1. Controller and contact

SPEECHLESS TRADING – FZCO
Silicon Oasis DDP A2
Dubai, United Arab Emirates
Email: jonas.lumpp@speechless-trading.com
Phone: +971 50 309 5363

Manager: Jonas Lumpp. This notice concerns our website, enquiries and related services. A broker’s separate privacy notice also applies to processing under your own broker agreement.

2. Website operation and security

Website requests involve data including IP address, requested resources, access time and browser information to deliver content, diagnose errors and prevent abuse. The website is provided through IONOS. Where GDPR applies, necessary operation and abuse prevention rely on Article 6(1)(f), reflecting our legitimate interest in a secure, reliable website.

Cloudflare Turnstile supports bot and spam protection using technical signals such as IP address, browser information, TLS characteristics and site origin. It remains active as a security service independently of optional marketing consent. Cloudflare describes processing for website operators as well as its own purposes of improving bot detection. See the Turnstile Privacy Addendum.

3. Enquiries and contracts

We process information you provide to answer enquiries and prepare or perform agreed services. The contact form uses Contact Form 7. Name, email and message are required; topic, preferred contact method and telephone number are optional. The form cannot be sent without required fields; email or telephone are alternatives. Messages are sent to our email address above and an automatic acknowledgement is configured. Do not send passwords or broker credentials.

Where GDPR applies, contract-related processing relies on Article 6(1)(b), statutory retention on Article 6(1)(c), and general enquiries on our legitimate interest in communication under Article 6(1)(f). An enquiry does not subscribe you to a newsletter.

4. Access and dashboard data

Requested accounts and member access involve the contact, login and permission information needed to provide the service. Website dashboards obtain strategy and performance data through an Airtable integration. Trading metrics are informational and do not manage your account. Do not provide broker login details. Personal data processing necessary for agreed access relies on Article 6(1)(b) GDPR where applicable.

5. Optional external services

HubSpot: The website has a HubSpot integration with analytics and form-capture functions. When enabled, technical usage and form-related data may be transmitted to and processed by HubSpot. The website currently uses a worldwide opt-out setting: the loader may run before you make a choice. Rejection or an existing privacy block prevents future loading. This technical default does not replace consent where the law requires it. See HubSpot data processing information.

Google Maps: Under the current opt-out setting, the contact-page map may load before you make a choice. Google then receives technical connection data including IP address. A placeholder appears when the category is blocked. Consent remains required where prescribed by applicable law.

External links: Opening WhatsApp or social-media links takes you away from this website. The provider handles the connection and interactions under its own terms. Communications you choose to make through those services are also subject to their privacy notices.

6. Cookies and consent

Complianz provides the consent dialogue and optional-service blocking. You may accept or reject optional categories and change your choice through “Cookie settings”. Rejection takes effect for the future and does not recall information already transmitted. Under the current worldwide opt-out setting, optional services may load before you make a choice. Our Cookie Policy explains browser storage and choices. The light/dark control stores your preference locally under st-appearance. Necessary storage supports requested functions; optional access requires consent where prescribed by law.

7. Recipients and processing outside the EEA

Access is available to personnel performing the relevant tasks and providers used for hosting, communication, security, data administration and enabled external services, and authorities where legally required. We are established in the United Arab Emirates and handle enquiries there. External services can involve additional countries. Consent to a service is not a blanket assurance of a specific storage country or adequate protection. Contact us for information on recipients, processing locations and applicable transfer safeguards.

8. Retention

Retention follows purpose and necessity: technical data for operation, troubleshooting and security incidents; enquiries until resolved and as needed for outstanding claims; account and contract information for the service and subsequent statutory evidence and recordkeeping obligations. Data is deleted when its purpose ends unless a prevailing legal obligation or another lawful basis remains. Browser settings allow removal of locally stored preferences. Providers may apply additional retention periods.

9. Your rights

Where GDPR applies, and subject to its conditions, you may request access, correction, erasure, restriction and portability. You may object to legitimate-interest processing for reasons relating to your circumstances and to direct marketing at any time. Consent can be withdrawn prospectively at any time. You may complain to a competent supervisory authority, including in the EU country of your habitual residence, work or the alleged infringement. Other rights under applicable privacy law remain available. Send requests to our email address above; proportionate identity verification may be necessary.

Additional provider and technical details

The current consent configuration remembers choices for 365 days, after which a new choice may be required. You may withdraw earlier at any time.

The dashboard integration retrieves Airtable data server-side. Data includes strategy allocation, internal account references, timestamps, currency, account values and trading/funding metrics. This is separate from personal member access: the access logic uses WordPress user accounts, email addresses and permissions and can send transactional access emails.

Airtable’s DPA identifies Formagrid Inc. and affiliates. Airtable lists the US as its default region; other regions require the corresponding plan and account configuration. Exclusively European storage is not promised here. Airtable DPA · Data regions.

Cloudflare Turnstile is provided by Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. Cloudflare DPA.

IONOS documents webhosting logs containing referrer, requested resource, browser, operating system, device type, access time and anonymised IP address, retained for eight weeks. This provider statement concerns the documented webhosting logs, not automatically email, WordPress records or other services. IONOS webhosting processing.

Google explains processing for embedded maps in its Privacy Policy. International processing and retention also depend on the Google service used and user settings.

10. Updates

We update this notice when services or processing change. The date is shown above.