Last updated: 7 August 2026
This policy explains what ReferenceFee OÜ (“we”) does with personal data. We are the data controller. Registered office: Paavli tn 5a/1, Põhja-Tallinna, 10412 Tallinn, Estonia. Contact: [email protected].
What we collect
- Account data: the email address you register with, and your password in hashed form.
- Exchange link: which exchange you selected and the UID (user ID) you entered.
- Rebate data: the trading volume and fee totals your UID generated, as reported to us by the exchange’s partner dashboard, and the rebates we paid.
- Technical data: IP address, browser and device information, and pages visited, collected through our website analytics.
What we never collect
We do not ask for and do not receive API keys, exchange passwords, wallet private keys or seed phrases, or identity documents. We do not see your open positions, trading pairs, direction, leverage, profit and loss, deposits or withdrawals. A UID is an account number; it cannot be used to sign in, move funds or place orders.
Why we process it, and on what legal basis
- To provide the service — creating your account, linking your UID, calculating and paying rebates. Legal basis: performance of a contract with you.
- To support you — answering emails about your account. Legal basis: performance of a contract, and our legitimate interest in running a support function.
- To keep the service working and secure — diagnostics, fraud and abuse prevention. Legal basis: our legitimate interests.
- Analytics — understanding how the website is used. Legal basis: your consent where required by law.
- Legal and accounting obligations — record keeping. Legal basis: compliance with a legal obligation.
Who we share it with
Your UID is shared with the exchange you selected, because the exchange must be able to attribute your trading activity to your rebate account. We also use service providers that process data on our behalf, including website hosting, email delivery and website analytics. We do not sell personal data and we do not share it for third-party advertising.
Cookies and analytics
This website uses Google Tag Manager and analytics cookies to measure traffic. Advertising and measurement pixels may also be present. You can block or delete cookies in your browser; essential parts of the site will continue to work.
International transfers
Some of our providers may process data outside the European Economic Area. Where that happens, we rely on transfer mechanisms permitted under the GDPR, such as the European Commission’s standard contractual clauses.
How long we keep it
We keep account and rebate records for as long as your account is open, and afterwards for the period required by applicable accounting and tax law. Technical and analytics data is kept for a shorter period. When data is no longer needed, it is deleted or anonymised.
Your rights
Under the GDPR you may request access to your data, correction of inaccurate data, deletion, restriction of processing, and portability. You may object to processing based on legitimate interests, and withdraw consent at any time where processing is based on consent. To exercise any of these, email [email protected].
If you believe we have handled your data unlawfully, you may lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or with the supervisory authority in your country of residence.
Children
The service is not directed at, and may not be used by, anyone under 18.
Changes
We may update this policy. The date at the top shows when it last changed.