Orange Tree
Terms Privacy Risk Disclosure

Privacy Policy

Last updated: January 20, 2026

1. Overview and Scope

Orange Tree ("Orange Tree", "we", "us", or "our") is dedicated to upholding the privacy, confidentiality, and security of individuals who access our services. This Privacy Policy outlines the operational procedures through which we collect, process, store, disclose, and protect personal data collected via the Orange Tree platform, website, and technical interfaces.

We process personal data in strict adherence to applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and relevant privacy frameworks.

2. Data We Collect

In operating our trading infrastructure, we process categories of data necessary to provide and safeguard our services:

  • Identity and Contact Data: Full name, verified email address, phone number, and jurisdictional residency provided during communication or account configuration.
  • Technical and Connection Data: Internet Protocol (IP) addresses, device fingerprinting identifiers, browser type, operating system version, access timestamps, and routing latency records.
  • Platform Activity Data: Algorithmic strategy triggers, backtest parameters, platform diagnostic logs, and interaction analytics within user dashboards.
  • Exchange Credentials: Encrypted, restricted API access keys and secret tokens supplied by you to authorize automated trade execution on partner exchanges. We never request withdrawal-enabled API privileges.

3. Lawful Grounds and Purposes of Processing

We process personal data only when substantiated by valid lawful grounds under data protection law:

  • Contractual Performance: Establishing and maintaining your account, executing algorithmic commands requested by you, and routing trade configurations.
  • Legal and Regulatory Compliance: Fulfilling anti-money laundering obligations, fraud detection duties, and statutory recordkeeping mandates.
  • Legitimate Interests: Hardening technical infrastructure against cyberattacks, preventing abuse, optimizing execution speeds, and troubleshooting software errors.
  • Consent: Sending voluntary technical updates or marketing communications where express affirmative consent has been obtained. Consent can be revoked at any time.

4. Data Retention and Security Architecture

Orange Tree implements institutional-grade technical and organizational security controls to protect information against unauthorized modification, destruction, loss, or access. Security controls include AES-256 data encryption at rest, TLS 1.3 encryption in transit, strict role-based access governance, continuous vulnerability auditing, and hardware security modules (HSM) for credential isolation.

We retain your personal information only for as long as is necessary to deliver platform services and satisfy legal, accounting, and regulatory obligations. Once retention periods expire, data is securely wiped or irreversibly anonymized.

5. Information Sharing and Disclosure

Orange Tree does not sell, rent, or trade your personal data to third-party advertisers. We disclose data strictly on a need-to-know basis to:

  • Vetted cloud hosting, cybersecurity, and telecommunication infrastructure vendors operating under comprehensive data processing agreements.
  • Partner brokerage endpoints or exchange APIs authorized by you to receive algorithmic execution orders.
  • Law enforcement agencies, regulatory bodies, or judicial authorities when compelled by lawful subpoena, court order, or applicable statutory mandates.

6. International Data Transfers

Because our algorithmic infrastructure leverages globally distributed server networks, data may be processed outside of the United Kingdom or European Economic Area. When transferring data internationally, Orange Tree ensures equivalent protections through UK International Data Transfer Agreements (IDTAs), Standard Contractual Clauses (SCCs), or adequacy decisions.

7. Your Data Protection Rights

Under the UK GDPR and associated privacy regulations, you possess rights concerning your personal data:

  • Right of Access: Request a copy of the personal information we hold concerning you.
  • Right to Rectification: Request correction of inaccurate or incomplete personal records.
  • Right to Erasure: Request the deletion of personal data where retention is no longer justified.
  • Right to Restrict Processing: Request limits on how your personal information is processed under specific circumstances.
  • Right to Data Portability: Obtain your data in a structured, machine-readable format.
  • Right to Object: Object to processing grounded in legitimate interests or direct marketing.

To exercise these rights, please contact our Data Protection Team at [email protected].

8. Contact Our Data Protection Team

For questions, data access requests, or regulatory queries, please contact:

Orange Tree — Privacy Compliance
High Holborn 184, EC3M 4AJ Edinburgh, GB
Email: [email protected]
Phone: +44 20 7946 6513