Onedream Privacy Policy

1. Overview & Legal Basis

1.1 We recognize the sensitivity of personal information, especially financial data. This Privacy Policy aims to transparently inform you about how we collect, process, store, protect, and share your personal information when you use Onedream to connect and manage your cTrader trading account. Our practices comply with applicable data protection laws and regulations, including those of the People's Republic of China, the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other relevant jurisdictions (collectively, "Applicable Laws").

1.2 This Policy forms a legally binding part of the agreement between you and us. PLEASE READ THIS POLICY CAREFULLY, UNDERSTAND ITS CONTENTS FULLY, AND CONFIRM YOUR ACCEPTANCE BEFORE USING THE APP. If you do not agree, please do not authorize us to access your data or use our services.

2. Personal Information We Collect & Process

We only process personal information strictly necessary for providing the App's core functionality. Data processing is based on your explicit consent and/or the necessity to perform our contract with you.

Information Category	Specific Content	Legal Basis for Processing
A. Account & Identity Information	Identifiers you provide when registering for Onedream, such as username and email address.	Performance of our contract with you (Terms & Conditions).
B. Financial Transaction Data (via cTrader API)	Data related to your trading account that we receive through Spotware Systems Ltd.'s cTrader Open API, following your explicit authorization: Account Summary: Account ID, number, type, balance, equity, margin level. Positions & Open Trades: Open price, current price, volume, floating profit/loss. Order History: Current pending orders, historical order details (including price, time, status). Trade Instructions: Instructions (e.g., place, close, modify orders) you send through the App and their execution results.	Your explicit consent (via OAuth authorization). This is necessary for performing the App's core service (account display and trade execution).
C. Technical Logs & Device Information	Anonymized information automatically collected to ensure secure and stable operation: IP address, device model, OS version, app crash logs, access timestamps.	Our legitimate interests (maintaining service security and improving performance).

3. Purposes of Information Processing

We commit to using your personal information only for the following explicit, specific, and lawful purposes:

• Service Delivery: To display your trading account information, positions, and market data in real-time within the Onedream interface, and to securely and accurately transmit your trading instructions to the cTrader platform.
• Service Optimization & Development: To analyze usage patterns on an anonymized, aggregated basis to improve app performance, develop new features, and enhance user experience.
• Security, Fraud Prevention & Compliance: To monitor, prevent, and investigate potentially prohibited or illegal activities, to protect the rights and safety of us, our users, and the public, and to fulfill our legal obligations.
• User Support: To respond to your inquiries, requests, and provide technical support.

4. Information Sharing & Disclosure

We share your personal information with third parties only under the following strictly limited circumstances, ensuring they are contractually bound to provide a level of protection consistent with this Policy:

• Authorized Service Providers (Data Processors): We may engage trusted third-party partners to provide infrastructure, analytics, or customer support services. They process data only on a "need-to-know" basis and are strictly prohibited from using data for any other purpose.
• Legal Obligation & Rights Protection: When we believe in good faith that disclosure is necessary to comply with a law, regulation, subpoena, court order, governmental request, or to protect the vital interests, rights, property, or safety of us, our users, or the public from imminent harm.
• Business Transfer: In connection with a merger, acquisition, reorganization, bankruptcy, or sale of all or part of our assets, your information may be transferred as part of that transaction. We will ensure the transferee is bound by this Policy.

5. Cross-Border Data Transfers

As our service providers or infrastructure may be located outside your country/region, your information may be transferred to and processed in overseas jurisdictions, as permitted by Applicable Laws. For transfers originating from regions like the European Economic Area (EEA), we will ensure appropriate safeguards are in place, such as the European Union's Standard Contractual Clauses (SCCs).

6. Your Data Subject Rights

Under Applicable Laws, you may have the following rights:

• Right of Access & Data Portability: To obtain a copy of your personal information we hold and to receive it in a structured, commonly used format.
• Right to Rectification: To request correction of inaccurate or incomplete personal information.
• Right to Erasure: To request deletion of your personal information ("right to be forgotten").
• Right to Restriction of Processing: To request restriction of processing of your information under specific circumstances.
• Right to Object: To object to processing based on legitimate interests.
• Right to Withdraw Consent: To withdraw your consent for access to cTrader data at any time via the App's settings or by contacting us to delete your Onedream account. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

Exercising Your Rights: To exercise any of these rights or for any queries regarding our data processing, please submit a request using the contact details in Section 9. We may verify your identity for security before processing your request.

7. Data Security & Retention

Security Measures: We implement technical measures (e.g., TLS encryption, data-at-rest encryption, access controls) and organizational measures (e.g., employee confidentiality agreements, principle of least privilege) aligned with industry standards to protect your information against loss, misuse, unauthorized access, disclosure, alteration, or destruction.

Incident Response: In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by law.

Data Retention: We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Policy. After you delete your account or withdraw authorization, we will securely delete or anonymize your data within a reasonable operational timeframe (typically not exceeding 180 days), unless a longer retention period is required or permitted by law for legal claim establishment, exercise, or defense.

8. Updates to This Privacy Policy

We may update this Policy periodically to reflect changes in law, technology, or our business practices. The updated policy will be posted on this page with a revised "Effective Date." For material changes, we will notify you via a prominent notice within the App or by email to your registered address. YOUR CONTINUED USE OF THE APP AFTER THE EFFECTIVE DATE OF THE UPDATED POLICY CONSTITUTES YOUR ACCEPTANCE OF THE CHANGES.

9. Contact Us

If you have questions about this Privacy Policy, our data practices, or wish to exercise your data rights, please contact our Data Protection Officer (DPO) or legal team:

Matter	Contact Details
General Inquiries & Rights Requests	Email: 418991054@qq.com Email Subject: Privacy Policy Inquiry - Onedream
Company Registered Address	Singapore Central Business District
Official Website	https://www.wyzs.online

We are committed to responding to your request within the timeframe stipulated by Applicable Laws (typically 30 days).