1. INTRODUCTION AND SCOPE
This Privacy Policy (“Policy”) governs the collection, use, storage, disclosure, and protection of personal information by TradingInDepth.com (“Company,” “we,” “us,” or “our”) in connection with your (“User,” “you,” or “your”) access to and use of the website located at www.tradingindepth.com, including any associated subdomains, features, content, applications, and services offered thereon (collectively, the “Website”).
This Policy is incorporated by reference into the Company’s Terms of Service and constitutes a legally binding agreement between you and the Company. By accessing or using the Website, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree to the terms of this Policy, you must immediately cease all use of the Website.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. You are encouraged to periodically review this Privacy Policy to stay informed of updates.
2. INFORMATION COLLECTION
2.1 Categories of Personal Information
For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The Company may collect the following categories of Personal Information:
(a) Identifiers: Including but not limited to name, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, or other similar identifiers;
(b) Financial Information: Including but not limited to credit card number, debit card number, bank account information, or other payment information;
(c) Commercial Information: Including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
(d) Internet Activity Information: Including browsing history, search history, and information regarding your interaction with the Website, applications, or advertisements;
(e) Geolocation Data: Including physical location or movements;
(f) Sensory Data: Including audio, electronic, visual, or similar information;
(g) Professional or Employment-Related Information: Including current or past job history or performance evaluations; and
(h) Inferences: Including inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
2.2 Methods of Collection
The Company collects Personal Information through:
(a) Direct Interactions: Information you provide when you create an account, register for services, complete forms, correspond with us, or otherwise provide information directly to us;
(b) Automated Technologies: Information collected automatically through cookies, web beacons, server logs, and other tracking technologies when you interact with the Website;
(c) Third-Party Sources: Information obtained from business partners, analytics providers, social media platforms, and other third parties that provide services to us or with whom we have a business relationship.
3. LEGAL BASIS FOR PROCESSING
3.1 Lawful Bases
The Company processes Personal Information pursuant to the following lawful bases:
(a) Performance of Contract: Processing necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;
(b) Legitimate Interests: Processing necessary for the purposes of the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by your fundamental rights and freedoms which require protection of Personal Information;
(c) Compliance with Legal Obligation: Processing necessary for compliance with a legal obligation to which the Company is subject;
(d) Consent: Processing based on your freely given, specific, informed, and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of your Personal Information.
3.2 Legitimate Interests
Where the Company relies on legitimate interests as a lawful basis for processing, such legitimate interests include, but are not limited to:
(a) Providing, maintaining, and improving the Website and services;
(b) Developing new products and services;
(c) Marketing and promoting the Company’s products and services;
(d) Protecting the Company’s legal rights and interests;
(e) Detecting and preventing fraud and security incidents;
(f) Conducting business analytics and research; and
(g) Enforcing the Company’s terms, conditions, and policies.
4. USE OF PERSONAL INFORMATION
4.1 Business Purposes
The Company uses Personal Information for the following business purposes:
(a) To provide the Website and services, including to create and maintain your account, process transactions, and respond to your inquiries;
(b) To personalize your experience on the Website, including to recognize you when you return to the Website and to customize content and offerings;
(c) To improve and develop the Website and services, including to troubleshoot, test, research, and analyze how users access and use the Website;
(d) To communicate with you, including to send you technical notices, updates, security alerts, support messages, and administrative communications;
(e) To market and promote the Website and services, including to send promotional communications about products, services, offers, and events (subject to your marketing preferences);
(f) To monitor and analyze trends, usage, and activities in connection with the Website;
(g) To protect the Website and services, including to detect, investigate, and prevent fraudulent transactions and other illegal activities and to protect the rights, property, and safety of the Company, its users, and others;
(h) To debug to identify and repair errors that impair existing intended functionality of the Website;
(i) To comply with legal obligations, including to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
(j) For any other purpose disclosed to you at the time of collection or with your consent.
4.2 Change of Purpose
The Company will not process Personal Information for purposes that are materially different, unrelated, or incompatible with the purposes for which the Personal Information was collected or subsequently authorized by you, without notifying you and obtaining your consent.
5. DISCLOSURE OF PERSONAL INFORMATION
5.1 Categories of Recipients
The Company may disclose Personal Information to the following categories of recipients:
(a) Service Providers: Third-party vendors, consultants, and other service providers who require access to Personal Information to perform services on the Company’s behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance;
(b) Business Partners: Third parties with whom the Company has a business relationship, including joint marketing partners and other companies with whom we collaborate;
(c) Affiliates: Entities that control, are controlled by, or are under common control with the Company, including parent companies, subsidiaries, and other affiliated entities;
(d) Corporate Transactions: Third parties in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of the Company’s business to another company;
(e) Legal Authorities: Law enforcement, government officials, or other third parties as required by law, court order, subpoena, or other legal process, or when the Company believes in good faith that disclosure is necessary to protect the Company’s rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
(f) With Your Consent: Third parties with your consent or at your direction.
5.2 No Sale of Personal Information
The Company does not sell, rent, or lease Personal Information to third parties for monetary or other valuable consideration.
6. INTERNATIONAL DATA TRANSFERS
6.1 Cross-Border Transfers
The Company is a global business, and your Personal Information may be transferred to, stored at, or processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your home country. The Company implements appropriate safeguards to ensure that your Personal Information remains protected in accordance with this Policy and applicable law.
6.2 Transfer Mechanisms
When transferring Personal Information from the European Economic Area (“EEA”), United Kingdom, or Switzerland to countries that have not been deemed to provide an adequate level of data protection, the Company relies on one or more of the following legal mechanisms:
(a) European Commission Standard Contractual Clauses;
(b) Binding Corporate Rules;
(c) Consent to the transfer (in limited circumstances);
(d) Necessity for the performance of a contract between you and the Company;
(e) Other valid transfer mechanisms or derogations.
You may request a copy of the safeguards that the Company has put in place in respect of transfers of Personal Information by contacting the Company using the contact information provided in Section 13 of this Policy.
7. DATA SECURITY
7.1 Security Measures
The Company implements and maintains reasonable administrative, technical, and physical safeguards designed to protect Personal Information from unauthorized access, disclosure, alteration, or destruction. Such measures include, but are not limited to:
(a) Encryption of sensitive Personal Information in transit and at rest;
(b) Access controls and authentication mechanisms;
(c) Network and system monitoring;
(d) Regular security assessments and testing;
(e) Business continuity and disaster recovery plans; and
(f) Employee training on privacy and security practices.
7.2 Limitation of Liability
Despite the Company’s efforts to safeguard Personal Information, no security system is impenetrable, and the Company cannot guarantee the security of Personal Information. The transmission of information via the Internet or email is not completely secure. In the event that Personal Information is compromised as a result of a breach of security, the Company will promptly notify you in accordance with applicable law.
8. DATA RETENTION
8.1 Retention Period
The Company retains Personal Information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
8.2 Retention Criteria
To determine the appropriate retention period for Personal Information, the Company considers:
(a) The amount, nature, and sensitivity of the Personal Information;
(b) The potential risk of harm from unauthorized use or disclosure of the Personal Information;
(c) The purposes for which the Company processes the Personal Information and whether those purposes can be achieved through other means;
(d) Applicable legal, regulatory, tax, accounting, or other requirements; and
(e) Whether the Company has a legitimate interest in retaining the Personal Information that overrides the interests, rights, and freedoms of the individual.
8.3 Disposal
When Personal Information is no longer needed for the purposes for which it was collected, the Company will dispose of such information securely in accordance with applicable law.
9. YOUR RIGHTS AND CHOICES
9.1 Access and Control
Depending on your jurisdiction, you may have certain rights with respect to your Personal Information, including:
(a) Right to Access: The right to request information about the Personal Information the Company holds about you and to obtain a copy of such Personal Information;
(b) Right to Rectification: The right to request correction of inaccurate Personal Information or completion of incomplete Personal Information;
(c) Right to Erasure: The right to request deletion or removal of Personal Information where there is no compelling reason for its continued processing;
(d) Right to Restrict Processing: The right to request the Company to suspend the processing of your Personal Information;
(e) Right to Data Portability: The right to request a copy of your Personal Information in a structured, commonly used, machine-readable format;
(f) Right to Object: The right to object to processing of your Personal Information based on legitimate interests or for direct marketing purposes;
(g) Right to Withdraw Consent: The right to withdraw consent at any time where the Company relies on consent to process your Personal Information; and
(h) Right to Non-Discrimination: The right not to be subject to discriminatory treatment for exercising your privacy rights.
9.2 Exercise of Rights
To exercise any of the rights described above, please submit a verifiable request to the Company using the contact information provided in Section 13 of this Policy. The Company may request specific information from you to help confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it.
9.3 Response Timeline
The Company will respond to verifiable requests within the timeframes required by applicable law. In certain circumstances, the Company may extend the response period, in which case you will be informed of the extension and the reason for the delay.
9.4 Limitations and Exceptions
Your rights with respect to your Personal Information are not absolute. In certain circumstances, the Company may limit your rights or deny your request as permitted by applicable law. If the Company denies your request, you will be provided with the reason for such denial to the extent required by law.
10. COOKIES AND TRACKING TECHNOLOGIES
10.1 Use of Cookies
The Company uses cookies, web beacons, pixel tags, and similar tracking technologies (collectively, “Cookies”) to collect and store information when you use the Website. Cookies are small text files that are stored on your device when you visit a website. The Company uses both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until they expire or you delete them).
10.2 Types of Cookies
The Company uses the following types of Cookies:
(a) Strictly Necessary Cookies: Cookies that are essential for the operation of the Website, including to enable you to navigate the Website and use its features;
(b) Functional Cookies: Cookies that allow the Website to remember choices you make (such as your username, language, or region) and provide enhanced, personalized features;
(c) Performance/Analytical Cookies: Cookies that collect information about how users interact with the Website, including which pages are visited most often, how users navigate the Website, and whether users encounter errors. These Cookies do not collect information that identifies you directly;
(d) Targeting/Advertising Cookies: Cookies that are used to deliver advertisements relevant to you and your interests, track the effectiveness of advertising campaigns, and limit the number of times you see an advertisement.
10.3 Third-Party Cookies
The Company allows certain third parties, such as analytics providers and advertising networks, to set Cookies on the Website. These third parties may collect information about your online activities over time and across different websites when you use the Website.
10.4 Cookie Management
Most web browsers are set to accept Cookies by default. You can typically remove or reject Cookies through the settings on your browser. Please note that blocking or deleting Cookies may impact your ability to use certain features of the Website.
For more detailed information about the Cookies the Company uses and how to manage your Cookie preferences, please refer to the Company’s Cookie Policy.
11. CHILDREN’S PRIVACY
11.1 Age Restriction
The Website is not directed to individuals under the age of sixteen (16) years, and the Company does not knowingly collect Personal Information from individuals under sixteen (16) years of age.
11.2 Removal of Information
If the Company learns that it has collected or received Personal Information from an individual under sixteen (16) years of age without verification of parental consent, the Company will delete such information in accordance with applicable law. If you believe the Company might have any Personal Information from or about an individual under sixteen (16) years of age, please contact the Company using the contact information provided in Section 13 of this Policy.
12. CHANGES TO THIS POLICY
12.1 Policy Updates
The Company reserves the right to modify this Policy at any time in accordance with applicable law. If the Company makes material changes to this Policy, the Company will notify you by updating the effective date of this Policy and posting the revised Policy on the Website. In certain circumstances, the Company may provide additional notice, such as sending you an email notification.
12.2 Your Continued Use
Your continued use of the Website after the effective date of the revised Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must immediately cease all use of the Website.
13. CONTACT INFORMATION
13.1 Contact Details
If you have any questions, concerns, or requests regarding this Policy or the Company’s privacy practices, please contact the Company at:
Email: info@tradingindepth.com
13.2 Data Protection Inquiries
For inquiries specifically related to data protection, including requests to exercise your rights under applicable data protection laws, please specify the nature of your request in your communication to the Company.
14. JURISDICTION-SPECIFIC PROVISIONS
14.1 European Economic Area, United Kingdom, and Switzerland
If you are located in the European Economic Area (“EEA”), United Kingdom, or Switzerland, the following additional provisions apply:
(a) Data Controller: The Company is the data controller responsible for processing your Personal Information.
(b) Supervisory Authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of your Personal Information infringes the General Data Protection Regulation (“GDPR”) or other applicable data protection laws.
(c) Automated Decision-Making: The Company does not engage in automated decision-making, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where permitted by applicable law.
14.2 California Residents
If you are a resident of California, the following additional provisions apply:
(a) California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”): California residents have specific rights regarding their Personal Information under the CCPA and CPRA, including:
(i) The right to know what Personal Information the Company has collected, used, disclosed, and sold about them;
(ii) The right to request deletion of their Personal Information;
(iii) The right to correct inaccurate Personal Information;
(iv) The right to opt-out of the sale or sharing of their Personal Information;
(v) The right to limit the use and disclosure of sensitive Personal Information; and
(vi) The right to non-discrimination for exercising their CCPA/CPRA rights.
(b) Shine the Light Law: California residents who have provided Personal Information to the Company may request information about the Company’s disclosures of certain categories of Personal Information to third parties for their direct marketing purposes.
(c) Do Not Track Signals: The Company does not currently respond to “do not track” signals or similar mechanisms.
14.3 Other Jurisdictions
The Company is committed to complying with applicable privacy and data protection laws in all jurisdictions in which it operates. If you have questions about your rights under local privacy and data protection laws, please contact the Company using the contact information provided in Section 13 of this Policy.
15. MISCELLANEOUS
15.1 Third-Party Links
The Website may contain links to third-party websites, products, or services. The Company is not responsible for the privacy practices or content of such third parties. We encourage you to read the privacy policies of these third parties before providing any information to them.
15.2 Interpretation
The headings used in this Policy are included for convenience only and will not limit or otherwise affect this Policy. In the event of any conflict between this Policy and any other agreement or understanding between you and the Company regarding the subject matter hereof, this Policy shall govern.
15.3 Severability
If any provision of this Policy is held by a court of competent jurisdiction to be illegal, invalid, or unenforceable, the legality, validity, and enforceability of the remaining provisions of this Policy will not be affected or impaired thereby.
15.4 Waiver
The failure of the Company to enforce any right or provision of this Policy will not constitute a waiver of such right or provision.
15.5 Assignment
The Company may assign or transfer this Policy, and its rights and obligations hereunder, without your consent, to any entity that acquires or is an assignee of the Company or the Website.
15.6 Entire Agreement
This Policy, together with the Terms of Service and any other agreements expressly incorporated by reference herein, constitute the entire agreement between you and the Company concerning the Website and supersede all prior agreements, understandings, representations, and warranties, both written and oral, with respect to the Website.