Privacy Policy

SYSTEMTRADE.COM recognizes the importance of personal information obtained through its services and establishes this Privacy Policy.

The data controller is Attempia Ltd. (registered in the Republic of Seychelles; Japan contact: Singapore branch). For inquiries regarding personal data protection, please use the contact form at the bottom of this page.

Information We Collect

We may collect the following information:

• Name, email address, account information
• IP address, cookies, access logs, device information
• Transaction history, purchase history, payment data (via payment processors)

Purpose of Use

Collected information is used for the following purposes:

• Service provision, identity verification, authentication
• Payment processing, reward handling, fraud prevention
• Support and important notifications
• Analysis and service improvement

Third-Party Disclosure

We do not disclose personal information to third parties except as required by law or necessary for service operation.

International Data Transfer

In providing our Service, we may use servers or service providers located in the following countries/regions:

• United States (Cloudflare CDN, PayPal payment processing)
• Lithuania / EU (Hostinger server infrastructure)
• United States (Google Analytics data analysis)

For transfers of personal data to these countries/regions, we ensure appropriate protection through contractual safeguards with each service provider (data processing agreements, standard contractual clauses, etc.).

Security Measures

We take reasonable measures to protect personal information from unauthorized access or loss, including:

• Protection of communications through SSL/TLS encryption
• Access control restrictions (only authorized personnel with business necessity)
• Security protection via Cloudflare (DDoS mitigation, WAF)

Access, Correction, Deletion

Users may request access, correction, suspension of use, or deletion of their personal information through the following methods:

Please submit your request via the contact form (at the bottom of this page) along with information necessary for identity verification. We will respond to your request within 30 days of receipt as a general rule.

You may also withdraw your consent for consent-based processing of personal information at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Use of Cookies

We use cookies for the following purposes:

• Essential cookies: required for basic site functionality (maintaining login status, etc.). These cannot be disabled.
• Analytics cookies: used via Google Analytics to analyze site usage. Anonymized data is collected.
• Security cookies: used via Cloudflare for protection against unauthorized access and site security.

You may opt out of analytics cookies by disabling cookies in your browser settings or by using the Google Analytics opt-out add-on. However, essential cookies and security cookies cannot be disabled as they are necessary for the proper functioning of the site.

Legal Basis for Data Processing

We process personal information based on the following legal grounds:

• Performance of contract: processing necessary for service provision, including account management, product delivery, and payment processing
• Legitimate interests: fraud prevention, security measures, and analytics for service improvement
• Legal obligation: record keeping based on tax and legal requirements

Children's Data

We do not intentionally collect personal information from individuals under 18 years of age. If we become aware that data has been provided by a person under 18, we will promptly delete such data.

Data Breach Response

In the event of a breach, loss, or destruction of personal information, we will promptly investigate the cause and take measures to prevent further damage. Where the breach is likely to adversely affect the rights and interests of Members, we will notify the affected Members promptly (within 72 hours as a general rule) via email or notice on the site, and report to the Personal Information Protection Commission as required.

Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will notify you at least 14 days before the effective date via posting on the Service or email.

Data Retention

We retain personal information for the following periods:

• Account information (name, email, etc.): deleted 1 year after account closure
• Transaction/purchase history: 5 years from the last transaction (for tax and legal requirements)
• Access logs and IP addresses: 1 year from collection
• Support inquiries: 2 years after resolution

Third-Party Services

We use the following third-party services to provide and operate our Service. Each service is subject to its own privacy policy.

• PayPal (payment processing): used to process payment information
• Google Analytics (web analytics): used to analyze site usage
• Cloudflare (CDN/security): used for content delivery optimization and security
• Hostinger (hosting): server infrastructure provider

Contact

For inquiries regarding this policy, please contact us:

Complaints regarding our handling of personal information may also be filed with the Personal Information Protection Commission (https://www.ppc.go.jp/) in addition to our contact form above.