Privacy Policy

Last updated: 16 June 2026

This Privacy Policy describes how Commodity Technologies Limited ("Commodity Technologies", "we", "us") collects, uses, and shares information in connection with your use of CT Chat, ctchat.com, and all related mobile applications and services (collectively, the "Services").

Information We Collect

We collect information in the following ways:

• Account information: When you create an account, we collect your name, email address, and other information you provide.
• Usage information: We collect information about how you interact with our Services, including the features you use and the actions you take.
• Device information: We collect information about the devices you use to access our Services, including device type, operating system, and unique device identifiers.
• Contact form submissions: When you contact us via our website, we collect the name, company, email address, and message you provide.

How and Why We Use Information

We use the information we collect to:

• Provide, maintain, and improve our Services;
• Communicate with you about our Services, including responding to your enquiries;
• Monitor and analyse trends and usage to improve user experience;
• Protect the security of our Services, detect and prevent fraud and abuse;
• Comply with legal obligations.

Legal Bases for Processing (EU/UK)

For individuals in the European Union or United Kingdom, our processing of your information is based on: (1) the necessity to fulfil our commitments to you under applicable terms of service; (2) compliance with legal obligations; (3) protection of vital interests; (4) our legitimate interests in providing and improving our Services; or (5) your consent.

How We Share Information

We do not sell your personal information. We share information only in the following limited circumstances:

• Service providers: Third party vendors who assist in providing our Services (e.g. hosting, payment processing, email delivery). We require vendors to protect your information in accordance with this policy.
• Legal requirements: When required by law, subpoena, court order, or governmental request.
• Protection of rights: When we believe disclosure is necessary to protect the rights, property, or safety of Commodity Technologies, our users, or the public.
• Business transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred. This Privacy Policy would continue to apply.
• With your consent: We may share information with your explicit consent or at your direction.

Compliance Recording

CT Chat provides compliance recording functionality for regulated firms. Messages sent to or from a firm-managed (recorded) account are archived by the firm. Recording is never applied retroactively. Compliance archives belong to the firm, not to Commodity Technologies.

How Long We Keep Information

We retain information for as long as necessary to provide our Services and fulfil the purposes described in this policy, unless a longer retention period is required by law. Server logs are typically retained for approximately 30 days.

Security

We take reasonable measures to protect your information against unauthorised access, use, alteration, or destruction. No online service is 100% secure, and we cannot guarantee absolute security.

Your Rights

If you are located in the EU, UK, or other jurisdictions with applicable data protection laws, you have the right to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to or restrict our processing of your personal data;
• Request portability of your personal data.

To exercise these rights, please contact us using the details below. EU/UK individuals also have the right to lodge a complaint with a supervisory authority.

Controller

Commodity Technologies Limited is the controller of personal information processed through our Services.

How to Reach Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us at support@thectgrid.com.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting on our website or sending you a communication. Your continued use of our Services after changes take effect constitutes acceptance of the updated policy.