Privacy

Effective Date: March 9, 2022

The Gist

TraderWise will collect certain non-personally identifiable information about you as you use our sites. We may use this data to better understand our users. We can also publish this data, but the data will be about a large group of users, not individuals. We may also collect certain personal information about you and your use of the Service (as defined herein) which may be published and used in the aggregate as set forth in this Privacy Policy.

We will also ask you to provide personal information, but you’ll always be able to opt out. If you give us personal information, we won’t do anything evil with it.

We can also use cookies, but you can choose not to store these.

That’s the basic idea, but you must read through the entire Privacy Policy below and agree with all the details before you use any of our sites.

EU-U.S. Privacy Shield Framework

TraderWise adheres to the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Upon notification by the Privacy Shield team, TraderWise will update this Policy.

To learn more about the Privacy Shield program, and to view our certification once it is complete, please visit https://www.privacyshield.gov/.

Reuse

This document is based upon the Automattic Privacy Policy and is licensed under Creative Commons Attribution Share-Alike License 2.5. Basically, this means you can use it verbatim or edited, but you must release new versions under the same license and you have to credit Automattic somewhere (like this!). Automattic is not connected with and does not sponsor or endorse TraderWise or its use of the work.

TraderWise makes available services include our web sites (TraderWise.me (the “Site”)), our blog, our API, and any other software, sites, and services offered by TraderWise in connection to any of those (taken together, the “Service”). It is TraderWise’s policy to respect your privacy regarding any information we may collect while operating our Site.

Questions

If you have question about this Privacy Policy, please contact us at [email protected]

Visitors

Like most website operators, TraderWise collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. TraderWise’s purpose in collecting non-personally identifying information is to better understand how TraderWise’s visitors use its website. From time to time, TraderWise may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.

TraderWise also collects potentially personally-identifying information like Internet Protocol (IP) addresses. TraderWise does not use such information to identify its visitors, however, and does not disclose such information, other than under the same circumstances that it uses and discloses personally-identifying information, as described below. We may also collect and use IP addresses to block users who violated our Terms of Service.

Gathering of Personally-Identifying Information

Certain visitors to TraderWise’s websites choose to interact with TraderWise in ways that require TraderWise to gather personally-identifying information. The amount and type of information that TraderWise gathers depends on the nature of the interaction. TraderWise collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with TraderWise. TraderWise does not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain Service-related activities.

Additionally, some interactions, such as posting a comment, may ask for optional personal information. For instance, when posting a comment, may provide a website that will be displayed along with a user’s name when the comment is displayed. Supplying such personal information is completely optional and is only displayed for the benefit and the convenience of the user.

Aggregated Statistics and Third Party Analytics Providers

TraderWise may collect statistics about the behavior of visitors to and users of the Service. For instance, TraderWise may monitor the most popular parts of the TraderWise Site. TraderWise may display this information in the aggregate publicly or provide it to others.

In addition, TraderWise may, from time to time, collect certain personal information from you, your use of the Services, and/or the users of your website, such as your user churn rate, your financial data and revenue, your conversation rates and other metrics (your “Data”). TraderWise may publish and display your Data in the aggregate to the public through our Site or on our blog, e.g. by publishing a report on average churn rates on the Site. However, all Data is only used and published in the aggregate which means that any published Data will not identify you, your website, your company or your users, or link you to the published information in any way. If you wish to opt out of the publication of your Data, please contact us as [email protected].

TraderWise may also use third party analytics providers and products (collectively, “Third Party Providers”), to obtain, compile and analyze information (that may include personally-identifying information) about how users are using and interacting with TraderWise and/or the Services. Such information is compiled in the aggregate and anonymized (i.e. the aggregated data will not personally identify users in any way) and provided to Third Party Providers for analytics purposes only (e.g. obtaining statistics and other information about how users are using and interacting with TraderWise). These Third Party Providers may use a variety of established or new technologies or tools (including, without limitation, cookies, web beacons, HTTP cache, local shared objects and persistent identifiers) to recognize your computer or device and/or to collect or compile this information. You understand and acknowledge that TraderWise has no control over the technologies, tools or practices of the Third Party Providers providing analytics products and services to TraderWise.

TraderWise does not disclose personally-identifying information other than as described below.

Protection of Certain Personally-Identifying Information

TraderWise discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on TraderWise’ behalf or to provide services available at TraderWise’ Site websites, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using the Service, you consent to the transfer of such information to them. TraderWise will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, TraderWise discloses potentially personally-identifying and personally-identifying information only when required to do so by law, or when TraderWise believes in good faith that disclosure is reasonably necessary to protect the property or rights of TraderWise, third parties or the public at large. If you are a registered user of the Service and have supplied your email address, TraderWise may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with TraderWise and our products. We primarily use our website and blog to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. TraderWise takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.

Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the Service each time the visitor returns. TraderWise uses cookies to help TraderWise identify and track visitors, their usage of TraderWise Service, and their Service access preferences. TraderWise visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using TraderWise’s websites, with the drawback that certain features of TraderWise’s websites may not function properly without the aid of cookies.

Business Transfers

If TraderWise, or substantially all of its assets, were acquired, or in the unlikely event that TraderWise goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of TraderWise may continue to use your personal information as set forth in this policy.

Data Storage

TraderWise uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Service. You understand that although you retain full rights to your data, it may be stored on third party storage and transmitted through third party networks.

Privacy Policy Changes

Although most changes are likely to be minor, TraderWise may change its Privacy Policy from time to time, and in TraderWise’s sole discretion. TraderWise encourages visitors to frequently check this page for any changes to its Privacy Policy.

Privacy Shield Policy

TraderWise OÜ (“TraderWise”) has adopted this Privacy Shield Policy (“Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that TraderWise obtains from Customers located in the European Union and Switzerland.

TraderWise complies with the EU-U.S. Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Individual Customers in the European Union member countries and Switzerland. TraderWise adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page once it is complete, please visit https://www.privacyshield.gov.

The Federal Trade Commission (FTC) has jurisdiction over TraderWise’s compliance with the Privacy Shield.

All TraderWise employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.

Capitalized terms are defined in Section 14 of this Policy.

By using this Website, placing an order with TraderWise on this Website or through other means, clicking the “buy” button, or checking the terms and conditions box, you agree to the TraderWise Terms and Conditions set forth below, including, without limitation, the Privacy Policy https://www.traderwise.me/traders-journal/page/privacy

• SCOPE

This Policy applies to the processing of Individual Customer Personal Data that TraderWise receives in the United States and the United Kingdom concerning Individual Customers who reside in the European Union and Switzerland. TraderWise provides products and services to businesses and consumers.

This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)

• RESPONSIBLITIES AND MANAGEMENT

TraderWise will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. TraderWise personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that TraderWise has undertaken to protect Personal Data.

III.  RENEWAL / VERIFICATION

TraderWise is in the process of self-certification under EU-U.S. Privacy shield. TraderWise will renew its EU-U.S. Privacy Shield and Swiss-US Privacy Shield certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.

Prior to the re-certification, TraderWise will conduct an in-house verification to ensure that its attestations and assertions about its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, TraderWise will undertake the following:

• Review this Privacy Shield policy and its publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data
• Ensure that the publicly posted privacy policy informs Individual Customers of TraderWise’s participation in the EU-U.S Privacy Shield and Swiss-U.S. Privacy Shield programs and where to obtain a copy of additional information (e.g., a copy of this Policy)
• Ensure that this Policy continues to comply with the Privacy Shield principles
• Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (TraderWise may do so through its publicly posted website, Individual Customer contract, or both)
• Review its processes and procedures for training Employees about TraderWise’s participation in the Privacy Shield programs and the appropriate handling of Individual’s Personal Data

TraderWise will prepare an internal verification statement on an annual basis.

•  COLLECTION AND USE OF PERSONAL DATA

TraderWise provides various solutions to its Individual Customers who purchase its products. TraderWise collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, TraderWise individual customers may choose to seek live support or post to a message board.

The Personal Data that we collect may vary based on the Individual Customer’s interaction with our website and request for our services. As a general matter, TraderWise collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person’s name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information). Individual customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect information that they choose to provide to us through these portals.

When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.

The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.

For certain products, TraderWise serves as a service provider. In our capacity as a service provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent.

TraderWise uses Personal Data that it collects directly from its Individual Customers and for its partners indirectly in its role as a service provider for the following business purposes, without limitation:

• maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to a Individual Customer);
• satisfying governmental reporting, tax, and other requirements (e.g., import/export);
• storing and processing data, including Personal Data, in computer databases and servers located in the United States and the United Kingdom;
• verifying identity (e.g., for online access to accounts);
• as requested by the Individual Customer;
• for other business-related purposes permitted or required under applicable local law and regulation;
• and as otherwise required by law.

TraderWise does not disclose personal information to third parties for purposes that are materially different than what it was originally collected for. Should this change in the future, we will provide individuals with the option to opt-out.

•  DISCLOSURES/ ONWARD TRANSFERS OF PERSONAL DATA

Except as otherwise provided herein, TraderWise discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.

TraderWise may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, TraderWise may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by TraderWise and they must either:

• comply with the Privacy Shield principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Data;
• or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy;

TraderWise also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that TraderWise may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. TraderWise is liable for appropriate onward transfers of personal data to third parties.

• SENSITIVE DATA

TraderWise does not collect Sensitive Data from its Individual Customers.

VII.  DATA INTEGRITY AND SECURITY

TraderWise uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. TraderWise has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to TraderWise’s electronic information systems requires user authentication via password or similar means. TraderWise also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.

Further, TraderWise uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.

VIII.  NOTIFICATION

TraderWise notifies Individual Customers about its adherence to the EU-US Privacy Shield and Swiss-US Privacy Shield principles through its publicly posted website privacy policy, available at: https://www.traderwise.me/traders-journal/page/privacy and take Individual customers approval and adherence to the current policy when they provide their information to us in the transactional process.

•  ACCESSING PERSONAL DATA

TraderWise personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.

•  RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
• Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which TraderWise collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and TraderWise policies. Upon reasonable request and as required by the Privacy Shield principles, TraderWise allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting TraderWise by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to local TraderWise office.
• Requests for Personal Data. TraderWise will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If TraderWise receives a request for access to their Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, TraderWise will refer such Data Subject to the Individual Customer.
• Satisfying Requests for Access, Modifications, and Corrections. TraderWise will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

XII.  CHANGES TO THIS POLICY

This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.

XIII.  QUESTIONS OR COMPLAINTS

EU and Swiss Individual customers may contact TraderWise with questions or complaints concerning this Policy at the following address:

[email protected]

XIII.  ENFORCEMENT AND DISPUTE RESOLUTION

In compliance with the EU-U.S. and Swiss-US Privacy Shield Principles, TraderWise commits to resolve complaints about your privacy and our collection or use of your personal information. EU and Swiss individuals with questions or concerns about the use of their Personal Data should contact us at: [email protected].

If a Customer’s question or concern cannot be satisfied through this process TraderWise has further committed to refer unresolved privacy complaints under EU-U.S. Privacy Shield and Swiss-US Privacy Shield to an independent dispute resolution mechanism operated by the JAMS.

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by TraderWise, EU and Swiss individuals may bring a complaint before the JAMS EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks program can be found at: https://www.jamsadr.com/eu-us-privacy-shield.

Finally, as a last resort and in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

XIV.  DEFINED TERMS

Capitalized terms in this Privacy Policy have the following meanings:

“Individual Customer” means an Individual customer or client of TraderWise from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of TraderWise and all employee of TraderWise where TraderWise has obtained his or her Personal Data from such Individual Customer as part of its business relationship with TraderWise.

“Data Subject” means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.

“Employee” means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of TraderWise or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.

“Europe” or “European” refers to a country in the European Union.

“Personal Data” as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term “person” includes both a natural person and a legal entity, regardless of the form of the legal entity.

“Sensitive Data” means Personal Data that discloses a Data Subject’s medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.

“Third Party” means any individual or entity that is neither TraderWise nor an TraderWise employee, agent, contractor, or representative.