES

The Software may contain links to third-party websites, services, or applications. This Privacy Policy does not apply to those third parties. We are not responsible for the privacy practices of third parties, including cryptocurrency exchanges. We encourage you to review the privacy policies of any third-party services you use.

14. DATA BREACH NOTIFICATION

14.1 Our Commitment

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify relevant supervisory authorities within 72 hours where required by law

• Notify affected users without undue delay where the breach is likely to result in a high risk to your rights and freedoms

• Document all breaches and remediation actions

14.2 Your Role

If you become aware of any unauthorized access to your account or data, please notify us immediately at support@tradewithsequence.com.

15. COMPLAINTS

15.1 Contact Us First

If you have concerns about how we handle your personal data, please contact us first at support@tradewithsequence.com. We will do our best to resolve your concerns.

15.2 Supervisory Authorities

If you are located in the European Economic Area or United Kingdom, you have the right to lodge a complaint with your local data protection supervisory authority if you believe we have violated your privacy rights.

• EEA: A list of supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

• UK: Information Commissioner's Office (ICO) - https://ico.org.uk/

We encourage you to contact us first so we can try to resolve your concerns.

16. CHANGES TO THIS PRIVACY POLICY

16.1 Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons.

16.2 Notification

For material changes that significantly affect your rights or how we process your data, we will provide notice through:

• Email to the address associated with your account

• Prominent notice within the Software

• At least fourteen (14) days before changes take effect

16.3 Continued Use

Your continued use of the Software after changes become effective constitutes acceptance of the updated Privacy Policy. If you do not agree with any changes, you should stop using the Software before the changes take effect.

16.4 Review

We encourage you to periodically review this Privacy Policy for the latest information about our data practices.

17. CONTACT US

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about our data practices, please contact us:

Sequence Strategies BVI Ltd

British Virgin Islands

Email: support@tradewithsequence.com

For general inquiries: support@tradewithsequence.com

We aim to respond to all privacy inquiries within 30 days.

SUMMARY OF KEY POINTS

For your convenience, here is a summary of key points in this Privacy Policy:

1. What we collect: Identity, KYC, API keys (encrypted), trading data, payment, technical, and usage data.

2. Why we process: To provide the Software (contract), comply with laws (legal obligation), protect our systems (legitimate interests), and with your consent (marketing).

3. Who we share with: Group companies, service providers, exchanges (via your API), professional advisors, and authorities when required by law. We do not sell your data.

4. International transfers: Your data may be transferred to BVI, UAE, and other countries. We use Standard Contractual Clauses for EEA/UK transfers.

5. Retention: Account and trading data for 7 years after account closure; logs for 24 months; API keys deleted on termination.

6. Your rights: Access, correct, delete, restrict, port your data; object to processing; withdraw consent. Contact support@tradewithsequence.com

7. Security: We use encryption, access controls, and other measures to protect your data.

8. Cookies: We use essential and analytics cookies. EEA/UK users can manage non-essential cookie preferences.

© 2026 Sequence Strategies BVI Ltd. All rights reserved.

All rights reserved. Sequence Strategies Limited BVI: Company Registration 2202200. Belmont Chambers, Road Town, Tortola, VG1110. British Virgin Islands. 🇻🇬

Sequence is a crypto algo trading software business. All interested parties are to check in advance whether they are legally entitled to purchase the products or activate and/or access services presented on the website/presentation. No recommendations are made to activate this service or invest in any other investment. Access to products and services on this website may be restricted for certain persons or countries. It is your responsibility to make sure that you are abiding to the laws and regulations of your domicile. Sequence offers a signals trading service that is self-custodial. You have full access, rights and understanding close any position at your own discretion, risk and responsibility. We make best efforts to ensure the accuracy and correctness of the information here, we do not accept any liability or responsibility for any errors or omissions. Trading carries risks. Exchanges carry risks. Coins carry risk. DYOR (Do Your Own Research).