Privacy Policy

How TFP Software FZCO collects, uses, stores, and protects your personal data.

Effective Date: 1 September 2026 · Last Updated: 1 September 2026 · TFP Software FZCO — UAE

1. Introduction

This Privacy Policy explains how TFP Software FZCO (“we,” “us,” “our”) collects, uses, stores, and protects your personal data when you visit our website, use The Friendly PARTNER software toolkit, or interact with our partner program.

We are committed to protecting your privacy and being transparent about our data practices. This Privacy Policy applies to all visitors to our website, users of our software, and individuals who interact with our partner program.

This Privacy Policy is provided in a layered format so you can click through to specific sections. It is important that you read this Privacy Policy together with our Rules and Regulations, our Cookie Policy, and any other privacy notice we may provide on specific occasions.

2. Who We Are and Contact Details

The controller responsible for your personal data is:

Detail	Value
Registered name	TFP SOFTWARE - FZCO
Legal form	Free Zone Company (FZCO) with limited liability
Registration number	82410
Trade licence number	89171
Licensing authority	Dubai Integrated Economic Zones Authority (DIEZA), Dubai Silicon Oasis (DSO), Dubai
Incorporated	12 June 2026, under Dubai Law No. 16 of 2021 and the DIEZA Implementing Regulations 2023
Licensed activities	Computer Systems & Communication Equipment Software Design Computer Systems & Communication Equipment Software Trading
Registered office	IFZA Properties, DSO-IFZA, Dubai Silicon Oasis, Dubai, United Arab Emirates
Jurisdiction	United Arab Emirates

To contact us: through the Contact page, the Support section of your dashboard, email ([email protected]), or by post to the registered office above.

3. What Personal Data We Collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

Data Type	Description
Identity Data	The name on your MetaTrader account, as you declare it in your dashboard and as reported by the software. We do not collect a date of birth or a separate username — your email address identifies your account.
Contact Data	Email address, and the billing address you provide (name, street, city, state, postal code, country). We do not collect telephone numbers.
Profile Data	Your MT4/MT5 account numbers and your partner code. Your password is stored only as a one-way cryptographic hash — we never hold the password itself and cannot recover it.
Transaction Data	Details of your subscription, billing interval and price, trial activations, and payment status. Card details are handled entirely by our payment provider and never reach our systems.
Technical Data	IP addresses — recorded when you register or accept our terms, when the software validates your licence, and when a partner referral link is clicked. We do not build device fingerprints or record your browser, operating system, or time zone.
Usage Data	Licence validation records: which of your accounts checked in, when, and from which IP address.
Marketing Data	Whether you have opted in to marketing email, and when.
Communication Data	Your correspondence with us, which lives in our support mailbox. For the automated emails our system sends you — things like your trial ending, a payment confirmation or a setup guide — we keep a short delivery record: which message it was, which account it went to, and when. We do not store the subject line or the contents of those messages, and we keep no database log of your replies; what our systems otherwise store is your delivery address and your email preference.
Partner Data	If you join the partner program: your public display name and region, referral link and code, commission tracking data (clicks, referrals, sales, active clients, payouts), and the payout details you enter so we can pay your commission — your chosen currency and the bank account or IBAN you supply.
Customer Support Data	Whatever you choose to include when you contact us. Messages sent through our contact form are emailed to our support inbox. We do not record calls.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity.

Unless required by law, we will not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, health information, or criminal convictions).

4. How We Collect Your Personal Data

We use different methods to collect data from and about you:

Direct Interactions

When you sign up for a free trial
When you create a dashboard account
When you become a partner
When you contact us through the Contact page
When you give us feedback
When you submit a query

Automatically

When our software validates your licence, we record the account number, your IP address, and the account holder name your trading platform reports
When you arrive through a partner referral link, we record the partner's code, your IP address, and which page you landed on
Your IP address is also recorded at the moment you register and accept our terms, as the record of that consent

This is the full extent of our automatic collection. We do not profile your browsing, and our cookies do not gather data about you — see our Cookie Policy.

Third Parties

When a partner refers you to our website
From our payment provider, when a subscription is purchased, renewed, or cancelled

We do not buy contact lists, scrape public sources, or enrich your record with data from data brokers.

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to. We have set out below the purposes for which we process your personal data and the legal bases we rely on:

Purpose	Data Type	Legal Basis
To provide access to The Friendly PARTNER software	Identity, Profile	Performance of a contract
To manage your subscription and trial period	Identity, Contact, Profile	Performance of a contract
To attribute sales to partners (referral tracking)	Identity, Profile, Partner	Legitimate interests / Consent
To send you important notifications (trial expiry, payment confirmations)	Identity, Contact	Performance of a contract / Legal obligation
To send you service-related communications to help you set up, configure, and use the toolkit effectively, and to provide ongoing support and guidance	Identity, Contact, Communication	Performance of a contract / Legitimate interests
To respond to your inquiries and support requests	Identity, Contact, Customer Support	Legitimate interests
To improve our website and software	Technical, Usage	Legitimate interests
To comply with legal obligations	Identity, Contact, Transaction	Legal obligation
To validate your licence and prevent licence sharing and trial abuse	Identity, Profile, Technical, Usage	Performance of a contract / Legitimate interests
To send marketing communications (only with your explicit consent)	Identity, Contact, Marketing	Consent

Licence validation and anti-fraud

Because our software is licensed per user rather than per device, it contacts our servers to confirm that the MetaTrader account it is running on holds a valid licence. Each time it does, we record the account number, your IP address, and the account holder name your trading platform reports. We use this to:

Confirm your licence — the name reported by the software is compared with the name you declared in your dashboard. If the two do not match, validation is refused until they do. This check is automated; if you believe it has denied you in error, contact us and a person will review it.
Detect licence sharing — we flag accounts validating from an unusually large number of distinct IP addresses. This is reviewed by a person and never results in an automatic block.
Prevent free-trial abuse — we keep a permanent record of every MetaTrader account number that has been granted a free trial, so that each account number can receive one trial only.

The free-trial record is kept against the account number, not against you, and contains no contact details. It is retained permanently and deliberately survives deletion of your account — see “Limitations” under Your Legal Rights below.

6. Legal Basis for Processing

The law allows us to process your personal data only if we have a valid legal basis to do so. We rely on one or more of the following legal bases:

Legal Basis	Description
Performance of a Contract	Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract (e.g., providing you with access to our software, managing your subscription, and sending service-related communications to help you use the toolkit effectively)
Consent	You have given clear consent for us to process your personal data for a specific purpose (e.g., receiving marketing communications or enabling analytics cookies)
Legitimate Interests	Processing is necessary for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests. Our legitimate interests include: providing and improving our services; ensuring website and user security; personalizing user experience; developing new features; and protecting our legal rights
Legal Obligation	Processing is necessary for compliance with a legal or regulatory obligation to which we are subject (e.g., tax reporting, anti-money laundering obligations)

Where we rely on Consent, you have the right to withdraw your consent at any time. Where we rely on Legitimate Interests, you have the right to object to such processing on grounds relating to your particular situation.

7. Service & Marketing Communications

7.1 Service Communications

We may send you service-related communications to support your use of The Friendly PARTNER. These communications are distinct from marketing communications and are designed to help you get the most out of the toolkit. Examples include setup guides and installation instructions, configuration tips and best practices, technical support and troubleshooting assistance, updates about the toolkit's functionality or performance, educational content about specific features, proactive outreach to ensure you are using the toolkit correctly, and community engagement messages inviting you to connect with other traders.

Essential vs. non-essential service communications

We distinguish between the two based on content and primary purpose:

Type	What it covers	Opt out?
Essential	Strictly necessary to fulfil a specific, active request or to perform the core service, and purely informational with no promotional content. Examples: email address verification, password resets, trial start and expiry notices, subscription renewal and payment confirmations, security alerts, critical technical updates affecting the toolkit, and changes to our Terms and Conditions or this Privacy Policy. This also covers messages needed to get the software you are actively trialling or subscribed to into working order — notifying you that your Expert Advisor has not yet connected and your licence has never been validated, and the installation and configuration instructions that resolve it.	No — these are necessary for the performance of our contract with you and for compliance with legal obligations
Non-essential	Helpful but not strictly necessary for the core service; may include educational content or community engagement. Examples: trading tips and best practices beyond initial setup, educational content, community engagement messages, feature highlights, and proactive outreach that is not about getting the software working.	Yes — at any time, using the same switch and unsubscribe links described in 7.2 below

We send these communications because:

They are necessary for the performance of our contract with you (that is, to provide you with access to and support for the software you have subscribed to)
They help us fulfil our legitimate interest in ensuring you have a positive experience with the toolkit and understand how to use it effectively
They are not promotional in nature and do not require your separate consent under applicable data protection laws

No promotional content in service communications

In accordance with regulatory guidance, any email containing promotional material is considered marketing, regardless of its primary purpose. We ensure that our service communications contain no promotional content (for example, links to new features, suggestions to upgrade, or special offers). Any communication containing such content will only be sent to users who have given explicit consent to receive marketing communications.

You may opt out of non-essential service communications at any time by switching off Product updates and offers under Account details in your dashboard, by clicking the unsubscribe link included in any such email, or by contacting us directly. You cannot opt out of essential service communications, which are necessary for the performance of our contract with you and for compliance with legal obligations.

7.2 Marketing Communications

We may use your contact details to send you information about our products, services, and other communications that may be of interest to you.

We will only send you marketing communications where:

You have provided your explicit, prior consent (by ticking an unchecked opt-in checkbox on our sign-up form or switching the preference on in your dashboard), or
We are otherwise permitted to do so under applicable data protection laws (for example, where permitted by the soft opt-in rules in certain jurisdictions, provided you have had a prior relationship with us and have been given a clear opportunity to opt out)

We do not and will not send marketing communications to users who have not given their explicit consent.

You may withdraw your consent or update your communication preferences at any time by:

Switching off Product updates and offers under Account details in your dashboard — this takes effect immediately
Clicking the unsubscribe link included in every marketing email
Contacting us using the details provided in this Privacy Policy

Opting out of marketing

If you opt out of receiving marketing communications, we will stop sending such communications. However, we may still send you essential service-related or transactional communications, including messages relating to your account, trial, subscription, or important service updates.

7.3 How We Obtain and Manage Consent for Marketing

Obtaining consent

When you create a dashboard account you are presented with a clear, unchecked opt-in checkbox for marketing communications. It is separate from the checkbox by which you accept our legal terms, and it is never pre-ticked — agreeing to our terms never signs you up for marketing. The checkbox reads:

“Email me product updates, offers, and educational content. You can unsubscribe at any time.”

If you do not tick it at sign-up, you can opt in later at any time from Account details in your dashboard.

Record of consent

We maintain a record of your consent, including:

The date and time you provided consent
The version of this Privacy Policy recorded against your account at that time
The method by which consent was obtained (the opt-in checkbox on the sign-up form, or the preference switch in your dashboard)

This record is kept for as long as we process your personal data for marketing purposes and for a reasonable period thereafter to demonstrate compliance.

Withdrawing consent

You may withdraw your consent for marketing communications at any time through any of the following methods:

Clicking the unsubscribe link included in every marketing email
Adjusting your communication preferences in your dashboard
Contacting us using the details provided in Section 17

Withdrawal takes effect immediately in your dashboard, and we will cease sending marketing communications within a reasonable time. We may continue to send you essential service communications as described in Section 7.1.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our website. For detailed information on the cookies we use, the purposes for which we use them, and how you can manage your preferences, please refer to our separate Cookie Policy.

9. Disclosures of Your Personal Data

Within TFP Software FZCO

Access to your personal data is granted only to those employees and contractors who have a need to access the information for a lawful purpose. We train our employees how to appropriately handle personal data.

Outside TFP Software FZCO

We may share your personal data with trusted third-party service providers who assist us in delivering our services. These may include:

A payment provider — none is engaged at present, because subscriptions are not open, so no data is shared for this purpose today. When subscriptions open, the provider we appoint will handle checkout, card details, invoicing and tax, and we will share your email, billing address and the plan you selected. We never see or store your card details.
Cloudflare — content delivery, security, and bot protection (including the anti-bot check on our sign-up, sign-in, and contact forms). Processes your IP address.
Our website and database hosting provider
Our email delivery provider, for account and service emails such as verification and password resets — and, only where you have given your explicit consent, for marketing email. Email providers are contractually obliged to process your data solely to deliver those messages on our behalf and in accordance with our instructions
Professional advisors (legal, accounting, audit), where required

We do not currently use any analytics or advertising provider, and we do not sell or rent your personal data to anyone.

We select our service providers carefully, ensuring they offer sufficient guarantees to implement appropriate technical and organizational measures that ensure compliance with data protection laws.

Law Enforcement, Courts, and Regulatory Authorities

We may disclose your personal data to government officials, law enforcement authorities, or regulatory bodies as necessary to comply with applicable laws, court orders, or legal process. We may also disclose data to establish or exercise our legal rights or defend against legal claims.

Business Transfers

In the event that we sell, transfer, or merge parts of our business or assets, or acquire other businesses, your personal data may be transferred to interested parties. We will only do this if the other parties agree to keep your personal data safe and private.

10. International Transfers

As a UAE-based company, we may transfer your personal data to countries outside your jurisdiction. We ensure appropriate safeguards are in place for all international data transfers.

Safeguards We Use

Adequacy Decisions: Where the destination country has been recognized by the European Commission or UAE authorities as providing adequate protection
Standard Contractual Clauses: We implement the European Commission's Standard Contractual Clauses (SCCs) or equivalent safeguards for transfers to countries without adequacy decisions
Transfer Impact Assessments: Where required, we conduct assessments to ensure appropriate safeguards are in place
Consent: Where required, we obtain explicit consent for international transfers

Jurisdiction	Transfer Basis
EU/EEA	Adequacy decisions or SCCs
UAE	Not applicable (within jurisdiction)
KSA	SCCs and Transfer Impact Assessments
Other MENA countries	SCCs or explicit consent as required

11. Data Security

We implement appropriate technical and organizational measures to safeguard your personal data from accidental loss, unauthorized access, misuse, alteration, or disclosure.

Our Security Measures Include

Encryption of sensitive data
Access controls and authentication
Secure data storage systems
Regular security assessments
100% MQL-native software with zero external DLL dependencies
Access granted only to those with a legitimate business need, under strict confidentiality obligations

Your Role in Security

You also have a role to play in protecting your data. We recommend using prudent measures to protect against unauthorized access to your account, including:

Logging out of your account when finished
Not sharing your login information
Using strong passwords

If a data breach occurs

If a personal data breach occurs, we will notify you and any applicable regulator where we are legally required to do so, and within the timeframes the applicable law sets.

12. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Data Type	Retention Period	Legal Basis
Active subscribers	Duration of subscription + reasonable period thereafter	Contractual necessity
Partner records	Duration of active partnership + reasonable period thereafter	Contractual necessity / Legitimate interests
Trial users who do not subscribe	Kept while your account exists. Deleted at any time on request, and removed when we review dormant accounts	Legitimate interests
Marketing data	Until you withdraw your consent. Withdrawal takes effect immediately and clears the consent record — your email address remains, because it is the identity you sign in with	Consent
Communication data	Correspondence is held in our support mailbox for the duration of your subscription + 1 year thereafter. The delivery record of our automated emails is tied to your account and is deleted with it	Contractual necessity / Legitimate interests
Inquiries and support requests	3 years after resolution	Legitimate interests
Regulatory and legal records	7 years (or as required by law)	Legal obligation

How we apply these periods

These periods are applied by review and on request rather than by an automatic timer: we do not run a scheduled process that deletes data once a period elapses. You can ask us to delete your personal data at any time using the contact details below, and we will do so unless we are legally required to keep it — see “Your Legal Rights” below for the one deliberate exception.

For existing relationships: We process and store your personal data as long as you maintain any type of relationship with us and such processing is necessary for the performance of our contractual obligations.

For terminated relationships: Where you have held a subscription or been paid partner commission, we will keep the records of that relationship for a period of 7 (seven) years from the date of termination to:

Maintain records according to applicable laws and regulations
Respond to any questions or complaints
Demonstrate fair treatment
Preserve evidence for the establishment, exercise, or defense of legal claims

For prospective clients: If you provide us with personal data for the purposes of becoming a client but do not complete the process, your personal data will be kept for a period of 6 (six) months.

When personal data reaches the end of the applicable period, or when you ask us to remove it, it is securely deleted or anonymized — carried out as described above rather than by an automatic process.

13. Your Legal Rights

Under applicable data protection laws, you have the following rights regarding your personal data:

Right	Description
Right to Access	Request a copy of the personal data we hold about you (subject access request)
Right to Rectification	Request corrections to inaccurate or incomplete data
Right to Erasure	Request deletion of your personal data in certain circumstances
Right to Restrict Processing	Request that we limit how we process your data
Right to Data Portability	Request that your data be transferred to another controller in a machine-readable format
Right to Object	Object to processing based on legitimate interests or direct marketing
Right to Withdraw Consent	Withdraw consent at any time where processing is based on consent
Right to Lodge a Complaint	Lodge a complaint with the relevant supervisory authority

How to Exercise Your Rights

To exercise any of these rights, please contact us through your dashboard or via the Contact page. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure.

Response Time

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Fees

We will not charge a fee for any of these rights unless your request is manifestly unfounded, excessive, or repetitive. In such cases, we may charge a reasonable administrative fee.

Limitations

Please note that some rights may be overridden by legal and regulatory obligations applicable to us. For example, we may not be able to delete your personal data if we have a legal obligation to retain it under applicable laws.

One specific exception you should know about: the record that a given MetaTrader account number has already used its one free trial is retained permanently, even if you delete your account. Without this, the free trial could be claimed repeatedly by re-registering, and we would have to withdraw it for everyone. This record consists of the account number and the date only — it holds no email address, name, or contact details, and is not used to identify you.

14. Children's Privacy

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from individuals under the age of 18.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately. We will use commercially reasonable efforts to delete that information unless we are required by law to retain it.

15. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. The "Last Updated" date at the top indicates when the latest changes were made.

Material Changes: If we make material changes to this Privacy Policy, we will notify our registered users by email or by posting a notification when you log into your dashboard.

Non-Material Changes: If any non-material changes to this Privacy Policy are unacceptable to you, you must immediately contact us and stop using our services until the issue is resolved. Your continued use of our services following the posting of non-material changes constitutes your acceptance of those changes.

16. Complaints

If you are unhappy with how we process your personal data, please inform us using the contact details in the "Contact Us" section below. We will do our best to address your concerns.

If you remain unsatisfied, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction:

Jurisdiction	Supervisory Authority
UAE	UAE Data Bureau
EU/EEA	Your local data protection authority
KSA	Saudi Data and Artificial Intelligence Authority (SDAIA)
Qatar	Ministry of Communications and Information Technology (MCIT)
Bahrain	Personal Data Protection Authority (PDPA)
Oman	Ministry of Transport, Communications and Information Technology
Kuwait	Communications and Telecommunications Regulatory Authority (CITRA)
Jordan	Personal Data Protection Council
Egypt	Personal Data Protection Centre (PDPC)
Morocco	National Control Commission for the Protection of Personal Data (CNDP)
Tunisia	National Authority for the Protection of Personal Data (INPDCP)
Algeria	National Authority for the Protection of Personal Data (ANPDP)
Cyprus	Office of the Commissioner for Personal Data Protection
Australia	Office of the Australian Information Commissioner (OAIC)

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

Method	Detail
Website	Contact page
Dashboard	Support section
Email	[email protected]
Post	TFP SOFTWARE - FZCO, IFZA Properties, DSO-IFZA, Dubai Silicon Oasis, Dubai, United Arab Emirates

The Friendly PARTNER — TFP Software FZCO
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