Privacy policy.

RAM Trader (“RAM Trader”, “we”, “us”, “our”) is a sandbox exchange for virtual PC hardware. It is operated by Wayne Enterprise Ltd, a company registered in England and Wales (company number 00000000), with its registered office at 221b, Baker Street, London A00 0AA, United Kingdom.

We are the data controller for the personal data described here. This policy explains what we collect when you create an account and use the exchange, how and why we use it, who we share it with, and the rights you have under UK data protection law — the UK GDPR and the Data Protection Act 2018.

Questions or requests about your data? Email us at contact@wayne-enterprise.co.uk or write to the registered office above, marking your letter “Privacy request”.

We collect and process the following categories of personal data:

Account information

• Email address
• First and last name (also shown as your display name)
• Date of birth — used to confirm you are 18 or over
• Investing-experience level, from the sign-up questionnaire
• Password — stored only as a salted scrypt hash, never in plain text

Activity data

• Virtual balance and transaction history
• Trades, lootbox openings and portfolio holdings
• Leaderboard ranking and performance

Technical information

• IP address
• Browser type and version
• Device and operating system
• Pages visited and session activity
• Cookies and similar identifiers

We do not intentionally collect special category data, and we do not collect real payment card or banking details — see “Payments” below.

We use your personal data to:

• Create, secure and maintain your account
• Confirm you meet the 18+ age requirement
• Operate the exchange — execute simulated trades, value your portfolio and rank the leaderboard
• Keep the service running, prevent abuse and protect other users
• Respond to your questions and support requests
• Review, in aggregate, how the service is used so we can improve it
• Comply with our legal obligations

Under the UK GDPR, we rely on the following lawful bases:

• Performance of a contract — to create your account and provide the exchange you sign up for
• Legitimate interests — to secure the service, prevent abuse and improve the product, balanced against your rights and freedoms; we have carried out a legitimate interests assessment and can provide a summary on request
• Consent — for any non-essential cookies or optional communications; you can withdraw it at any time
• Legal obligation — where the law requires us to keep or disclose information

We do not currently send marketing communications. If we introduce them, we will rely on your consent or another lawful basis, and you will have the right to object to direct marketing at any time — no balancing test applies — using the unsubscribe link in any message or by emailing us. Service messages about your account, such as security or support notices, are not marketing and may still be sent.

RAM Trader is a simulation. Balances, prices and trades are virtual and denominated in the in-game currency. We do not currently collect, process or store real payment card numbers, security codes or banking details.

The platform is built payment-ready. Before any real-money payment processing goes live, payments will be handled by a PCI-DSS-compliant third-party provider, and we will update this policy to describe that processing before it begins.

We apply appropriate technical and organisational measures to protect your data: passwords are stored only as salted scrypt hashes, data is encrypted in transit, access is restricted to authorised personnel who need it, and we monitor and back up our systems.

No method of transmission or storage is completely secure, but we work to keep your data protected. We will report qualifying personal data breaches to the Information Commissioner’s Office within 72 hours, and notify affected users where a breach is likely to result in a high risk to their rights and freedoms.

We do not sell, rent or trade your personal data. We share it only:

• With service providers that help us run the platform (for example hosting and infrastructure), under contracts that require equivalent protection
• Where required by applicable law, regulation or a valid legal request
• To protect the rights, safety and security of the service and its users

Where a provider processes data outside the UK or EEA, we rely on an adequacy decision or on UK-approved safeguards such as the International Data Transfer Agreement or Standard Contractual Clauses. You can ask us which countries your data may be transferred to and request a copy of the relevant safeguards.

We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing. Leaderboard ranking, portfolio valuation and abuse-prevention checks are automated, but they do not have that kind of effect.

We use a small number of strictly necessary and functional cookies — to keep you signed in, remember your display-currency preference, and pre-fill the email you last signed in with. We do not use advertising, analytics or third-party tracking cookies. See our Cookie Policy for the full list, durations and how to control them.

We keep your information only as long as we need it:

• Account data — while your account is open; if you close it, we delete or anonymise it within 30 days
• Activity data (trades, holdings, leaderboard) — for the life of the account, then deleted or anonymised with it
• Security and abuse-prevention logs — up to 12 months
• Records we must keep to meet legal or tax obligations — for as long as the law requires

You can ask us to delete your account and associated data at any time.

Under UK data protection law, you have the right to:

• Access the personal data we hold about you
• Have inaccurate or incomplete data corrected
• Have your data erased
• Restrict or object to certain processing
• Receive your data in a portable format (data portability)
• Withdraw consent where our processing relies on it

To exercise any of these rights, contact us at contact@wayne-enterprise.co.uk. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority, at ico.org.uk — though we would appreciate the chance to put things right first.

RAM Trader is intended for adults aged 18 and over, and we confirm your date of birth at sign-up. We do not knowingly collect personal data from anyone under 18; if we learn that we have, we will delete it.

We may update this Privacy Policy from time to time. Material changes will be posted on this page with a new “last updated” date, and significant changes may also be flagged in-product.

Questions about this policy or how we handle your data? Email contact@wayne-enterprise.co.uk, write to Wayne Enterprise Ltd, 221b, Baker Street, London A00 0AA, United Kingdom, or reach us through the contact page.